Sustainable Finance Disclosure Regulation (SFDR)

Novum Capital Management GmbH & Co. KG is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information on its website in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the "SFDR").

I. Sustainability risk policies statement

Novum Capital Management GmbH & Co. KG addresses sustainability risks in its investment decision-making process. ‘Sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

In the course of making investment decisions possible sustainability risks are evaluated, assessed and compared with other factors (such as price and expected return of the prospective investment) as part of risk management. Sustainability risks can have a significant impact on all known types of risk and contribute as a factor to the significance of these risk types. The consideration of sustainability risks as part of the investment process is therefore intended to prevent a negative impact on the expected/estimated market price and/or the liquidity of the investment and thus on the return of the respective fund managed by Novum Capital Management GmbH & Co. KG.

These policies are under regular review to ensure that they address new and emerging risks as well as investors’ concerns.

II. Principal adverse sustainability impacts statement

According to the current interpretation of the regulatory requirements, Novum Capital Management GmbH & Co. KG taking into account its size makes use of an election right under Article 4(1) lit. b) SFDR and does not currently take into account principal adverse impacts on sustainability factors in the context of investment decision-making processes. This decision is subject to regular review by management. The non-consideration of the associated PAI concept (PAI = principal adverse impact) as a specific regulatory approach does not contradict the consideration of sustainability risks by Novum Capital Management GmbH & Co. KG.

III. Remuneration policies statement

Novum Capital Management GmbH & Co. KG takes reasonable account of sustainability risks as part of its remuneration policy. The implemented remuneration system does not provide any incentives to take sustainability risks with regard to Novum Capital Management GmbH & Co. KG or the funds it manages. Accordingly, sustainability risks are also taken into account reasonably in the context of employee performance appraisals.