SFDR Policy

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"):

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

Grazia Capital Management GmbH 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. Grazia Capital Management GmbH considers sustainability related risks in its investment decision as well as in the management of its investment portfolio. Furthermore, sustainability risks may be considered as part of the due diligence and risk assessment processes in advance of each investment.

II. 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 Grazia Capital Management GmbH must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, Grazia Capital Management GmbH 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. Grazia Capital Management GmbH will monitor developments with regard to available information and consider whether it makes sense for Grazia Capital Management GmbH in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).