Statement on principal adverse impacts of investment decisions on sustainability factors

J & E Davy Unlimited Company, LEI Code 63540061DPCBNMCGRY22

Published 30/06/2025

Summary

J & E Davy Unlimited Company, LEI Code 63540061DPCBNMCGRY22 provides wealth management and investment banking services from five locations across Ireland and the UK. The scope of this statement relates to our investment activities within wealth management in Ireland, covering advisory and discretionary services to retail and institutional clients.

The statement includes mandatory as well as additional voluntary principal adverse impacts (PAIs) for 2024.
Davy is committed to responsible investing, with our approach to the embedding of Environment, Social and Governance (ESG) factors in our discretionary investment processes described in our responsible investment policy. We are a member of the UNPRI, and a party to a number of related collaborative engagements, a signatory to the UN Global Compact and have offered responsible investment solutions to our clients for more than a decade.

We are now investing in an expansion of our advisory responsible investment solutions, as well as raising client and public awareness of the availability of our discretionary offering via dedicated marketing campaign.

Simultaneously, we are working with partners to develop a more granular understanding of the factors underpinning ESG performance of our discretionary as well as our advisory portfolios to support our decision making.

The report which follows shows notable improvements in certain of our primary indicators, specifically the GHG intensity of all of client investments. These improvements have been driven substantially by changes in our discretionary portfolios, where the Davy investment team is most directly involved in decision-making. We do not have access to market-wide data to test our relative performance but will supplement our report once available.

Against this, and reflecting changes in the composition of our advisory portfolios, the GHG intensity of our investee companies increased through 2024 with the GHG intensity of investee countries falling. In the case of both, our discretionary portfolios registered change which was both positive in an absolute sense and relative to advisory.

A significant number of the additional metrics of note recorded an MSCI methodology change in 2024, reducing direct comparability with 2023, or have a reporting coverage so low as to impair reliability.

We endeavour across the piece to provide an explanation on the underlying cause of the year-on-year change, split appropriately across advisory and discretionary, and describe actions which we are taking to make positive change.

As additional information becomes available, we will update this statement appropriately

Adverse Impact Indicators

EU Sustainable Finance Disclosure Regulation (EU SFDR) aims to assist investors in making informed decisions about the sustainability characteristics of their investments. With this aim in mind, the Regulation seeks to standardise sustainability disclosures made by Financial Market Participants (FMPs) and Financial Advisers

Mandatory Principal Adverse Impact Indicators (PAIs)

In line with EU SFDR, 18 mandatory PAIs are disclosed to provide investors with a comprehensive understanding of the potential adverse impacts that our investment decisions may have on the environment, society, and good governance. These indicators relate to 3 areas – Companies, Sovereigns, and Real Estate Assets. The EU SFDR requires assessment and consideration of 18 mandatory indicators under the headings of Environmental and Social.

A component of these disclosures will consider how J & E Davy assesses potential adverse impacts of its investment decisions and financial advice on the environment and social factors.

