Information according to EU Disclosure Regulation

Sustainable Finance Disclosure Regulation in the financial services sector pursuant to Regulation (EU) 2019/2088.

COI Partners Deutschland GmbH (“COI Partners Deutschland”) is a capital management company within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”). It publishes the following information on its website in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosure requirements in the financial services sector (the “EU Disclosure Regulation”).

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

Strategy for dealing with sustainability risks

COI Partners Germany does not currently include any sustainability risks within the meaning of the EU Disclosure Regulation in its investment decision-making processes.

The EU Disclosure Regulation defines a “sustainability risk” as 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. The EU Disclosure Regulation and the associated future legal acts will provide for a catalogue of criteria, the applicability and meaningful feasibility of which to COI Partners Germany cannot currently be assessed.

Consider adverse impacts of investment decisions on sustainability factors

“Sustainability factors” under the EU Disclosure Regulation are environmental, social and labour concerns, respect for human rights and the fight against corruption and bribery.

The EU Disclosure Regulation and the associated future legal acts will provide for a catalogue of criteria , the applicability and meaningful feasibility of which to COI Partners Germany cannot currently be assessed.

Accordingly, COI Partners Germany does not currently take into account the most important adverse effects of investment decisions on sustainability factors.

COI Partners Germany has defined its own processes and parameters for the selection of portfolio companies, such as a valid business model, ownership structure, management qualifications, etc. COI Partners Germany currently does not consider the most important adverse effects of investment decisions on sustainability factors.

COI Partners Germany does not currently plan to change this.