SFDR information in relation to Astorius Consult GmbH

Astorius Consult GmbH is a financial services institution within the meaning of the German Banking Act (Kreditwesengesetz, “KWG”) and, as such, publishes the following information on its website in connection with the consideration of sustainability-related aspects pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector (the “SFDR”).

To the extent that information is not explicitly provided in relation to a specific fund of funds in respect of whose investment activities Astorius Consult GmbH provides advisory services, the following refers to Astorius Consult GmbH’ advisory services in general.

I. Information on the inclusion of sustainability risks in advisory services

Astorius Consult GmbH includes sustainability risks in the provision of its advisory services as follows, whereby a “sustainability risk” is understood to be an event or condition in the environmental, social or corporate governance fields, the occurrence of which could actually or potentially have a material negative impact on the value of the investment.

In order to exclude investments with particularly high sustainability risks, Astorius Consult GmbH will use its best endeavours to recommend investments in a target fund to the funds of funds it advises only if, to the knowledge of Astorius Consult GmbH at the time of making the acquisition recommendation in respect of a share in the relevant target fund (after a diligent best efforts review of the target funds), the target fund does not invest in portfolio companies that engage in certain business practices (e.g. bribery, taxation). bribery, tax evasion, etc.) or are engaged in certain business activities (e.g. drug trafficking, gambling, etc.) that are not in line with the Abacus ESG criteria (List of Excluded Investments).

In addition, a so-called ESG scoring model is used in the pre-selection of potential target funds to be recommended, in which potential target funds are examined to determine whether they meet selected environmental, social and corporate governance criteria of the respective fund of funds advised by Astorius Consult GmbH. Currently, the scoring matrix for the purpose of this review is composed of four main categories (i) “Overall ESG engagement”, (ii) “ESG reporting”, (iii) “ESG implementation and ESG measures” and (iv) “Further information on social aspects”, each of which is fleshed out by several sub-categories with detailed requirements. Astorius Consult GmbH reserves the right to adapt and further improve the scoring matrix on an ongoing basis. The scoring matrix is applied to each potential investment of one of the funds of funds advised by Astorius Consult GmbH with regard to investment activities as part of a risk-oriented materiality analysis.

Whether a potential investment meets the criteria of each sub-category of the scoring matrix is determined with the help of a traffic light labelling, whereby a fulfilment of the requirements from 0% to 50% corresponds to “red”, from 50% to 75% to “yellow” and from 75% to 100% to “green”. The overall degree of fulfilment is determined as the average of the degree of fulfilment of all subcategories in percent. As a rule, Astorius Consult GmbH only intends to recommend investments in target funds that meet the ESG requirements to a degree of at least 50%.

Astorius Consult GmbH’ management regularly reviews these sustainability risk inclusion guidelines to ensure that new risks, as well as investor concerns, are taken into account.

II. Statement on the consideration of material adverse impacts on sustainability factors

Under the current interpretation of the regulatory requirements, Astorius Consult GmbH exercises an option under Article 4(5)(b) SFDR and does not currently consider material adverse impacts on sustainability factors in the context of its advisory activities. The non-consideration of the associated PAI concept (PAI = principal adverse impact) as a concrete regulatory approach does not contradict Astorius Consult GmbH’ commitment to sustainability, in particular the consideration of sustainability risks.

This decision shall be subject to regular review by the Executive Board at least once a year.

III. Information on the remuneration policy

Astorius Consult GmbH appropriately considers sustainability risks as part of its remuneration policy. The implemented remuneration system does not provide incentives to take sustainability risks in relation to Astorius Consult GmbH or funds advised by it. Accordingly, sustainability risks are also taken into account appropriately in the context of employee performance appraisals. Furthermore, aspects relating to sustainability risks are also taken into account within the framework of the risk carrier analysis.

This decision is subject to regular review by the Executive Board at least once a year.

III. Information on the remuneration policy

Astorius Consult GmbH adequately considers sustainability risks as part of its remuneration policy. The implemented remuneration system does not provide incentives to take sustainability risks in relation to Astorius Consult GmbH or funds advised by it. Accordingly, sustainability risks are also taken into account appropriately in the context of employee performance appraisals. Furthermore, aspects relating to sustainability risks are also taken into account within the framework of the risk carrier analysis.

