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Sustainable Finance Disclosure RegulationSustainableFinanceDisclosureRegulation

Dec 31, 2022

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Status under EU Regulation 2019/2088 Sustainable Finance Disclosure Regulation (“SFDR”)

Sustainability risks

The SFDR requires PGIM Wadhwani LLP (“PGIM Wadhwani”) to determine, on a product-by-product basis, whether sustainability risks are relevant to the Investment Manager’s in-scope financial products (the “Products”).

For the purposes of SFDR, “sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

PGIM Wadhwani has determined that sustainability risks are not relevant to the Products on the basis that in light of their investment strategies, and in particular in light of the algorithmic /quantitative strategy employed PGIM Wadhwani on behalf of the Products, PGIM Wadhwani considers that environmental, social or governance events or conditions are unlikely to cause a material negative effect on the returns of the Products.

Consequently, PGIM Wadhwani does not integrate sustainability risks into its investment decision making for the Products, and has not assessed the likely impacts of sustainability risks on the returns of the Products.

No consideration of adverse impacts

The Sustainable Finance Disclosure Regulation requires PGIM Wadhwani to disclose whether, and if so how, it considers the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR. PGIM Wadhwani does not currently consider the principal adverse impacts of its investment decisions on sustainability factors.

PGIM Wadhwani has carefully evaluated the requirements of the PAI regime in Article 4 SFDR, and in the Regulatory Technical Standards (the “PAI regime”). PGIM Wadhwani considers that its primary investment strategies and client relationships do not support adoption of the PAI regime within SFDR. Certain of the PGIM Wadhwani’s products involve investment strategies where it is not possible to conduct detailed diligence on the principal adverse impacts of PGIM Wadhwani’s investment decisions on sustainability factors, including algorithmic or quantitative trading and macro strategies.

PGIM Wadhwani will keep its decision not to comply with the PAI regime under regular review, and will formally re-evaluate the decision at least annually.

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For Professional Investors only. All investments involve risk, including the possible loss of capital.

The content and materials presented here are for informational and educational purposes only and should not be construed as investment advice or an offer or solicitation in respect of any products or services to any persons who are prohibited from receiving such information under the laws applicable to their place of citizenship, domicile or residence. PGIM Wadhwani LLP (PGIM Wadhwani), formerly known as QMA Wadhwani LLP, is authorized and regulated by the Financial Conduct Authority in the United Kingdom (Firm Reference Number 219900) and is an SEC-registered investment adviser in the United States. Registration with the SEC does not imply a certain level of skill or training. As a foreign registered investment adviser PGIM Wadhwani must comply with all provisions of the Advisers Act of 1940, as amended, only with respect to clients who are US persons. PGIM Wadhwani is an indirect, wholly-owned subsidiary of PGIM, Inc. (PGIM), the principal asset management business of Prudential Financial, Inc. (PFI), a company incorporated and with its principal place of business in the United States. PFI of the United States is not affiliated in any manner with Prudential plc, incorporated in the United Kingdom or with Prudential Assurance Company, a subsidiary of M&G plc, incorporated in the United Kingdom.

In the United Kingdom, information is issued by PGIM Wadhwani with registered office: 9th Floor, Orion House, 5 Upper St. Martin's Lane, London WC2H 9EA. In the European Economic Area (“EEA”), information is issued by PGIM Limited with registered office: Grand Buildings, 1-3 Strand, Trafalgar Square, London, WC2N 5HR in reliance on provisions, exemptions or licenses available to PGIM Limited under temporary permission arrangements following the exit of the United Kingdom from the European Union. PGIM Limited is authorised and regulated by the Financial Conduct Authority (“FCA”) of the United Kingdom (Firm Reference Number 193418). In certain EEA countries, information is, where permitted, presented by PGIM Netherlands B.V. with registered office: Gustav Mahlerlaan1212, 1081 LA Amsterdam, The Netherlands. PGIM Netherlands B.V. is authorised by the Autoriteit Financiële Markten(“AFM”) in the Netherlands (Registration number 15003620) and operating on the basis of a European passport. 
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