SUSTAINABILITY IMPACT REQUIREMENTS DISCLOSURE STATEMENT

Acorn Life DAC is a financial market participant which provides Protection, Savings, Pensions and Investment products specifically designed for the Irish market. As a financial market participant Acorn Life DAC is required to make certain disclosures under 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 (SFDR).

THE INTEGRATION OF SUSTAINABILITY RISKS IN ACORN LIFE DAC'S INVESTMENT DECISION - MAKING PROCESS

Acorn Life DAC does not have a policy on the integration of sustainability risks in the investment decision making process. This is because we outsource the fund management of our investment funds.

HSBC Global Asset Management and Mercer Global Investments Europe Limited, to which we outsource the fund management of our investment funds (other than the Deposit Fund), have made disclosures in relation to the SFDR available on their websites.

Acorn Life DAC's financial advisors (including tied-insurance intermediaries) do not currently integrate sustainability risks into their insurance advice as the only insurance products they may offer are those provided by Acorn Life DAC.

NO CONSIDERATION OF ADVERSE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABILITY FACTORS

Given the relative size of our company and the range of investment funds that we currently provide, we do not currently assess the impact of investment decisions on sustainability factors as part of investment due diligence or disclose the outcome of such an assessment to investors.

This position will remain under review. If we decide to extend our investment funds offering to include sustainable investments, we will then consider adverse impacts of investments on sustainability factors as part of our investment due diligence as required under the SFDR.

NO CONSIDERATION OF ADVERSE IMPACTS OF INSURANCE ADVICE ON SUSTAINABILITY FACTORS

Acorn Life DAC's financial advisors (including tied insurance intermediaries) do not consider the impact of investment decisions on sustainability factors in their financial advice as the only products they may offer investors are those provided by Acorn Life DAC.

This position will remain under review. If we decide to extend our investment funds offering to include sustainable investments, our financial advisors may then consider adverse impacts of investment sustainability factors as part of their financial advice.

REMUNERATION POLICIES

Acorn Life DAC’s Remuneration Policy is consistent with the integration of sustainability risks including regular evaluation of whether the remuneration architecture does not encourage any inappropriate risk taking.

Acorn Life DAC's Agency Remuneration Policy (for our tied-insurance intermediaries) is consistent with the integration of sustainability risks including regular evaluation of whether the remuneration architecture does not encourage any inappropriate risk taking.

EU CRITERIA FOR ENVIRONMENTALLY SUSTAINABLE ECONOMIC ACTIVITIES

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

UPDATES TO DISCLOSURES

This disclosure document was updated and amended on June 28, 2023. This update occurred to reflect Acorn Life’s position in relation to the consideration of principle adverse impacts of investment decisions on sustainability factors.