Mandatory disclosures under Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainable-related disclosures in the financial services sector (the “SFDR”) and pertaining to Conny & Co. Advisory S.à r.l., a société à responsabilité limitée governed by the laws of the Grand Duchy of Luxembourg, with registered office at 2, rue Edward Steichen, L-2540 Luxembourg, Grand Duchy of Luxembourg, and registered with the Luxembourg Register of Companies under number B 257771 (“Conny & Co.”):
I. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)
Conny & Co. acknowledges and 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. Conny & Co. remains free in its decision to refrain from investing or to invest despite sustainability risks. At all times, Conny & Co. will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.
The funds managed by Conny & Co. aim to invest mainly in companies within the digital economy sector. Due to the nature of the digital economy sector, there are rarely adverse impacts on sustainability factors. Therefore Conny & Co. does not formally consider adverse impacts of investment decisions on sustainability. However, should there occur adverse impacts during the investment decision-making process, Conny & Co. will evaluate those adverse impacts and in case of a negative outcome will refrain from an investment.
II. Principle adverse sustainability impact statement (Article 4 SFDR)
Given that the SFDR and the accompanying Regulatory Technical Standards (“RTS“) are new legislative acts, there is very little or no practical experience or practice with regard to applying their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by Conny & Co.. Following, it must be assumed that Conny & Co. do not yet take into account any principle adverse impact of investment decisions on sustainability factors as specified in the SFDR. If and to the extent that these uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, and that the portfolio companies provide sufficient information, Conny & Co. will reevaluate following them in due course.
III. Sustainability-related disclosures (Article 9 SFDR)
The funds managed by Conny & Co. also invest into sustainable securities but have no sustainable investment objective within the meaning of Art. 9 SFDR.
The funds managed by Conny & Co. regularly screen sustainable investments and conduct investments in companies that either actively promote environmental and/ or social characteristics or adhere to such guidelines, however, these funds do not invest a fixed percentage of their capital commitments into such companies and do not have sustainable investments within the meaning of Art. 9 SFDR as an objective.