Sustainability

For better readability and to avoid repetition, the term “Circle Eleven” is used uniformly in this document to refer to Circle Eleven GmbH and Circle Eleven Invest GmbH. All statements relate equally to both companies unless explicitly stated otherwise.

Mandatory information pursuant to the Regulation of the European Parliament and of the Council on sustainability‐related disclosures in the financial services sector (EU) 2019/2088 (“Disclosure Regulation”):

I. Strategies for dealing with sustainability risks in investment decision-making processes (Article 3 of the Disclosure Regulation)
A “sustainability risk” is an environmental, social, or governance event or condition, the occurrence of which could have an actual or potential material negative impact on the value of an investment (Art. 2 No. 22 of the Disclosure Regulation). Sustainability risks do not constitute a separate category of risk; rather, they affect all known risk categories, such as market, liquidity, credit, or operational risks. They may amplify these risks and thus significantly contribute to the overall risk profile of a managed AIF. The adequate consideration of sustainability risks is part of the risk management system of Circle Eleven Invest GmbH. Explicit sustainability risks are not a separate component of Circle Eleven’s investment decision-making processes. This is because, for the special AIFs managed by Circle Eleven, any potential sustainability risks cannot be determined with sufficient accuracy in advance due to the generally existing blind-pool strategy of the respective target funds and their still very differently developed strategies for dealing with ESG aspects.

II. Mandatory information on the consideration of adverse sustainability impacts at the level of Circle Eleven (Article 4 of the Disclosure Regulation)
Currently, Circle Eleven does not consider any potential adverse impacts of investment decisions on sustainability factors. The information required for this—relating to environmental, social, and governance aspects—is not yet sufficiently available in the market in which Circle Eleven Invest GmbH makes investments, either in scope or in the quality needed. Circle Eleven will monitor developments regarding the availability of such information and will assess whether it will be reasonably possible in the future to disclose the information required by Art. 4 of the Disclosure Regulation (including future RTS).

III. Mandatory information on the remuneration policy in relation to the consideration of sustainability risks (Article 5 of the Disclosure Regulation)
In accordance with Article 5 of the Disclosure Regulation, Circle Eleven states the extent to which the remuneration policy is consistent with the integration of sustainability risks. The handling or reduction of sustainability risks is not specifically considered in the remuneration system. An indirect influence on remuneration policy and practice—e.g., as part of the general risk strategy or within the framework of individual target agreements—cannot be ruled out.