• ESG policy

      • Introduction

      • Wealtheon acknowledges the importance of sustainability within the financial sector and aims to be transparent about the way sustainability aspects are taken into account in its activities.

        Wealtheon currently does not consider the principal adverse impacts on sustainability factors (Principal Adverse Impacts, PAI) in its investment decisions.

        Currently, Wealtheon also does not offer solutions that take into account a broad range of sustainability criteria, nor products with a sustainable investment objective (Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, SFDR) and Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 (Regulatory Technical Standards, RTS)).

  • 2. Current approach to sustainability

    2.1 Sustainability risks

    Wealtheon does not apply a formal sustainability framework. Investment decisions are made taking into account economic risks and return considerations. Where relevant, potential sustainability risks may be considered as part of the overall risk assessment.

    Wealtheon applies the following exclusions and restrictions within its investment policy:

    • Defense industry: Wealtheon does not exclude investments in companies active in the defense industry but will comply with the restrictions imposed by national and European regulations, for example regarding the prohibition on anti-personnel mines.
    • Tobacco industry: No investments in companies that produce tobacco products, i.e., listed companies whose main activity consists of the production of tobacco and tobacco-related products.
    • Gambling industry: No investments in companies active in the gambling industry. Companies that only provide (supporting) technological solutions or platforms that may also be used by other sectors are not excluded.
    • Pornographic industry: No investments in companies engaged in the pornographic industry.

    These exclusions reflect Wealtheon’s current ethical and societal values without being positioned as a sustainable investment strategy within the meaning of the SFDR.

    3. Non-consideration of adverse impacts

    Wealtheon currently does not take into account the principal adverse impacts (PAI) of investment decisions on sustainability factors (Cf. Article 4(1)(b) SFDR).

    The reasons for this are:

    • Economic considerations prevail in the investment decision-making process;
    • The available sustainability criteria and indicators vary significantly in terms of methodology and data quality, limiting reliable comparison between financial instruments;
    • The data required to assess adverse effects on sustainability factors are often incomplete or unavailable;
    • Given the nature and scale of Wealtheon’s activities, and the limited availability of consistent and comparable information, systematic integration of adverse effects on sustainability factors in investment decisions is currently not considered proportionate.

    4. Review of this position

    Wealtheon currently has no intention of systematically considering the adverse impacts on sustainability factors in its investment decisions. This position may be reviewed in the future as a result of further European regulation or market developments.

    Any change to this position will be made public on the Wealtheon website (In accordance with the transparency obligations under the SFDR and RTS).

    5. Product offering and sustainability preferences

    When clients indicate that they have sustainability preferences, Wealtheon communicates transparently that it currently does not offer solutions that take into account a broad range of sustainability criteria, but only applies the exclusions mentioned above.

    6. Final provision

    The last update of this policy was on 14/10/2025 and will be reviewed annually. Any material change will be made public through the Wealtheon website.

    The monitoring and periodic review of this ESG Policy fall under the responsibility of Wealtheon’s Compliance function, in consultation with the Management.