Sustainability-related disclosures

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”):

    1. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)

Maxburg Capital Management GmbH (“Maxburg”) is a long-term investor that embraces its responsibility towards investors, portfolio companies and stakeholders in the wider ecosystem in which the firm and its portfolio companies operate. Maxburg manages sustainability risks through a combination of committed participation on the boards of directors of its portfolio companies as well as ongoing monitoring of the progress of each company. Furthermore, sustainability risks will be considered as part of the due diligence and risk assessment processes in advance of each investment.]

    1. Principle adverse sustainability impact statement (Article 4 SFDR)

Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors. For this purpose, financial market participants such as Maxburg must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, Maxburg does not take into account any principle adverse impact of investment decisions on sustainability factors, as it believes that the information provided to it by the portfolio companies in relation to the investments is not sufficient to allow it to do so. Maxburg 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).

    1. 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 KAGB, Maxburg does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. Accordingly, the integration of sustainability risks is not considered with respect to the determination of the remuneration.