Disclosure obligations module under the SFDR

Status: Version 01, November 2024

In accordance with Regulation (EU) 2019/2088 ("SFDR"), capital management companies, among others, are obliged to provide information on certain sustainability issues. This information obligation is met in the following paragraphs.

We include sustainability risks in our investment decisions.

Sustainability risks are defined as 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 risks are part of the general risk types such as market risk, liquidity risk, counterparty risk and operational risk and can influence the materiality of these risks.

The consideration of sustainability risks can have a significant impact on the performance of an investment in the long term. For example, companies in which the fund invests with poor sustainability standards may be more susceptible to event, reputational, regulatory, litigation and technology risks. Such sustainability risks can inter alia have an impact on the operating business, the brand or company value and the continued existence of a target company and thus lead to a negative valuation of an investment made by us, which in turn can have an impact on the return of the fund managed by us.

We incorporate sustainability risks into our investment and portfolio management processes and assess them as follows:

As part of our investment process and risk management, we carry out due diligence on potential target investments prior to each investment decision, which also includes an assessment of sustainability risks. In this context, sustainability risks are identified and assessed in order to minimize their potential impact on investments and the return of the fund we manage.

The results of these assessments are taken into account in our investment decisions and identified sustainability risks are monitored during the investment period of our fund.

Investments may be made for our fund even if we have identified sustainability risks in relation to an asset as part of our due diligence. In such cases, however, we will take measures to mitigate these risks for the investment period.

We do not consider adverse impacts of investment decisions on sustainability factors.

The relevant data required to determine and weight the adverse sustainability impacts is not yet available on the market in sufficient quantity and quality.

The consideration of sustainability risks is not decisive for the evaluation of employees' work performance and has no influence on future salary development. At the same time, no direct incentives are created to take excessive sustainability risks.

Overview of updates:

25.11.2024: First publication