Disclosure obligation under Regulation (EU) 2019/2088


Executive Summary
The funds managed by Q21 Capital InvAG mit TGV, including ZeroBeta and PrudentBull, are classified as other financial products according to Article 6 (1) of the SFDR. The funds are managed in accordance with an investment process that incorporates ESG factors but does not promote ESG features and does not have a specific sustainable investment objective.

Disclosure Regulation
Regulation (EU) 2019/2088 („Disclosure Regulation“ or „Sustainable Finance Disclosure Regulation“, abbreviated as „SFDR“) of 27 November 2019, effective from 10 March 2021, requires financial market participants providing portfolio management services, UCITS management companies and alternative investment fund managers to disclose information on strategies for managing sustainability risks and potential or identified adverse sustainability impacts.

This regulation requires financial market participants to explain:

  • how they take sustainability risks into account in their investment decisions
  • on the potential adverse impacts of their products and how they measure them
  • on the characteristics of the financial products they present as sustainable.

Q21 Capital InvAG mit TGV (the „Manager“ is bound by the Disclosure Regulation in its capacity as management company and discloses its handling of sustainability risks for the ZeroBeta and PrudentBull funds (the „Funds“).

Handling of the Funds by the Manager
Consideration of sustainability risks in accordance with Article 3 of Regulation (EU) 2019/2088.
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 Funds‘ investment, cf. Art. 3 SFDR. The Manager considers and assesses sustainability risks as part of their investment decision-making process. Prior to any investment, the Manager shall conduct due diligence. Part of this due diligence includes an assessment of whether sustainability risks are present. The results of such assessments are taken into account in any investment decision, leaving the manager free to decide not to make an investment because of certain sustainability risks or to make it anyway, and always respecting the principle of proportionality in dealing with sustainability risks, taking into account the strategic relevance of an investment as well as its transaction context.

The Manager does not expect any impact of sustainability risks on the return of the Funds. In view of the investment strategy of the Funds, the Manager does not expect sustainability risks to have a negative impact on the return of the Funds within the meaning of Art. 3 SFDR. If relevant, the Manager will make reasonable efforts to adequately assess such risks and their potential impact.

Consideration of adverse effects of investment decisions pursuant to Art. 4 of Regulation (EU) 2019/2088
Sustainability factors are environmental, social and labour concerns, respect for human rights and the fight against corruption and bribery. The Manager does not consider any adverse impact of investment decisions on sustainability factors and no sustainability indicators are currently used. The burden of considering adverse impacts on sustainability factors (particularly when using sustainability indicators) is disproportionate to the very limited significance that such impacts could be given by the Manager in the context of its investment strategy. As the European Disclosure Regulation (EU 2019/2088) and the concretising Regulatory Technical Standards („RTS“) are new, there is little or no experience or practice in dealing with their provisions. Therefore, there is significant legal uncertainty in the application of these rules to the investment strategies pursued by the Funds. If and to the extent that these legal uncertainties are resolved and workable market and administrative practice is established in this regard, the management company will consider taking into account adverse impact of investment decisions on sustainability factors.

Remuneration Disclosure Pursuant to Article 5 of Regulation (EU) 2019/2088.
There are no incentives in the remuneration policy for the Board of Directors and key functions of the ZeroBeta and PrudentBull funds and the executives of Q21 Capital InvAG mit TGV that would support the taking of direct sustainability risks.