Table 1 - Indicators applicable to investments in investee companies

Adverse sustainability indicator		Metric	Impact Year 2024	Impact Year 2023	Coverage* Year 2024	Explanation	Actions taken, and actions planned and targets set for the next reference period
Climate and other environment-related indicators
Greenhouse gas emissions	1. GHG emissions	Scope 1 GHG emissions	388,575.31	367,714.67	91.54%	Coverage for the GHG emissions has improved year on year. Several factors contributed to changes in greenhouse gas emissions during the reference period. An increase in Davy’s assets under management has led to higher reported GHG emissions under PAI 1. The most significant rise in total GHG emissions came from Scope 3, which involves estimating emissions across companies’ value chains. In addition changes in asset allocation could impact these metrics. The increase in Scope 1 and Scope 3 is driven by our Advisory book, which also saw an increase in Scope 2 emissions. Emissions across Scopes 1 to 3 inclusive fell across our Discretionary book by c.12%. Our Responsible investing (RI) solution has demonstrated a lower impact on these PAIs compared to our non-RI solutions, primarily because it utilizes third-party funds with stronger sustainability criteria.	At Davy, our responsible policy aligns with our approach to investment research and portfolio construction. The policy covers the investments that are recommended by Davy Private Clients’ investment team. It details the processes and approach that the investment team undertake in consideration of ESG factors which include but is not limited to active ownership, and governance of responsible investment. In addition to Davy firmwide commitments to a more sustainable and equal society, our focus on responsible investment is influenced by being a signatory to the United Nations supported Principles for Responsible Investment (The PRI) and as a regulated financial market participant within the EU (European Union). In 2024, Davy began its formal engagement policy with external investment managers and also started to participate in collaborative engagements. Engagement is an important part of our responsible investment process. As most of our client assets are held via 3rd party funds, in many instances, Davy does not have the ability to engage directly with the companies. Our dialogue with these investment managers on important matters such as climate change and human rights helps ensure Davy meets its obligations of advocating for change. Examples of our collaborative engagement efforts are- • In 2024, we endorsed Advance-a human rights and social issues initiative led by the UN-supported Principles for Responsible Investment. • As a signatory to the UN Global Compact, Davy is already aligned with these values. While we don’t engage directly with companies in this initiative, we use it to guide our conversations with external investment managers making sure human rights are being taken seriously across our portfolios. • Davy also participated in signing a global investor letter ahead of COP29, calling on world governments to take urgent action on the climate crisis. Davy joined over 650 financial institutions representing more than $33 trillion in assets. In particular our RI solution demonstrates a lower impact on PAIs 1-4 compared to our non-RI solutions, primarily because it utilizes third-party funds with stronger sustainability criteria. Davy’s research process for third party RI managers (equity, fixed income and alternatives funds) within its discretionary assets emphasise integration and engagement. We utilise third party funds which display strong sustainability criteria and integrate sustainability within their investment strategy. Davy continues to monitor the evolution of PAI metric data, its vailability, and its quality with a view to developing Davy’s Sustainability Strategy. Guidance on target setting and planned actions in relation to individual PAI metrics will be provided by the Davy Sustainability Executive Committee, the Davy Investment Governance Committee and the Davy Investment Team.
Greenhouse gas emissions	1. GHG emissions	Scope 2 GHG emissions	61,962.86	65,141.35	91.54%	See above	See above
Greenhouse gas emissions	1. GHG emissions	Scope 3 GHG emissions	2,816,275.21	2,422,086.66	91.52%	See above	See above
Greenhouse gas emissions	1. GHG emissions	Total GHG emissions	3,234,278.13	2,908,145.86	91.51%	See above	See above
Greenhouse gas emissions	2. Carbon footprint	Carbon footprint	355.57	406.46	91.51%	Coverage has improved for carbon footprint metric year on year. The Carbon Footprint as measured by the total annual Scope 1, Scope 2, and estimated Scope 3 GHG emissions associated with 1 million EUR invested in the portfolio have fallen across the Advisory and Discretionary books. The increased level of coverage and changes in assets under management & asset allocation have contributed to the decrease in this metric.	See above
