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Investments

The scheme can invest in a wide range of assets, subject to the approval of the Retirement Scheme Trustee - MC Trustees (Malta) Limited.

If the member of a Retirement Scheme has been tax resident in the United Kingdom in any of the last 5 complete tax years we restrict the investments to those which we would permit in a UK Registered Pension Scheme.

After 5 complete UK tax years of non-residency the funds can be invested in other assets at the discretion of the Retirement Scheme Administrator.

We will not make any investments the purchase of which would trigger a tax charge from HMRC (Her Majesty's Revenue & Customs).

The Scheme Bankers are Lombard Bank Malta PLC.

You can chose your own investment manager or adviser who must be regulated to an equivalent standard as in Malta.

Please note that the Trustee does not accept responsibility for the performance of any investment or liabilities associated with any investment.

The Trustee will monitor all investments so that the principles of prudence and diversification are adhered to in the exercise of its trusteeship obligations.  Your regulated Investment Manager and Adviser (if you have one) should help us with this information.

If you would like a specific Investment Manager to be appointed for your Individual Fund, please let us know.  An Investment Manager provides advice on the member’s assets in the retirement scheme but ultimate responsibility for ascertaining the suitability of the investment is vested with MC Trustees (Malta) Limited.

MC Trustees (Malta) Limited (the “Company”) has a sustainability risk policy in place which outlines its assessment and monitoring processes relating to environmental, social and governance (together “ESG”) outcomes and sustainability risk which may be found attributable to the investment mandates it approves (the “Sustainability Policy”). To this effect, the Sustainability Policy forms an integral part of the investment strategy of the Company and ensures that, where applicable, any approved investment mandates take into account ESG outcomes and sustainability risks.

No consideration of sustainability adverse impacts

In terms of EU Regulation 2019/2088 on sustainable-related disclosures in the financial services sector (the “SFDR”), financial market participants must make specific disclosures on their assessment of ESG outcomes on any investments made/executed thereby, one of which is whether ‘principal adverse impacts’ (as defined in the SFDR) of investment decisions, are considered.

In this respect, the Company wishes to inform both existing and prospective members of the pension schemes which it administers, that it does not make considerations of principal adverse impacts on investment decisions on sustainability factors, and accordingly, limits its assessment to ensuring that sustainability risk is taken into consideration by the members of the pension schemes/their investment advisors.

The reasons for the Company opting-out of its consideration of principal adverse impacts as aforesaid, are as follows:

  1. In light of the composition of the portfolios to-date, any investment decisions approved, are considered unlikely to have a principal adverse impact on sustainability factors, including ESG outcomes;
  2. To-date, the portfolios are considered to be too small in size, to have a principal adverse impact on sustainability factors, including ESG outcomes; and
  3. The Company, when approving an investment mandate received by the members of the pension schemes/their investment advisors, may take into account any directions received in writing from them, indicating their preference with respect to an investment. However, the Company has not received any indications by any members/their advisors of any such preference(s), to approve investment mandates which promote ESG outcomes. Therefore, the potential of any investment mandates to have principal adverse impacts on ESG outcomes is perceived, at least to-date, to be minimal, at most.

Integration of Sustainability Risk in the Company’s Remuneration Policy

In line with our Remuneration Policy, no variable remuneration is paid to our staff unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.

We view our Remuneration Policy to be consistent with the integration of sustainability risks, to the effect that there is no component of its structure which is geared towards creating an incentive or bias towards excessive risk taking to the detriment of ESG outcomes and/or sustainability generally.

Thus, we believe that our existing structures are sufficient to prevent excessive risk taking in respect of sustainability risks, if any.