Disclosure in accordance with the Disclosure Regulation

No consideration of adverse effects of investment decisions on sustainability factors

(in accordance with the Disclosure Regulation (OffenlegungsVO))

LEI: 529900ZU84PRIG9EUH74

MADAUS Capital Partners GmbH ("Madaus") does not consider Principal Adverse Impacts (PAI) in its investment decisions, see Art. 4 para. 1 b), Art. 6 para. 1 Disclosure Regulation and does not use sustainability indicators. Consequently, Madaus does not classify and select portfolio companies on the basis of the indicators listed in Table 1 of Annex I of Delegated Regulation (EU) 2022/1288.

Sustainability factors include environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery.

As the Regulation on sustainability-related disclosures in the financial services sector (EU 2019/2088) ("OffenlegungsVO") and the accompanying regulatory technical standards ("RTS") are new pieces of legislation, there is very little or no practical experience or practice in relation to the application of their respective provisions. Therefore, significant legal uncertainties would remain when applying these provisions to the strategies pursued by Madaus. In addition, the effort involved in considering adverse impacts on sustainability factors (especially if sustainability indicators are used) is disproportionate given the very limited relevance that such impacts could have in the context of Madaus' investment strategy.

However, Madaus pursues an active risk capital strategy. Therefore, Madaus' investment decisions will have a limited impact on sustainability factors. If and when the legal uncertainties are clarified and a workable market and administrative practice develops in this regard, Madaus will reassess in due course, taking into account the main negative impacts of its investment decisions.

Disclosure of compensation

As a small securities institution pursuant to Art. 12 para. 1 of Regulation (EU) 2019/2033 in conjunction with Section 2 para. § Section 2 (16) and Section 38 (1) WpIG, Madaus does not have a remuneration guideline or policy in accordance with the requirements of Section 46 WpIG and is not required to do so. Sustainability risks are therefore not taken into account when determining the remuneration at Madaus.