Mandatory disclosures under the Regulation of the European Parliament and of the Council concerning sustainability-related disclosure requirements in the financial services sector (“Disclosure Regulation” / “SFDR”):
I. Strategies for dealing with sustainability risks in investment decision-making processes (Article 3 of the Disclosure Regulation)
At present, sustainability risks are not a separate component of Adina Fund Management GmbH’s investment decisions. As a fund of funds provider, we make our investment decision on the participation in a target fund before this target fund has started its investment activity. It is not known in advance which companies the target fund will invest in (blind pool). Therefore, at the time of our investment decision, we could only assess sustainability risks based on the investment strategy and investment criteria of the target fund managers. The strategies for dealing with sustainability issues (“ESG policies”) of the target fund managers are currently very different and only comparable to a limited extent. Above all, it is fundamentally not possible to derive from this in detail in advance which sustainability risks may subsequently exist in the target fund portfolio.
II. Mandatory Disclosures on the Consideration of Adverse Sustainability Impacts at the Level of Adina Fund Management GmbH (Article 4 of the Disclosure Regulation)
According to Art. 4 of the Disclosure Regulation, financial market participants are obliged to disclose whether they take into account adverse effects of investment decisions on sustainability factors. If they do so, they must provide detailed information in accordance with the specific requirements of Art. 4 of the Disclosure Regulation on concrete sustainability aspects. For the reasons outlined above in relation to Art. 3 of the Disclosure Regulation, we do not currently include adverse impacts of investment decisions on sustainability factors in our investment decision. In particular, we do not have sufficient information in relation to the target funds on their handling of sustainability aspects (“ESG data”) to determine the adverse impact of investment decisions on sustainability factors in accordance with Art. 4 of the Disclosure Regulation. It can therefore currently be assumed that Adina Fund Management GmbH does not yet take into account any adverse effects of investment decisions on sustainability factors within the meaning of Art. 4 of the Disclosure Regulation. We will monitor the extent to which the ESG policies of the target fund managers as well as the ESG data provided by you evolve and examine the extent to which it is reasonably possible in future to disclose the information required by Art. 4 of the Disclosure Regulation (including future detailed requirements for disclosure obligations).
III. Mandatory disclosures on remuneration policy in connection with the consideration of sustainability risks (Article 5 of the Disclosure Regulation)
Pursuant to Art. 5 of the Disclosure Regulation, financial market participants must include information in their remuneration policy on the extent to which it is consistent with the inclusion of sustainability risks. Adina Fund Management GmbH, as a registered capital management company within the meaning of § 2 para. 4 KAGB does 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 Adina Fund Management GmbH, no information can be provided on the compatibility of the remuneration policy with the inclusion of sustainability risks.
