Disclosures on addressing sustainability under the EU Disclosure Regulation (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) ("SFDR").
Linus Capital Management GmbH is a capital management company ("LCM") registered with the German Federal Financial Supervisory Authority ("BaFin") under the number 10155515 pursuant to Sections 2 (4) and 44 of the German Investment Code ("KAGB"). The object of LCM is the collective asset management of German closed-ended special AIFs pursuant to Sections 285 et seq. KAGB and all related transactions to the extent of its registration. Among others, LCM manages Linus Debt Invest DACH I GmbH & Co. KG, a special AIF pursuant to section 285 KAGB, as well as several special AIFs for semi-professional, professional and institutional investors (the "Funds").
LCM is a wholly owned subsidiary of Linus Digital Finance AG ("LINUS") and is part of the LINUS Digital Finance Group ("LINUS Group").
I. Information on the inclusion of sustainability risks in the investment process according to Art. 3 para. 1 SFDR
Sustainable and responsible investments are a long-term oriented investment approach, which integrate ESG factors alongside the investment process. The combination of research, fundamental analysis, and engagement with an evaluation of ESG factors to better capture the impact for the environment, long-term returns for investors and the benefit for society facilitates a reliable investment decision-making process.
LCM aims to review and evaluate sustainability risks as part of the investment process with the guidance of a questionnaire based on the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (“Taxonomy”). A "sustainability risk" is an environmental, social or governance event or condition, the occurrence of which could have an actual or potential material adverse effect on the net assets, financial position and results of operations of the relevant investment or LCM but also the LINUS Group as a whole.
Therefore, LCM already partially incorporates procedures as part of the funds' investment process to take relevant sustainability risks into account when making investment decisions. We acknowledge and agree that we shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to entities whose business activity consists of an illegal economic activity (i.e. any production, trade or other activity, which is illegal under the laws or regulations applicable to LINUS or the Funds)
II. Information on the consideration of adverse effects of investment decisions on sustainability factors according to Art. 4 para. 1 a) SFDR
LCM at present does not consider the main adverse impacts of investment decisions on sustainability factors as the relevant data needed to identify and assess the adverse sustainability impacts are not yet available in full and in sufficient quality. This decision is regularly reviewed regarding regulatory requirements and data availability.
III. Consideration of sustainability risks in the remuneration policy pursuant to Art. 5 SFDR
LINUS Group does not currently take sustainability risks into account in its remuneration policy. However, a change in the remuneration policy is planned so that sustainability risks will be adequately taken into account in the future.