European Sustainable Finance Disclosure Regulation

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

AQVC Management GmbH (“AQVC”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with the Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (the “SFDR”).

Unless information is explicitly provided in relation to a specific fund / fund of funds 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 considers and assesses sustainability risks as part of the due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted using an ESG questionnaire and interviews. The results of such assessment are taken into close consideration when the investment decision is being made and are documented. AQVC remains free in its decision to refrain from investing or to invest despite sustainability risks in which case AQVC can also apply measures to reduce or mitigate any sustainability risks. AQVC will apply 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 concerns, respect for human rights and the fight against corruption and bribery. No sustainability indicators are currently used. The administrative burden associated with considering adverse impacts on sustainability factors (particularly 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 the underlying companies. As a consequence, it cannot be foreseen whether the data capture requirements as specified in the Regulatory Technical Standards (RTS) can be met and at the current point in time AQVC must assume to not be able to fully take into account and monitor the principal adverse impacts (PAIs) of its investment decisions as requested by Article 4. However, AQVC seeks to proactively engage with responsible managers that aim to create value. AQVC will monitor developments with regard to available information and reporting practices to determine when it will be reasonably possible to fully implement the processes required by the Article 4 SFDR in the future.

C. Remuneration Disclosure (Article 5 SFDR)

As a registered alternative investment fund manager under § 44 Abs. 1 in connection with § 2 Abs. 4 KAGB, AQVC does not currently have a remuneration guideline or policy that is consistent with the integration of sustainability risks, except to the extent described below.

Remuneration is generally provided on a fixed basis. However, all team members participate in the carried interest generated by the fund-of-funds, 50% of which is reinvested to strengthen the alignment of interests with AQVC’s limited partners.

D. Miscellaneous

AQVC does not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including funds, or other entities whose business activity includes coal, unconventional oil & gas, nuclear power, arms and weapons, tobacco, alcohol, adult entertainment, gambling (in alignment with the United Nations Global Compact Principles (UNGC) and MSCI ESG Research).

In addition to the recognition and compliance with applicable law, AQVC became a UN PRI signatory in November 2021 and will formally report under the PRI from 2024 onwards. AQVC will also engage with the PRI across different collaboration formats beyond reporting, such as providing ‘best practices’ and case studies.