Public statement relating to enforcement action against Sarasin Funds Management (Ireland) Limited

• Date: 30 September 2021

Enforcement Action

Central Bank of Ireland

and

Sarasin Funds Management (Ireland) Limited

Sarasin Funds Management (Ireland) Limited fined €385,000and reprimanded by the

Central Bank of Ireland forbreachesof investment restrictions andinadequatesupervision

of delegates

On 27 September2021, the Central Bank of Ireland (the Central Bank) reprimanded and fined

Sarasin Funds Management (Ireland) Limited (the FirmorSFMIL) €385,000in respect off our

admitted breachesof investment funds regulationswhichoccurred between25 May 2017a nd

2 March 2018(the Relevant Period).

The Central Bank determined the appropriate fine to be €550,000, which was reduced by 30%

to €385,000 in accordance with the settlement discount scheme provided for in the Central

Bank’s Administrative Sanctions Procedure.

The Firm is authorised by the Central Bank as a UCITS fund management companyand is

managed by a board of non-executive directors (the Board).The Firm uses a delegationmodel,

wherebya number of fund management functions aredelegated to external service providers,

subject to ongoing monitoring byspecific directors(the Designated Directors) andthe Board.

Among its delegations, the Firm delegates investment management services to an investment

manager(the Investment Manager) and delegates the depositary function to a depositary(the

Depositary).

TheCentral Bank’sinvestigation commenced following a disclosure inAugust 2017 byth e

Depositary, in accordancewith itsstatutory reportingobligation, about an advertentbreach of