SFDR Disclosures

I. Sustainability Risks (Art. 3 (2) SFDR)

Sustainability Risks

Digital Transformation Capital Partners GmbH (DTC) integrates sustainability risks in its investment advice. 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. In its due diligence process, DTC conducts thorough due diligence work on all investment opportunities. Such due diligence work includes ESG related aspects and assessments to the extent relevant. The results of such due diligence work are taken into account when providing investment advice. At all times, DTC will apply the principle of proportionality taking due account of the relevance of ESG aspects in light of the specific investment opportunities as well as its transactional context.

II. Principal Adverse Impacts (Art. 4 (5) SFDR)

No consideration of sustainability adverse impacts

DTC does not consider adverse impacts of investment decisions on sustainability factors within the meaning of the Sustainable Finance Disclosure Regulation ((EU) 2019/2088, the SFDR). Given that the SFDR and the accompanying Regulatory Technical Standards (the RTS) are new, there is very little or no practical experience or established practice with regard to applying their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the investment advice provided by DTC. As of now, i.e., 10 March 2021, we consider applying the aforementioned disclosure obligations in light of the remaining uncertainties to be too burdensome in relation to the limited relevance we expect adverse impacts to have on the investment decisions resulting from our investment advice. If and to the extent that these uncertainties are resolved and a practicable market and administrative practice will evolve in this regard, we will re-evaluate following them in due course.