Environmental, Social, Governance (ESG) Information



Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):


I. Transparency of sustainability risk policies – Article 3 SFDR

Senovo Capital Management GmbH follows ESG Guidelines (e.g. negative screening), which are integrated along the investment processes.


II. Transparency of adverse sustainability impacts at entity level – Article 4 SFDR

Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principal adverse impacts of investment decisions on sustainability factors as defined in the SFDR. For this purpose, financial market participants such as Senovo Capital Management GmbH must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, Senovo Capital Management GmbH does not take into account any principal adverse impact of investment decisions on sustainability factors, as it believes that the information provided to it by (potential) portfolio companies in relation to the investments is not sufficient to allow it to do so. However, Senovo Capital Management GmbH will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).


III. Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks – Article 5 SFDR

As a registered AIFM within the meaning of section 2(4) of the German Capital Investment Code (Kapitalanlagegesetzbuch), Senovo Capital Management GmbH does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. The integration of sustainability risks is not considered with respect to the determination of the remuneration.


IV. Sustainability-related product disclosure – Article 10 SFDR

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