Sustainability-related disclosure requirements in the financial services sector pursuant to Regulation (EU) 2019/2088

COI Partners Deutschland GmbH (“COI Partners Deutschland”) is an investment management company as defined by the German Capital Investment Code (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 specific details regarding a particular fund managed by COI Partners Deutschland are explicitly provided, the following statements refer to COI Partners Deutschland’s management and investment decision-making processes in general.

Strategy for Managing Sustainability Risks

COI Partners Germany does not currently incorporate sustainability risks, as defined by the EU Disclosure Regulation, into its investment decision-making processes. The EU Disclosure Regulation defines a “sustainability risk” as an event or condition in the areas of the environment, social, or corporate governance, the occurrence of which could actually or potentially have a material adverse impact on the value of an investment (Art. 2(22) of the EU Disclosure Regulation). COI Partners Germany has determined, as part of an internal assessment, that sustainability risks as defined by the EU Disclosure Regulation are currently not materially relevant to the funds it manages and their investment strategies. COI Partners Deutschland reserves the right to review this assessment on a regular basis and to adjust it in the event of a material change in the factual or legal situation.

Taking into account the adverse effects of investment decisions on sustainability factors

“Sustainability factors” as defined by the EU Disclosure Regulation refer to environmental, social, and labor issues, respect for human rights, and the fight against corruption and bribery (Art. 2(24) of the EU Disclosure Regulation). COI Partners Deutschland currently does not take into account any adverse impacts of investment decisions on sustainability factors within the meaning of Article 4(1)(b) of the EU Disclosure Regulation. When selecting portfolio companies, COI Partners Germany has defined its own processes and parameters, including, for example, the validity of the business model, the ownership structure, and the qualifications of management. COI Partners Germany does not currently plan to change its strategy regarding the consideration of adverse impacts on sustainability factors and will review this assessment on a regular basis.