Greenhouse gas emissions	3. GHG intensity of investee companies	GHG intensity of investee companies	767.38	755.38	93.42%	Coverage for GHG intensity of investee companies metric has improved year on year. The overall increase in GHG Intenisty has been driven in the main by the increase associated with our Advisory book, c.+2.8%. The GHG Intensity associated with our Discretionary book has fallen significantly, c.-4.5% The increased level of coverage and changes in assets under management & asset allocation have contributed to the increase in this metric.	See above
Greenhouse gas emissions	4. Exposure to companies active in the fossil fuel sector	Share of investments in companies active in the fossil fuel sector	6.11%	6.77%	93.46%	Coverage for exposure to companies active in fossil fuel sector remains broadly similar to previous years. Changes in asset under managements & asset allocation have contributed to the overall decrease in this share of investments active in fossil fuel sector. This exposure has decreased across both our Advisory, c.-11.5% and Discretionary books, c.-6.5%.	See above
Greenhouse gas emissions	5. Share of non-renewable energy consumption and production	Share of non-renewable energy consumption and non-renewable energy production of investee companies from non-renewable energy sources compared to renewable energy sources, expressed as a percentage of total energy sources	58.50%	64.73%	71.37%	Coverage for share of nonrenewable energy consumption and production metric has improved year on year. The increased level of coverage and changes in assets under management & asset allocation have contributed to the overall decrease in this metric. We have experienced an improvement across both our Advisory and Discretionary books	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	"NACE Code A (Agriculture, Forestry and Fishing)"	0.54	0.55	81.59%	Coverage for Energy Consumption intensity per high impact climate sector has decreased year on year. The indicators related to NACE Code A (Agriculture, Forestry and Fishing), NACE Code B (Mining and Quarrying), NACE Code D (Electricity, Gas, Steam and Air Conditioning Supply), NACE Code F (Construction), NACE Code H (Transportation and Storage) and NACE Code L (Real Estate Activities) have improved year on year. Whilst the indicators related NACE Code C (Manufacturing),NACE Code E (Water Supply; Sewage, Waste Management and Remediation Activities),NACE Code G (Wholesale and Retail Trade; Repair of Motor Vehicles and Motorcycles) have increased year on year. Changes in asset under management and asset allocation have contributed to the changes across these indicators.	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code B (Mining and Quarrying)	1.02	1.13	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code C (Manufacturing)	1.17	0.55	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code D (Electricity, Gas, Steam and Air Conditioning Supply)	3.07	3.18	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code E (Water Supply; Sewerage, Waste Management and Remediation Activities)	1.10	0.76	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code F (Construction)	0.12	0.20	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code G (Wholesale and Retail Trade; Repair of Motor Vehicles and Motorcycles)	0.19	0.09	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code H (Transportation and Storage)	3.40	3.57	81.59%	See above	See above
Greenhouse gas emissions	6. Energy consumption intensity per high impact climate sector	NACE Code L (Real Estate Activities)	0.24	0.42	81.59%	See above	See above
Biodiversity	7. Activities negatively affecting biodiversity-sensitive areas	Share of investments in investee companies with sites/operations located in or near to biodiversity-sensitive areas where activities of those investee companies negatively affect those areas	7.57%	8.41%	93.39%	The “Activities Negatively affecting biodiversity sensitive areas” metric was subject to a methodology change during the 2024 reporting period. Coverage has marginally fallen year on year. This metric has improved, with exposure falling across both the Advisory and Discretionary books.	See above
Water	8. Emissions to water	Tonnes of emissions to water generated by investee companies per million EUR invested, expressed as a weighted average	0.14	0.40	1.40%	Coverage for emission to water remains too low c.1.4%, despite showing improvement year on year, on this metric to properly assess.	See above
Waste	9. Hazardous waste and radioactive waste ratio	Tonnes of hazardous waste and radioactive waste generated by investee companies per million EUR invested, expressed as a weighted average	6.05	3.17	30.76%	Coverage for hazardous waste and radioactive waste radio remains too low, 30.8%, on this metric to properly assess.	See above

