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Sustainability-related Disclosures

Mandatory disclosures under Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector ("SFDR")

AQVC Asset Management GmbH ("AQVC") is an alternative investment fund manager registered with the German Federal Financial Supervisory Authority (BaFin) under § 44 Abs. 1 in conjunction with § 2 Abs. 4 of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) (BaFin-ID 10164856). AQVC has its registered office at Akazienallee 20, 16359 Biesenthal, Germany, and is registered with the commercial register of the Amtsgericht Frankfurt (Oder) under HRB 21796 FF. AQVC publishes the following information on the consideration of sustainability-related aspects in accordance with the SFDR.

Unless information is explicitly provided in relation to a specific fund managed by AQVC, the following statements refer to the management and investment decision-making processes of AQVC in general.

A. Sustainability Risks (Article 3 SFDR)

AQVC considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.

AQVC assesses sustainability risks as part of its due diligence process prior to any investment. The results of this assessment are taken into account when the investment decision is made and are documented.

AQVC remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case AQVC may apply measures to reduce or mitigate such risks. AQVC applies the principle of proportionality in dealing with sustainability risks, taking due account of the strategic relevance of an investment as well as its transactional context.

B. Principal Adverse Impacts (Article 4 SFDR)

AQVC does not consider adverse impacts of investment decisions on sustainability factors. Sustainability factors are environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters. No sustainability indicators are currently used.

The administrative burden associated with considering adverse impacts on sustainability factors, in particular the use of sustainability indicators, is disproportionate in light of the very limited influence AQVC has on the reporting arrangements between its investee fund managers and their underlying portfolio companies. As a consequence, it cannot be foreseen whether the data requirements specified in the Regulatory Technical Standards (RTS) can be met, and at the current point in time AQVC must assume that it is not able to fully take into account and monitor the principal adverse impacts (PAIs) of its investment decisions as required by Article 4 SFDR.

AQVC will monitor developments with regard to available information and reporting practices to determine when it will be reasonably possible to implement the processes required by Article 4 SFDR.

C. Remuneration Policy (Article 5 SFDR)

As a registered alternative investment fund manager, AQVC does not currently maintain a remuneration policy that specifically addresses the integration of sustainability risks.

Remuneration consists of a fixed salary. In addition, employees may participate in the carried interest of the funds managed by AQVC, depending on their individual involvement. Remuneration is not linked to the assumption of sustainability risks.

D. Changes to this Statement (Article 12 SFDR)

With effect from 1 September 2026, AQVC Asset Management GmbH has assumed the management of the funds previously managed by AQVC Management GmbH. This statement replaces the statement previously published by AQVC Management GmbH. The following changes have been made:

  • —The disclosures are now made by AQVC Asset Management GmbH as the responsible alternative investment fund manager.
  • —The reference to the signatory status under the UN Principles for Responsible Investment (PRI) has been removed, as AQVC is no longer a signatory.
  • —The description of remuneration has been updated (Section C).
  • —The sector exclusions previously listed under "Miscellaneous" no longer apply and have been removed.

Last updated: 1 September 2026