Sustainable Finance Disclosure Regulation

Sustainable Finance Disclosure Regulation

Moonfare GmbH (“Moonfare”) acts as investment advisor to alternative investment fund managers providing services to alternative investment funds, pooling the commitments of investors on Moonfare’s platform with a view to invest in other private equity or venture capital funds. Unless information is explicitly provided in relation to a specific fund advised by Moonfare the following statements refer to the management and investment decision-making processes of Moonfare in general.

Disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):

Policies on the integration of sustainability risk in investment decision-making processes

Moonfare reviews and evaluates sustainability risks as part of the investment advice 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 advised investment. Prior to any investment advice, Moonfare conducts due diligence. Part of this due diligence includes checking whether sustainability risks are present. If and to the extent such risks are identified and a likelihood exists that these risks might affect the returns of a fund, these risks are taken into account for the investment advice. There is no dedicated policy in place at Moonfare with regards to environmental, social, and corporate governance and Moonfare is free to advise in favour of or against an investment in relation to which certain sustainability risks have been identified.

No consideration of sustainability adverse impacts

For the avoidance of doubt, Moonfare does not consider principal adverse impacts on sustainability factors when preparing and relaying its investment advice. Moonfare provides investment advice to either Pancura, a fully authorized AIFM, and Moonfare I S.à r.l. , a sub-threshold AIFM, with respect to portfolio funds which are blind-pooled private equity or venture capital funds. As blind-pooled funds, the portfolio funds usually have not conducted any investments, yet, when Moonfare relays its investment advice. Furthermore, even if there was under exceptional circumstances a case in which a portfolio fund has already carried out an investment at that point in time, Moonfare would have no access to such portfolio company due to its role as investment advisor. Consequently, Moonfare does not rank and select portfolio funds based on indicators provided in table 1 of Annex I RTS.