Classification of the AIF
The AIF constitutes a financial product within the meaning of Article 2(12) of the SFDR (Sustainable Finance Disclosure Regulation). The AIF neither promotes environmental or social characteristics within the meaning of Article 8 SFDR nor pursues a sustainable investment objective within the meaning of Article 9 SFDR. Accordingly, the disclosures set out below are provided in accordance with Articles 4, 5, 6 and 7 SFDR and Article 7 of the Taxonomy Regulation.
Consideration of Sustainability Risks (Article 6(1) SFDR)
Sustainability risks within the meaning of Article 2(22) SFDR (i.e. environmental, social or governance events or conditions that could, if they occur, cause an actual or potential material negative impact on the value of an investment) are monitored as part of the AIFM's risk management process to the extent they are identifiable from publicly available sources.
However, due to the AIF's investment strategy, which is exclusively focused on crypto-assets and related derivative instruments, traditional ESG-related sustainability risks are considered to be of limited relevance to the AIF's performance. Furthermore, there are currently no established methodologies or reliable data sources for the systematic assessment of sustainability risks in relation to crypto-assets. The AIFM therefore concludes that sustainability risks are not materially relevant to the returns of the AIF.
It cannot be excluded that the above assessment may differ materially if alternative methodologies are applied. Accordingly, this assessment does not constitute a representation or guarantee that sustainability risks will in fact affect the AIF in the manner described above. The AIFM will review and, where appropriate, revise its assessment as robust methodologies, reliable data sources, and established market and regulatory practices for the crypto-asset asset class become available.
Remuneration Policy (Article 5 SFDR)
The AIFM's remuneration policy does not include incentives that would be inconsistent with the integration of sustainability risks or encourage the assumption of increased sustainability risks. Variable remuneration is not linked to factors that would undermine the appropriate consideration of sustainability risks in the investment process.
Principal Adverse Impacts on Sustainability Factors (Article 4(1)(b) and Article 7(2) SFDR)
The AIFM does not consider the principal adverse impacts of investment decisions on sustainability factors, either at the entity level (Article 4(1)(b) SFDR) or in respect of this AIF (Article 7(2) SFDR). This is, among other things, because the data required for such assessments is currently not available with sufficient quality and consistency for the crypto-asset asset class, and because the principal adverse impact (PAI) indicators set out in Annex I to Commission Delegated Regulation (EU) 2022/1288 are primarily designed for corporate investments and sovereign bonds.
Notice pursuant to Article 7 of the Taxonomy Regulation (Regulation (EU) 2020/852)
The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.