This information is published in accordance with 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 (the “SFDR” or the “Regulation”).

Integration of Sustainability Risks into Investment Decision-Making Processes

Orion Securities UAB FMI (hereinafter – the “Company”), when providing investment services, takes sustainability risks into account to the extent relevant to the particular service provided, the client’s investment objectives, and the information available regarding financial instruments.

A sustainability risk is understood as an environmental, social or governance (“ESG”) event or condition that, if it occurs, could have an actual or potential material negative impact on the value of an investment.

When providing portfolio management and investment advice services, the Company identifies clients’ sustainability preferences in accordance with applicable legal requirements and takes such preferences into account when assessing the suitability of financial instruments and when making investment decisions on behalf of clients or providing investment recommendations.

In the investment decision-making process, the Company primarily assesses whether investments are consistent with the client’s investment objectives, risk tolerance, financial situation and investment horizon. Where a client has expressed sustainability-related preferences, the Company seeks to offer financial instruments that meet those preferences, to the extent permitted by the availability of products in the market and the information available regarding their sustainability characteristics.

The Company currently does not apply a dedicated ESG rating methodology and does not perform a systematic sustainability impact assessment across all investment decisions.

When assessing sustainability risks, the Company does not currently consider sustainability risk to be a separate determining factor in investment decision-making. Accordingly, the impact of sustainability risks on investment returns is not assessed separately from other investment risks.

Information on the integration of sustainability risks and the likely impacts of sustainability risks on the returns of portfolio management services, as required under Article 6 of the SFDR, is provided to clients in pre-contractual documentation during the portfolio management onboarding and suitability assessment process.

Statement on Principal Adverse Impacts on Sustainability Factors

The Company currently does not consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors within the meaning of the SFDR.

This decision has been made taking into account the nature, scale and complexity of the Company’s activities, the scope of services provided, the availability of relevant data, and the administrative resources required to systematically collect, assess and monitor PAI indicators.

The Company has not implemented processes or systems that would enable the consistent assessment of the impact of all investment decisions against the principal adverse impact indicators set out in the SFDR and related legislation.

Nevertheless, when providing portfolio management and investment advice services, the Company assesses clients’ sustainability preferences and, where relevant, seeks to provide access to financial instruments that meet the client’s sustainability-related objectives and preferences.

The Company periodically reviews its operating model and assesses whether circumstances have changed such that consideration of principal adverse impacts on sustainability factors would become appropriate. This position may be reconsidered in the future in light of changes in regulatory requirements, the scale of operations, or client demand.

Transparency of the Remuneration Policy in Relation to the Integration of Sustainability Risks

The Company has adopted a remuneration policy designed to ensure responsible and effective risk management and to prevent excessive risk-taking.

The Company’s remuneration policy is consistent with the integration of sustainability risks and does not encourage decision-making that could result in excessive risk-taking, including sustainability-related risks.

As the Company does not currently apply a dedicated sustainability risk assessment methodology and does not consider principal adverse impacts of investment decisions on sustainability factors, its remuneration framework does not include specific remuneration components linked to ESG or other sustainability-related indicators.

Employees are assessed based on objective, transparent and non-discriminatory criteria aimed at ensuring the long-term and responsible provision of services to clients.

Additional Information

This webpage contains sustainability-related disclosures at the entity level as required under Articles 3, 4 and 5 of the SFDR.

Where portfolio management or investment advice services are provided, the information required under the SFDR and other applicable legislation regarding the integration of sustainability risks, the likely impact of sustainability risks on investment returns, clients’ sustainability preferences, and the sustainability characteristics of relevant financial instruments is provided through the applicable pre-contractual and contractual documentation.

Last updated: 1 June 2026.