Retirement Scheme Trustees and Administrators
Your guardians of a comfortable retirement
Retirement Scheme Trustees and Administrators
Your guardians of a comfortable retirement
About Bourse Pension Admin
Our Mission
We pride ourselves on our high-quality service and technical skills, while ensuring our staff has the expertise to provide a highly efficient and professional service to our members.
Established in Malta in 2014, we have a long history of providing retirement solutions to international clients.
We broke free from The Bourse Group Guernsey early in 2025 and no longer have any affiliation with them. This frees us to provide even more member focused innovative retirement solutions.
Sustainable Finance Disclosure Regulation (“SDFR”)
Sustainable Finance Disclosure Regulations ("SFDR")
As a ‘financial market participant’ in terms of Regulation (EU) 2019/2088 (also known as the
Sustainable Finance Disclosure Regulation or ‘SFDR’), Bourse Pension Administrators (Malta) Limited as Retirement Scheme Administrator (‘RSA’), trustee of the Bourse Retirement Scheme Malta and the Bourse Malta Overseas Pensions Scheme (the ‘Schemes’) is required to provide disclosures on how it considers sustainability risks and the impact of Environmental, Social and Corporate Governance (“ESG”) factors. Under the SFDR, the RSA is required to state as to whether it considers principal adverse impacts (PAIs) in its pension administration services or otherwise, stating the reasons for not doing so, as applicable.
Definitions
‘Investment Advisor’– The entity appointed by the Member and approved by the RA to provide investment advice to the member in relation to their individual fund held within the scheme and who meets the relevant criteria stipulated in the Malta Pension Rules relevant to the Personal Retirement Schemes;
‘Investment Manager’ – The entity appointed by the member and approved by the RSA of the scheme to carry out services of managing the investments held in the Trust on behalf of the member and who meets the criteria stipulated in the Malta Pension Rules relevant to Personal Retirement Schemes;
‘Member’ – A member in the scheme
‘Pension Rules’ – Pension Rules for Personal Retirement Schemes issued in terms of the Retirement Pensions Act, 2011
‘Sustainability Risks’ - an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment;
‘Sustainability Factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.
Integration of sustainability risk
All the Schemes administered are Member-directed, meaning that investment decisions are discussed and agreed between the Member and the appointed Investment Advisor and/or Investment Manager. All requests are received through an Investment Advisor or Manager, and signed by the Member, or by the Investment Manager on behalf of the Member.
The RSA’s role is to receive and review these instructions to ensure that the investments are suitable for the Member and in line with the investment restrictions detailed in the scheme documents and in line with the Pension Rules. Accordingly, the Company does not assess whether the proposed investments take into consideration sustainability risks or ESG factors.
The RSA also is responsible for approving the Investment Manager and Investment Advisor appointed by the Member. Prior to approving the service providers, the RSA ensures that such providers have the necessary regulatory licensing in hand to service the Members, perform the required due diligence and checks, together with the collection of specific questionnaires for the said service providers. The RSA is not responsible for assessing as to whether the service providers integrate Sustainability Risks and consider PAIs in their processes as part of the said checks. The Members of the schemes are supported to take into account sustainability risks, ESG and PAI of the said service providers prior to appointment. In fact, the sustainability preferences of the Member will be discussed with the appointed and approved Investment Advisor during the mandatory suitability assessment. The RSA reminds the Members of the Scheme that such disclosures from the said service providers are also mandated to be published on their websites as per SFDR requirements.
The RSA can only refuse a direction from the Member only when such instructions are not in line with the investment restrictions of the Scheme or the Pensions Rules. The RSA again supports initiatives taken by the members in the scheme to take ESG and PAI into account into their investment decisions as agreed with the Investment manager and or Advisor.
As a summary, the RSA:
- is not responsible for assessing as to whether the Investment Advisor integrates sustainability risks in the investment advisory services to the Member;
- is not responsible for assessing as to whether the Investment Manager integrates sustainability risks in the investment management process to the Member; and
- notes that while ESG and Sustainability Risks in the investment advisory and management processes maybe integrated by the Investment advisor and/or Manager, the RSA will always ensure that investment decisions will remain consistent with the investment restrictions of the Scheme and Pension rules.
PAIs
The RSA does not consider as to whether the Investment Advisor and Manager appointed by the Member take into consideration PAI in its advisory and management process to the Member. Furthermore, while ESG and sustainability risks in the investment decisions process maybe integrated by the Investment Manager and Advisor, the RSA will always ensure that investment decisions will remain consistent with the investment strategies and restrictions of the Schemes and Pension Rules.
As a trustee of the Schemes, RSA is to review the instructions to ensure the investments are compliant the respective scheme’s Investment Policy and Restrictions. Whilst RSA promotes the awareness of ESG factors, it is not RSA’s remit to reject trades based on whether they are ESG compliant or as to whether PAIs are considered by the Member or service providers to the Member of the Scheme.
Remuneration Policy
The SFDR requires the RSA to disclosure information on how remuneration policies are consistent with the integration of sustainability risks. The RSA has a fixed remuneration strategy unless variation is justified following a performance assessment. In this regard, RSA views its remuneration structure to be consistent with the integration of sustainability risks..