Sustainable Finance Disclosure Regulation Statement


Sustainability-related disclosures pursuant to REGULATION (EU) 2019/2088 OF THE EUROPEAN PALIAMENT AND OF THE COUNCIL of 27 November on sustainability-related disclosures in the financial sector (the “SFDR“)

As of 1st October 2023

I. Sustainability Risks

Round2 Capital GmbH (the “Fund Manager“) 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. The Fund Manager considers sustainability risks as part of the due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted using a questionnaire. The results of such assessment are taken into account when the investment decision is being taken. The Fund Manager remains free in its decision to refrain from investing or to invest despite sustainability risks in which case the Fund Manager can also apply measures to reduce or mitigate any sustainability risks. The Fund Manager will apply the principle of proportionality in dealing with sustainability risks taking due account of the strategic relevance of an investment as well as its transactional context.

II. No consideration of sustainability adverse impacts

The Fund Manager does not consider adverse impacts of its investment decisions on sustainability factors and, hence, does not use the sustainability indicators listed in Annex I of the Regulatory Technical Standards (Delegated Regulation (EU) 2022/1288, “RTS“) to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. Given that the SFDR, the Regulation (EU) 2020/852 (“Taxonomy“) and the accompanying RTS are relatively new legislative acts, there is very little or no practical experience or practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by the Fund Manager. Furthermore, the administrative burden associated with considering adverse impacts on sustainability factors for the Fund Manager and the portfolio companies (particularly if sustainability indicators are used) is disproportionate in light of the limited relevance that such impacts could have in the context of the Fund Manager’s investment strategy: The Fund Manager pursues a revenue based strategy and usually does not hold interests in its portfolio companies. Therefore, the Fund Manager is not in a position to positively assume it will be able to obtain sufficient information from portfolio companies to satisfy the disclosure obligations of Art. 4 SFDR. If and to the extent that the legal uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, the Fund Manager will re-evaluate considering principal adverse impacts of its investment decisions in due course.

III. Remuneration disclosure

As a registered alternative investment fund manager within the meaning of section 1 para (5) of the Austrian Alternative Investment Fund Manager Act (Alternative Investmentfonds Manager-Gesetz, “AIFMG”) and a manager of a qualifying venture capital fund as defined in Art. 3 (b) of Regulation (EU) No. 345/2013 (“EuVECA-Regulation”), the Fund Manager does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the AIFMG or the EuVECA Regulation. Sustainability risks are not considered with respect to the determination of the remuneration.

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