Adverse sustainability indicator		Metric	Impact Year 2024	Impact Year 2023	Coverage* Year 2024	Explanation	Actions taken, and actions planned and targets set for the next reference period
Indicators for social and employee, respect for human rights, anti-corruption and anti-bribery matters
Social and employee matters	10. Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises	Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	0.06%	0.10%	93.36%	Coverage remains broadlysimilar to previous years. The exposure to share of investments in investee companies that have been involved in violations of UNGC principles or OECD Guidelines for Multinational Enterprises has decreased significantly across both our Advisory c.-42.8% and Discretionary books, c.-25%. Factors including, changes in asset under management and asset allocation have contributed to the decrease in this metric.	At Davy, our responsible policy aligns with our approach to investment research and portfolio construction. The policy covers the investments that are recommended by Davy Private Clients’ investment team. It details the processes and approach that the investment team undertake in consideration of ESG factors which include but is not limited to active ownership, and governance of responsible investment. In addition to Davy firmwide commitments to a more sustainable and equal society, our focus on responsible investment is influenced by being a signatory to the United Nations supported Principles for Responsible Investment (The PRI) and as a regulated financial market participant within the EU (European Union). In 2024, Davy began its formal engagement policy with external investment managers and also started to participate in collaborative engagements. Engagement is an important part of our responsible investment process. As most of our client assets are held via 3rd party funds, in many instances, Davy does not have the ability to engage directly with the companies. Our dialogue with these investment managers on important matters such as climate change and human rights helps ensure Davy meets its obligations of advocating for change. Examples of our collaborative engagement efforts are- • In 2024, we endorsed Advance-a human rights and social issues initiative led by the UN-supported Principles for Responsible Investment. • As a signatory to the UN Global Compact, Davy is already aligned with these values. While we don’t engage directly with companies in this initiative, we use it to guide our conversations with external investment managers making sure human rights are being taken seriously across our portfolios. • Davy also participated in signing a global investor letter ahead of COP29, calling on world governments to take urgent action on the climate crisis. Davy joined over 650 financial institutions representing more than $33 trillion in assets. In particular our RI solution demonstrates a lower impact on PAIs 1-4 compared to our non-RI solutions, primarily because it utilizes third-party funds with stronger sustainability criteria. Davy’s research process for third party RI managers (equity, fixed income and alternatives funds) within its discretionary assets emphasise integration and engagement. We utilise third party funds which display strong sustainability criteria and integrate sustainability within their investment strategy. Davy continues to monitor the evolution of PAI metric data, its vailability, and its quality with a view to developing Davy’s Sustainability Strategy. Guidance on target setting and planned actions in relation to individual PAI metrics will be provided by the Davy Sustainability Executive Committee, the Davy Investment Governance Committee and the Davy Investment Team.
Social and employee matters	11. Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises	Share of investments in investee companies without policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises or grievance /complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	1.03%	0.67%	93.48%	This metric was subject to a methodology change during the 2024 reporting period. Coverage remains broadly similar to previous years. The exposure to share of investments in investee companies without policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises or grievance /complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises increased overall, driven by increased exposure within the Advisory book. However, exposure decreased across our Discretionary book by c.18.7%. Changes in assets under management & asset allocation have contributed to the increase in this metric.	See above
Social and employee matters	12. Unadjusted gender pay gap	Average unadjusted gender pay gap of investee companies	18.26%	15.34%	34.34%	While the coverage has improved year on year, the current coverage still remains too low for the average unadjusted gender pay gap of investee companies to properly assess (c34.3%).	In 2024, Davy began its formal engagement policy with external investment managers and also started to participate in collaborative engagements. Engagement is an important part of our responsible investment process. As most of our client assets are held via 3rd party funds, in many instances, Davy does not have the ability to engage directly with the companies. Our dialogue with these investment managers on important matters such as climate change and human rights helps ensure Davy meets its obligations of advocating for change. Examples of our collaborative engagement efforts are- • In 2024, we endorsed Advance-a human rights and social issues initiative led by the UN-supported Principles for Responsible Investment. • As signatory to the UN Global Compact, Davy is already aligned with these values. While we don’t engage directly with companies in this initiative, we use it to guide our conversations with external investment managers—making sure human rights are being taken seriously across our portfolios. • Davy also participated in signing a global investor letter ahead of COP29, calling on world governments to take urgent action on the climate crisis. Davy joined over 650 financial institutions representing more than $33 trillion in assets. Davy’s research process for third party RI managers (equity, fixed income and alternatives funds) within its discretionary assets emphasises integration and engagement. We utilise third party funds which display strong sustainability criteria and integrate sustainability within their investment strategy. Davy continues to monitor the evolution of PAI metric data, its availability, and its quality with a view to developing Davy’s Sustainability Strategy. Guidance on target setting and planned actions in relation to individual PAI metrics will be provided by the Davy Sustainability Executive Committee, the Davy Investment Governance Committee and the Davy Investment Team.
Social and employee matters	13. Board gender diversity	Average ratio of female to male board members in investee companies, expressed as a percentage of all board members	37.37%	37.10%	92.32%	The coverage on the average ratio of female to male board members in investee companies, expressed as a percentage of all board members has broadly remained similar year on year. The metric remains broadly static year on year.	See above
Social and employee matters	14. Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons)	Share of investments in investee companies involved in the manufacture or selling of controversial weapons	0.05%	0.08%	93.49%	The coverage for share of investments in investee companies involved in the manufacture or selling of controversial weapons broadly remains similar to previous years. We have experienced an improvement across both our Advisory and Discretionary books. Changes in assets under management & asset allocation have contributed to the decrease in this metric.	See above

