Please note this is a convenience translation only and the legally binding document is the German version.

Legal Disclosure

Strategies of the Company for the Integration of Sustainability Risks

(Disclosure pursuant to Article 3 of Regulation (EU) 2019/2088 – “SFDR”)

• We do not promote environmental or social characteristics within the meaning of Article 8 SFDR, nor do we pursue a sustainable investment objective within the meaning of Article 9 SFDR.
• As a company, we aim to contribute to a sustainable and resource-efficient economy, with a particular focus on identifying the risks and impacts of climate change. In addition to pursuing sustainability goals within our own organization, we consider it our responsibility to raise our clients’ awareness of sustainability aspects when structuring business relationships and to point out the potential impact of sustainability risks on investment results.
• Environmental risks, social developments, or weak corporate governance can negatively affect the value of our clients’ investments and assets in several ways. These so-called sustainability risks may directly impact the financial position, performance, and reputation of investments. Since such risks cannot be entirely excluded, we have developed strategies to identify and consider sustainability risks in the financial services we provide.
• To assess sustainability risks, we make use of sustainability ratings and analyses from recognized external providers such as MSCI, S&P Global, Sustainalytics, or Bloomberg. In this way, we seek to identify companies that exhibit increased sustainability risks and take these findings into account in our investment decisions. The specific application depends on the respective client agreements.
• The sustainability data used may be incomplete or based on estimates and therefore may not always fully reflect all sustainability risks.
• Our internal organizational guidelines incorporate the company’s strategies for integrating sustainability risks. Adherence to these guidelines is a factor in evaluating employee performance and thus influences future remuneration development. Accordingly, our remuneration policy is consistent with our strategies for integrating sustainability risks and discourages excessive risk-taking with respect to sustainability factors (Article 5 SFDR).
• All investment decisions and the consideration of sustainability risks are made within the framework of the contractual agreements with our clients (for undertakings for collective investment, in particular the sales prospectus) and other binding legal requirements.

Statement on the Non-Consideration of Adverse Impacts on Sustainability Factors

(Disclosure pursuant to Article 4 of Regulation (EU) 2019/2088 – “SFDR”)

• Investment decisions may have adverse impacts on sustainability factors, such as on environmental matters (e.g. climate, water, biodiversity), social and employee concerns, or the fight against corruption and bribery.
• In accordance with Article 4(1)(b) SFDR, we currently do not consider the principal adverse impacts of investment decisions on sustainability factors.
• This decision is due to the absence of sufficiently standardized and reliable data particularly for small- and mid-cap companies as well as the disproportionate administrative burden that would currently result from such consideration. We will continue to monitor regulatory and data developments and may reassess this decision in the future.
• This approach does not diminish our commitment to contribute to a sustainable and resource-efficient economy and to reduce the risks and impacts of climate change and other environmental or social challenges.

Legal Notice

This statement is made pursuant to Articles 3, 4, and 5 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”).

The information reflects the company’s current approach and may be updated from time to time.

Disclosure pursuant to Section 16 of the Remuneration Ordinance for Institutions

The Company's compensation systems are designed in such a way that, as a matter of principle, false incentives are avoided and no incentives are given to take high risks. Fixed and, where applicable, variable compensation is paid, with the fixed compensation being set in such a way that no economic dependency on the variable compensation components or excessive incentive can arise for the employee. Depending on the financial situation of the Company, the variable compensation may be reduced to zero. In application of the materiality, protection and confidentiality principles of Section 26a (2) of the German Banking Act (KWG), detailed disclosure of the total amount of fixed and variable remuneration and the number of employees receiving variable remuneration is not provided, as this information would allow conclusions to be drawn about the confidential remuneration of individual employees due to the size and structure of the Company. Further required disclosures are published annually in the Federal Gazette.

