SFDR Disclosures

The Company is acting as registered alternative investment fund manager under code A00003285 of the Luxembourg Commission de Surveillance du Secteur Financier and as such provide services to alternative investment funds in accordance with article 3 (2) a) of the Luxembourg AIFM Law.

As per Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Company is considered a “financial market participant”.

No consideration of adverse impacts of investment decisions on sustainability factors.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The SFDR lays down harmonised rules for financial market participants on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.

In accordance with these rules, the Fund is required to disclose how sustainability risks are integrated into the investment decision and the results of the assessment of the likely impacts of sustainability risks on the Fund’s returns.

The Fund is considered to fall within the scope of Article 6 of the SFDR. Indeed, it does not promote environmental or social characteristics and does not pursue a specific sustainable investments objective.

Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the Fund may generate.

The AIFM shall continue to review and consider its obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.

The Sub-Fund is committed to active stewardship, including the consideration of ESG issues, and to developing processes to maintain best practices as they evolve across the industry. However, at the present time, the Sub-Fund is considered to fall within the scope of Article 6 of the SFDR as it does not promote environmental or social characteristics and does not pursue a specific sustainable investment objective. Consequently, sustainability risks are not integrated into the investment decisions and are deemed not to be relevant, as (i) as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis is unlikely to have a relevant impact on the potential reduction of sustainability risks that the investment strategy of the Sub-Fund may generate and (ii) the information reported to the Sub-Fund in relation to its portfolio investments does not necessarily enable the Sub-Fund to do so.

The General Partner and the AIFM shall continue to review and consider their obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.

The Fund is considered to fall within the scope of Article 6 fund under SFDR. The Fund does not promote environmental or social characteristics within the meaning of Article 8 SFDR, nor does it have sustainable investment as its objective within the meaning of Article 9 SFDR.
Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the Fund may generate. Given the early-stage and high-growth profile of blockchain and digital asset-related businesses, the AIFM and the Investment Advisor consider that sustainability risks, while assessed, are not likely to be the primary determinant of investment decisions. The AIFM continues to monitor developments in this area.

The General Partner and the AIFM have identified the following ESG events or conditions which, if they occur, could cause an actual or potential material negative impact on the Compartment’s Investments (“Sustainability Risks”):
• Environmental: The Portfolio Companies utilize existing (native) digital infrastructure and have usually still rather small operations.
Accordingly, the Portfolio Companies have no relevant own energy or environmental impact. As the Portfolio Companies of the Compartment operate blockchain-based technologies, they are also beneficiaries of efforts by the blockchains to achieve carbon neutrality.
• Social: Given the relatively small size of Portfolio Companies and the limited resources available to fund and ensure appropriate oversight in certain areas, there are risks from insufficient social protections, including a lack of diversity, potential for discrimination, lack of whistleblower protections, or workplace accident prevention policies for employees, including, access to other basic employee benefits could also be impacted.
• Governance: The lack of consideration by the manager of the Portfolio Companies regarding codes of conduct and anti-corruption safeguards. The Compartment is committed to active stewardship, including the consideration of ESG issues, and to developing processes to maintain best practices as they evolve across the industry. However, at the present time, the Compartment is considered to fall within the scope of Article 6 of the SFDR as it does not promote environmental or social characteristics and does not pursue a specific sustainable investment objective. Consequently, Sustainability Risks are not integrated into the investment decisions and are deemed not to be relevant, as (i) as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis is unlikely to have a relevant impact on the potential reduction of Sustainability Risks that the Investment Strategy of the Compartment may generate and (ii) the information reported to the Compartment in relation to its portfolio Investments does not necessarily enable the Compartment to do so.
The General Partner and the AIFM shall continue to review and consider their obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.
The General Partner and the AIFM do not consider the adverse impacts of investment decisions on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters (“Sustainability Factors”) outside the Sustainability Risks, because the Compartment’s Investments only have a limited impact on the Sustainability Factors due to the small size of their operations and the use of existing (native) digital infrastructure.
The Compartment does not take into account the EU criteria for environmentally sustainable economic activities.