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Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):
I. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)
Capnamic Ventures Management GmbH follows a Code of Conduct (which includes ethical guidelines in terms of nature of companies that are eligible for investment) and a Policy for Responsible Investment that are integrated in the investment processes. However, it generally does not strive to promote environmental or social characteristics in its funds or to make sustainable investments.
II. Principle adverse sustainability impact statement (Article 4 SFDR)
Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors. For this purpose, financial market participants such as Capnamic Ventures Management GmbH must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, Capnamic Ventures Management GmbH does not take into account any principle adverse impact of investment decisions on sustainability factors, as it believes that the information provided to it by the portfolio companies in relation to the investments is not sufficient to allow it to do so. Capnamic Ventures Management GmbH will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).
III. Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)
As a registered AIFM within the meaning of section 2(4) of the German Capital Investment Code (Kapitalanlagegesetzbuch), Capnamic Ventures Management GmbH does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. The integration of sustainability risks is not considered with respect to the determination of the remuneration.