Statutory Disclosure on the Implementation of the Second Shareholder Rights Directive (ARUG II, zweite Aktionärsrechterichtlinie, Second Shareholder Rights Directive)

Spinoza Capital GmbH falls under the definition of an asset manager within the meaning of § 134a para. 1 no. 2 AktG (Aktiengesetz, Stock Corporation Act) and must therefore describe its participation policy within the meaning of § 134b AktG.

• The company does not exercise any shareholder rights within the meaning of § 134b para. 1 no. 1 AktG that are based on participation in the company. In particular, no rights related to general meetings of public limited companies are exercised. The right to a share in profits within the meaning of §§ 60ff. AktG as well as to subscription rights are exercised or monetized on behalf of the clients.
• The monitoring of important matters of the companies within the meaning of § 134b para. 1 no. 2 AktG is carried out by taking note of the legally required reporting of the companies in financial reports as well as ad hoc announcements.
• There is no exchange of opinions with the corporate bodies and stakeholders of the company within the meaning of § 134b para. 1 no. 3 AktG.
• There is no cooperation with other shareholders within the meaning of § 134b para. 1 no. 4 AktG.
• In the event of conflicts of interest within the meaning of § 134b para. 1 no. 5 AktG, disclosure is made to the parties concerned in accordance with the statutory provisions and further proceedings are clarified with them.
• An annual publication on the implementation of the participation policy within the meaning of § 134b para. 2 AktG is not made because the corresponding rights are not exercised.
• There is no publication of voting behaviour within the meaning of § 134b para. 3 AktG because there is no participation in voting.

Complaints

You can notify us of any complaints by e-mail or by letter using the following contact details:

Spinoza Capital GmbH
Opernturm, 16. Stock
Bockenheimer Landstraße 2-4
D-60306 Frankfurt am Main
info@spinozacapital.com

Please provide us with your name, contact details and a description of your concern. You will immediately receive a confirmation of the receipt of your complaint by letter or e-mail.

We will then endeavor to resolve your concern as quickly as possible in your interest. If this is not possible within two weeks of receipt, you will receive an interim reply from us by letter or e-mail.

Within four weeks of receipt, you will receive a final decision from us by letter or e-mail. If this is not possible, we will inform you of the reasons and our estimate of when the resolution is expected to be completed.

Complaints will be discussed with at least one member of management. If this does not lead to satisfactory results, the Company’s auditor for the current fiscal year can be called in as an arbitrator upon request. Any costs incurred shall be borne by the Company.

Disclaimer

Liability for contents

The contents of our pages have been created with the utmost care. However, we cannot guarantee the accuracy, completeness and timeliness of the content. As a service provider, we are responsible for our own content on these pages in accordance with § 7 Para. 1 of the German Telemedia Act (TMG). According to §§ 8 to 10 TMG, however, we are not obligated as a service provider to monitor transmitted or stored third-party information or to investigate circumstances that indicate illegal activity. Obligations to remove or block the use of information under the general laws remain unaffected. However, liability in this regard is only possible from the point in time at which a concrete infringement of the law becomes known. If we become aware of any such infringements, we will remove the relevant content immediately.

Liability for links

Our offer contains links to external websites of third parties, on whose contents we have no influence. Therefore, we cannot assume any liability for these external contents. The respective provider or operator of the pages is always responsible for the content of the linked pages. The linked pages were checked for possible legal violations at the time of linking. Illegal contents were not recognizable at the time of linking. However, a permanent control of the contents of the linked pages is not reasonable without concrete evidence of a violation of the law. If we become aware of any infringements, we will remove such links immediately.

Copyright

The contents and works created by the site operators on these pages are subject to German copyright law. Duplication, processing, distribution, or any form of commercialization of such material beyond the scope of the copyright law shall require the prior written consent of its respective author or creator. Downloads and copies of this site are only permitted for private, non-commercial use. Insofar as the content on this site was not created by the operator, the copyrights of third parties are respected. In particular, third-party content is identified as such. Should you nevertheless become aware of a copyright infringement, please inform us accordingly. If we become aware of any infringements, we will remove such content immediately.