Adverse sustainability indicator		Metric	Impact Year 2024	Impact Year 2023	Coverage* Year 2024	Explanation	Actions taken, and actions planned and targets set for the next reference period
Indicators applicable to investments in sovereigns and supranationals
Environmental	15. GHG intensity	GHG intensity of investee countries	190.41	224.32	99.79%	Coverage for the GHG intensity of investee countries (in sovereigns and supranationals) is broadly similar to previous years. We have experienced an improvement across both our advisory & discretionary books. Changes in assets under management & asset allocation have contributed to the decrease in this metric.	In 2024, Davy began its formal engagement policy with external investment managers and also started to participate in collaborative engagements. Engagement is an important part of our responsible investment process. As most of our client assets are held via 3rd party funds, in many instances, Davy does not have the ability to engage directly with the companies. Our dialogue with these investment managers on important matters such as climate change and human rights helps ensure Davy meets its obligations of advocating for change. Examples of our collaborative engagement efforts are- • In 2024, we endorsed Advance-a human rights and social issues initiative led by the UN-supported Principles for Responsible Investment. • As signatory to the UN Global Compact, Davy is already aligned with these values. While we don’t engage directly with companies in this initiative, we use it to guide our conversations with external investment managers—making sure human rights are being taken seriously across our portfolios. • Davy also participated in signing a global investor letter ahead of COP29, calling on world governments to take urgent action on the climate crisis. Davy joined over 650 financial institutions representing more than $33 trillion in assets. Davy’s research process for third party RI managers (equity, fixed income and alternatives funds) within its discretionary assets emphasises integration and engagement. We utilise third party funds which display strong sustainability criteria and integrate sustainability within their investment strategy. Davy continues to monitor the evolution of PAI metric data, its availability, and its quality with a view to developing Davy’s Sustainability Strategy. Guidance on target setting and planned actions in relation to individual PAI metrics will be provided by the Davy Sustainability Executive Committee, the Davy Investment Governance Committee and the Davy Investment Team.
Social	16. Investee countries subject to social violations	Number of investee countries subject to social violations (absolute number and relative number divided by all investee countries), as referred to in international treaties and conventions, United Nations principles and, where applicable, national law	7	6	99.79%	China is a sovereign issuer that currently features on the list of European External Action Service (EEAS) restrictive measures (sanctions) on imports and exports. It represents a significant portion of Global Aggregate fixed income, as a result global fixed income exposures will likely have China exposure. This exposure drives the majority of 8.1% shown in the 2024 indicator. Other country exposures are significantly smaller and are predominantly driven by instruments held in our Advisory book. Changes in assets under management and asset allocation have contributed to the increase in this metric.	See above
Social	16. Investee countries subject to social violations	Number of investee countries subject to social violations (relative number divided by all investee countries), as referred to in international treaties and conventions, United Nations principles and, where applicable, national law	8.09%	6.92%	99.79%	See above	See above

