SFDR Disclosure

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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“):

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1.  Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)

Currently, sustainability risks are not a separate part of the investment decision-making processes of Elvaston Capital Management GmbH.

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2.  Principle adverse sustainability impact statement at the level of Elvaston Capital Management GmbH (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 as defined in the SFDR. For this purpose, financial market participants such as Elvaston Capital Management GmbH must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS). Elvaston Capital Management GmbH believe that the information provided to them by the portfolio companies in relation to the investments is not yet sufficient (in particular with a view to the comprehensive requirements of the RTS) to allow them to do so. Currently, it must be assumed that Elvaston Capital Management GmbH do not yet take into account any principle adverse impact of investment decisions on sustainability factors in terms of Art. 4 SFDR. However, Elvaston Capital 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).

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3.  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 KAGB, Elvaston Capital Management GmbH do not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. As sustainability risks are not part of the investment decisions of Elvaston Capital Management GmbH, no information can be provided on the compatibility of the remuneration policy with the inclusion of sustainability risks.

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