STATEMENT REGARDING THE MAIN ADVERSE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABLE DEVELOPMENT FACTORS

Below are the details provided by Evig Alfa sp. z o.o., located in Poznan at 35/214 Ziebicka Street, 60-164 Poznan, registered in the National Court Register kept by the District Court Poznan – Nowe Miasto i Wilda in Poznan, VIII Economic Department of the National Court Register under the KRS number: 0000618534, NIP: 7831741932, REGON: 364463152, with a share capital of PLN 5,000 (“Company” or “ASI Manager”), in accordance with the requirements specified in the Regulation of the European Parliament and of the Council (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector.

PRELIMINARY ISSUES

This information has been approved by the Company’s Management Board in accordance with the following legal acts:

• Act of 27 May 2004 on investment funds and alternative investment fund managers (Journal of Laws of 2023, item 681, “Investment Funds Act”);
• Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on alternative investment fund managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010 (“AIFM Directive”);
• Commission Delegated Regulation (EU) No 231/2013 of 19 December 2012 supplementing Directive 2011/61/EU with regard to exemptions, general operating conditions, depositaries, leverage, transparency, and supervision (“AIFMR”);
• Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR Regulation”);
• Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regulatory technical standards specifying the details of the “do no significant harm” principle, specifying the content, methods, and presentation of information on sustainability indicators and adverse impacts on sustainability, and specifying the content and presentation of information on the promotion of environmental or social aspects and sustainable investment objectives in documents made available before the conclusion of an agreement, on websites, and in periodic reports (OJ EU L 196, 2022, p. 1, as amended, “RTS Regulation”);
• Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investments, amending Regulation (EU) 2019/2088 (OJ EU L 198, 2020, p. 13, as amended, “Taxonomy”);
• Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing technical criteria for qualification to determine the conditions under which an economic activity qualifies as making a significant contribution to climate change mitigation or adaptation to climate change and establishing whether that economic activity does not cause significant harm to any of the other environmental objectives (OJ EU L 442, 2021, p. 1, as amended, “Climate Regulation”).

The SFDR Regulation establishes harmonized provisions for financial market participants and financial advisers regarding transparency in relation to the incorporation of sustainability risks into their activities and the consideration of adverse impacts on sustainability in their activities, as well as the provision of information on the sustainability of financial products by them.

The above information primarily concerns:

(a) transparency regarding the strategy for incorporating sustainability risks into the investment decision-making process;

(b) consideration of the main adverse impacts of investment decisions on sustainability factors;

(c) determining how consistency is ensured within the financial market participant’s adopted policies;

(d) compensation policies related to the incorporation of sustainability risks into activities.

The SFDR provisions and accompanying acts impose obligations on alternative investment fund managers to provide information to market participants regarding the financial products offered and to facilitate the understanding of actions taken regarding sustainable development. These obligations are fulfilled by ASI Managers through disclosures, including on their website, to ensure an adequate level of awareness.

ARTICLE 2 OF THE SFDR REGULATION

Under the SFDR Regulation, ASI Managers are qualified as financial market participants, and the alternative investment funds they manage are considered financial products.

INFORMATION ABOUT STRATEGIES FOR INCORPORATING SUSTAINABILITY RISKS INTO INVESTMENT DECISION-MAKING PROCESSES

The SFDR Regulation in Article 3(1) establishes a requirement for financial market participants to publish information on their website regarding their strategy for incorporating sustainability risks into the investment decision-making process. According to the definition in Article 2(22) of the SFDR Regulation, sustainability risk means environmental, social, and governance (ESG) factors that, if realized, could have a material adverse impact on the value of investments.

Specifically, factors influencing the level of risk include: (i) an environmental focus on energy production, (ii) responsible use of water resources (both marine and inland), (iii) climate change due to global warming, (iv) respect for human rights, (v) adherence to universally recognized labor standards (including child labor, forced labor, and non-discrimination), (vi) protection of workers’ rights, (vii) support for anti-corruption efforts, (viii) sustainable and responsible social and territorial development. The primary goal of ASI Manager’s activities is to consider the interests of ASI participants and its clients.

ASI Manager has not yet adopted a strategy for incorporating sustainability risks into the investment decision-making process because it does not anticipate such risks in the investment process. This is primarily due to the profile and nature of the entities subject to the investments made.

Furthermore, ASI Manager states that the Company’s activities do not involve emissions to the atmosphere, wastewater discharge, or the production of harmful substances, so the potential impact of the Company’s activities on environmental issues, including climate change, is marginal. The Company places importance on waste minimization, proper sorting, and optimizing the use of electricity and water.

Taking these factors into consideration, and in particular the scale and nature of its activities, the Company has not developed a strategy that incorporates ESG regulations.

MAIN ADVERSE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABLE DEVELOPMENT

When making investment decisions, adverse impacts on sustainability factors are not taken into account.

As regulations on the disclosure of sustainability-related information and the development of market standards for incorporating sustainability risk evolve, the internal process within the Company related to managing sustainability risk may change to align with current market standards.

In the event of a change in the nature and investment profile of the Company’s activities, ASI Manager will consider taking into account the adverse impacts of investment decisions on sustainability factors in the future.

TRANSPARENCY OF COMPENSATION POLICY IN RELATION TO THE INCORPORATION OF SUSTAINABILITY RISKS INTO ACTIVITIES

ASI Manager is a subject referred to in Article 3(2) of the AIFM Directive and is therefore exempt from the obligation to adopt a compensation policy referred to in Article 13(1) of the AIFM Directive.

Furthermore, under Polish law, in accordance with Article 70zb of the Investment Funds Act, ASI Manager, as an entity engaged in managing an alternative investment fund without the permission of the Supervisory Commission, is not obligated to have a compensation policy as defined in Article 70j of the Investment Funds Act.

At the same time, due to the lack of a strategy for incorporating sustainability risks into the investment decision-making process and the non-consideration of adverse impacts of the investment process on sustainability factors, ASI Manager does not ensure consistency of its compensation policy with the incorporation of sustainability risks into activities within other internal documents of the Company that determine the remuneration levels of individuals responsible for ASI Manager’s activities