Adverse sustainability indicator		Metric	Impact Year 2024	Impact Year 2023	Coverage* Year 2024	Explanation	Actions taken, and actions planned and targets set for the next reference period
Indicators applicable to investments in real estate assets
Fossil fuels	17. Exposure to fossil fuels through real estate assets	Share of investments in real estate assets involved in the extraction, storage, transport or manufacture of fossil fuels	N/A	N/A	-	Not currently available	See above
Energy efficiency	18. Exposure to energy-inefficient real estate assets	Share of investments in energy-inefficient real estate assets	N/A	-	N/A	Not currently available	See above

*The coverage in year 2024 column in this statement shows the extent of the financial instrument-level data actually used by MSCI in MSCI’s calculation of each PAI metric for 2024

Other indicators for principal adverse impacts on sustainability factors

In addition to the mandatory PAIs, entities must report on 1 additional indicator related to principal adverse impacts on climate or environmental related sustainability factors and 1 additional indicator related to principal adverse impacts on a social, employee, human rights, anti-corruption or anti-bribery sustainability facto

Davy has selected one emissions focused additional climate indicator, Investments in companies without carbon emission reduction initiatives (Table 2, Indicator 4) and one anti-corruption and anti-bribery focused additional indicator, Investments in entities lacking anti-corruption and anti-bribery policies (Table 3, Indicator 15).

Table 2 - Indicators applicable to investments in investee companies

Adverse sustainability impact	Adverse impact on sustainability factors (qualitative or quantitative)	Metric	Impact Year 2024	Impact Year 2023	Coverage* Year 2024	Explanation	Actions taken, and actions planned and targets set for the next reference period
Climate and other environment-related indicators
Emissions	4. Investments in companies without carbon emission reduction initiatives	Share of investments in investee companies without carbon emission reduction initiatives aimed at aligning with the Paris Agreement	40.93%	39.96%	93.90%	Coverage for the share of investments in investee companies without carbon emission reduction initiative aimed at aligning with Paris Agreement broadly remains the same. This metric has shown a slight increase overall which has been driven by our Advisory book, +c.10.1%. Discretionary assets displayed an improvement in this metric, with exposure falling c.-0.9%.	See above

*The 'coverage in year 2024' column in this statement shows the extent of the financial instrument-level data actually used by MSCI in MSCI’s calculation of each PAI metric for 2024.

Table 3 - Indicators for social and employee, respect for human rights, anti-corruption and anti-bribery matters

Adverse sustainability impact	Adverse impact on sustainability factors (qualitative or quantitative)	Metric	Impact Year 2024	Impact Year 2023	Coverage* Year 2024	Explanation	Actions taken, and actions planned and targets set for the next reference period
Indicators applicable to investments in investee companies
Anti-corruption and anti-bribery	15. Lack of anti-corruption and anti-bribery policies	Share of investments in entities without policies on anti-corruption and anti-bribery consistent with the United Nations Convention against Corruption	2.18%	0.87%	93.73%	Coverage has remained broadly similar year on year. The overall increase in exposure to without policies on anticorruption and anti-bribery consistent with the United Nations Convention against Corruption is driven largely by a single fund held across our Advisory book.	See above

*The 'coverage in year 2024' column in this statement shows the extent of the financial instrument-level data actually used by MSCI in MSCI’s calculation of each PAI metric for 2024.

Description of policies to identify and prioritize principal adverse sustainability impacts

The EU defines a Principal Adverse Impact (PAI) as follows: “Negative, material or likely to be material effects on sustainability factors that are caused, compounded by or directly linked to investment decisions and advice performed by the legal entity.”