SFDR Information in relation to Astorius Capital GmbH

Astorius Capital GmbH is a capital management company within the meaning of the German Capital Investment Code (Kapitalanlagegesetzbuch, “KAGB”) and, as such, publishes the following information in connection with the consideration of sustainability-related aspects pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosure requirements in the financial services sector (the “SFDR”) on its website.

To the extent that disclosures are not explicitly made in relation to a specific fund managed by Astorius Capital GmbH, the following refers to Astorius Capital GmbH’ management and investment decision-making processes in general.

I. Information on the inclusion of sustainability risks in the investment decision-making processes

Astorius Capital GmbH incorporates sustainability risks into its investment decision-making processes as follows, where a “sustainability risk” means an environmental, social or governance event or condition, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.

In order to exclude investments with particularly high sustainability risks, Astorius Capital GmbH will use its best efforts to acquire interests in a target fund only if, to the knowledge of Astorius Capital GmbH at the time of acquiring the interest in the relevant target fund (after a diligent best efforts review of the target funds), the target fund does not invest in portfolio companies that engage in certain business practices (e.g. bribery, tax evasion, tax fraud). bribery, tax evasion, etc.) or are active in certain business areas (e.g. drug trafficking, gambling, etc.) that are not in line with the Abacus ESG criteria (List of Excluded Investments).

Furthermore, the tasks, responsibilities as well as the time frame for the identification, assessment, management, monitoring and reporting of sustainability risks within the scope of known risk types are clearly defined within the risk management with regard to the funds of funds managed by Astorius Capital GmbH. The methods and procedures established for this purpose are regularly reviewed.

In addition, a so-called ESG scoring model is used in the pre-selection of target funds, in which potential target funds are examined to determine whether they meet selected environmental, social and corporate governance criteria of the respective fund of funds managed by Astorius Capital GmbH. Currently, the scoring matrix for the purpose of this review is composed of four main categories (i) “Overall ESG engagement”, (ii) “ESG reporting”, (iii) “ESG implementation and ESG measures” and (iv) “Further information on social aspects”, each of which is fleshed out by several sub-categories with detailed requirements. Astorius Capital GmbH reserves the right to adapt and further improve the scoring matrix on an ongoing basis. The scoring matrix is applied to each potential investment of one of the funds of funds managed by Astorius Capital GmbH as part of a risk-oriented materiality analysis.

Whether a potential investment meets the criteria of each sub-category of the scoring matrix is determined with the help of a traffic light labelling system, whereby a fulfilment of the requirements from 0% to 50% corresponds to “red”, from 50% to 75% to “yellow” and from 75% to 100% to “green”. The overall compliance level is calculated as the average of the compliance level of all subcategories in percent. As a rule, Astorius Capital GmbH only intends to invest in target funds that meet the ESG requirements to a degree of at least 50%.

Astorius Capital GmbH’ management regularly reviews these sustainability risk inclusion policies to ensure that new risks, as well as investor concerns, are addressed.

II. Statement on the consideration of material adverse impacts on sustainability factors

Under the current interpretation of the regulatory requirements, Astorius Capital GmbH exercises an option under Article 4(1)(b) SFDR and does not currently consider material adverse impacts on sustainability factors in the context of investment decision-making processes. The non-consideration of the associated PAI concept (PAI = principal adverse impact) as a concrete regulatory approach does not contradict Astorius Capital GmbH’ commitment in the area of sustainability, in particular the consideration of sustainability risks.

This decision shall be subject to regular review by the Executive Board at least once a year.

III. Information on the remuneration policy

Astorius Capital GmbH adequately considers sustainability risks within its remuneration policy. The implemented remuneration system does not provide incentives to take sustainability risks in relation to Astorius Capital GmbH or from the funds it manages. Accordingly, sustainability risks are also appropriately taken into account in the context of employee performance appraisals. In addition, aspects relating to sustainability risks are also taken into account within the framework of the risk carrier analysis.

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