Principal Adverse Indicators are identified and assessed at an investment solution level by our Portfolio Management Group. The Investment Selection Team perform initial and ongoing due diligence of third-party investment managers and a key part of this process is gaining an understanding of how prospective and existing managers consider Environmental, Social and Governance (ESG) and sustainability factors in their investment process. Portfolio level Principal Adverse Impacts are monitored by our Portfolio Management Group

Davy Private Clients’ methods of identifying adverse impact is based upon a broad set of data taken from multiple providers including MSCI ESG Research, MSCI Index Data, Bloomberg and Style Analytics, in addition to data and reports provided by third party investment managers.

While the available dataset is extensive, it is important to note that ESG and Sustainability data is an evolving area. Data sources will be reviewed on an ongoing basis to ensure the best quality data is integrated into the investment process. Where data is missing or unavailable, Davy Private Clients may make use of assumptions and estimated data. Finally, the launch of the European ESG Template (EET) provides an additional source of adverse impacts data. Davy Private Clients will develop an approach to assessing differences in reported data points from multiple sources as the availability of EET data increases.

The dataset is available to the investment team, allowing for an assessment of the indicators to be applied across Davy Private Clients’ product range, providing a source of additional information when making investment decisions. The PAIs will be considered and assessed in non responsible investment approach products but may not be a deciding factor in investment decision making or in the provision of financial advice.

The prioritisation of Principal Adverse Impacts is currently dictated by the investment product’s objective and ESG priorities, consistent with the SFDR framework.

Engagement policies

Davy Private Clients, as part of its investment manager due diligence process, engages with its third-party investment managers on many issues, including sustainability. As Davy’s investment approach employs a multi-manager approach most of our clients’ holdings are held via funds. We assess the funds and instruments we invest in and work out an engagement plan to interact on key initiatives that are a focus for Davy. In addition to engaging with investment managers; we will engage with industry and policymakers via collaborative engagement to further advocate for responsible investment. In addition, Davy engages directly with companies it invests in on behalf of Discretionary clients, consistent with the requirements of the revised Shareholder Rights Directive (SRD II). Further details can be found in the Shareholder Engagement Policy published on Davy’s website.

References to international standards

J & E Davy conducts its business in a manner compliant with all applicable legislation and endorses and adheres to internationally recognised due diligence and reporting standards such as:

United Nations Principles of Responsible Investing
United Nations Sustainable Development Goals
United Nations Global Compact

Historical comparison

The tables above display the Principal Adverse Impact Indicators from the 2023 reporting period (1st January 2023 to 31st December 2023) and the 2024 reporting period (1st January 2024 to 31st December 2024). Details related to changes in Principal Adverse Impact Indicators from one reporting period to the next have been provided in the explanation columns in the tables above.

Additional Disclosures

Description of AUM Universe

This PAI statement covers Davy Private Clients (Advisory & Discretionary assets), Davy Credit Unions (Advisory & Discretionary assets).

Our data provider has increased its coverage of the Davy AUM universe for the 2024 reporting period.

Assets lacking sufficient sustainability data have been excluded from this statement, examples include Private Equity, Structured Products and Direct Property. Assets falling under Execution Only service are also excluded from this statement as Davy does not exercise any influence over investment decision making.

Statement Methodology and Limitations

J & E Davy Unlimited Company have prepared this statement in conjunction with MSCI ESG Research. MSCI is a provider of ESG data to the financial services industry.

As of June 2023, MSCI’s EU SFDR Dataset covered Mandatory and Additional PAIs for over 12,000 issuers, approximately 53,000 equity and fixed income funds. In addition, 6,000 indices are also covered.

The dataset is designed to help financial market participants consider sustainability as part of their financial decision making and the principal adverse impacts of their investments.

The statement output is subject to MSCI ESG Research calculation and estimation methodologies and limitations of available data.

Davy’s assessment of Principal Adverse Impact Indicator metrics is confined to those metrics with a sufficient level of coverage.