SFDR Disclosures

The Company is acting as registered alternative investment fund manager under code A00003285 of the Luxembourg Commission de Surveillance du Secteur Financier and as such provide services to alternative investment funds in accordance with article 3 (2) a) of the Luxembourg AIFM Law.

As per Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Company is considered a “financial market participant”.

No consideration of adverse impacts of investment decisions on sustainability factors.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The SFDR lays down harmonised rules for financial market participants on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.

In accordance with these rules, the Fund is required to disclose how sustainability risks are integrated into the investment decision and the results of the assessment of the likely impacts of sustainability risks on the Fund’s returns.

The Fund is considered to fall within the scope of Article 6 of the SFDR. Indeed, it does not promote environmental or social characteristics and does not pursue a specific sustainable investments objective.

Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the Fund may generate.

The AIFM shall continue to review and consider its obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.

The Sub-Fund is committed to active stewardship, including the consideration of ESG issues, and to developing processes to maintain best practices as they evolve across the industry. However, at the present time, the Sub-Fund is considered to fall within the scope of Article 6 of the SFDR as it does not promote environmental or social characteristics and does not pursue a specific sustainable investment objective. Consequently, sustainability risks are not integrated into the investment decisions and are deemed not to be relevant, as (i) as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis is unlikely to have a relevant impact on the potential reduction of sustainability risks that the investment strategy of the Sub-Fund may generate and (ii) the information reported to the Sub-Fund in relation to its portfolio investments does not necessarily enable the Sub-Fund to do so.

The General Partner and the AIFM shall continue to review and consider their obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.

The Fund is considered to fall within the scope of Article 6 fund under SFDR. The Fund does not promote environmental or social characteristics within the meaning of Article 8 SFDR, nor does it have sustainable investment as its objective within the meaning of Article 9 SFDR.
Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the Fund may generate. Given the early-stage and high-growth profile of blockchain and digital asset-related businesses, the AIFM and the Investment Advisor consider that sustainability risks, while assessed, are not likely to be the primary determinant of investment decisions. The AIFM continues to monitor developments in this area.

The General Partner and the AIFM have identified the following ESG events or conditions which, if they occur, could cause an actual or potential material negative impact on the Compartment’s Investments (“Sustainability Risks”):
• Environmental: The Portfolio Companies utilize existing (native) digital infrastructure and have usually still rather small operations.
Accordingly, the Portfolio Companies have no relevant own energy or environmental impact. As the Portfolio Companies of the Compartment operate blockchain-based technologies, they are also beneficiaries of efforts by the blockchains to achieve carbon neutrality.
• Social: Given the relatively small size of Portfolio Companies and the limited resources available to fund and ensure appropriate oversight in certain areas, there are risks from insufficient social protections, including a lack of diversity, potential for discrimination, lack of whistleblower protections, or workplace accident prevention policies for employees, including, access to other basic employee benefits could also be impacted.
• Governance: The lack of consideration by the manager of the Portfolio Companies regarding codes of conduct and anti-corruption safeguards. The Compartment is committed to active stewardship, including the consideration of ESG issues, and to developing processes to maintain best practices as they evolve across the industry. However, at the present time, the Compartment is considered to fall within the scope of Article 6 of the SFDR as it does not promote environmental or social characteristics and does not pursue a specific sustainable investment objective. Consequently, Sustainability Risks are not integrated into the investment decisions and are deemed not to be relevant, as (i) as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis is unlikely to have a relevant impact on the potential reduction of Sustainability Risks that the Investment Strategy of the Compartment may generate and (ii) the information reported to the Compartment in relation to its portfolio Investments does not necessarily enable the Compartment to do so.
The General Partner and the AIFM shall continue to review and consider their obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.
The General Partner and the AIFM do not consider the adverse impacts of investment decisions on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters (“Sustainability Factors”) outside the Sustainability Risks, because the Compartment’s Investments only have a limited impact on the Sustainability Factors due to the small size of their operations and the use of existing (native) digital infrastructure.
The Compartment does not take into account the EU criteria for environmentally sustainable economic activities.

Pursuant to EU Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the “SFDR”), the Fund is required to disclose the manner in which Sustainability Risks (as defined in section 18 (Risk Factors) are integrated into the investment decision and the results of the assessment of the likely impacts of Sustainability Risks on the returns of the Fund.
The Fund does not actively promote environmental, social and governance characteristics and does not maximize portfolio alignment with Sustainability Factors, however it remains exposed to Sustainability Risks. Such Sustainability Risks are integrated into the investment decision making and
risk monitoring to the extent that they represent a potential or actual material risks and/or opportunities to maximizing the long-term risk-adjusted returns.
As part of its investment decision-making process, the AIFM takes Sustainability Risks into account, in line with article 6 (1) of the SFDR. The AIFM notably considers Sustainability Risks as part of its due diligence process and evaluates their likely impact on the returns of the Fund on an ongoing basis. In evaluating Sustainability Risks, the AIFM will rely on the ESG Policy, which can be found under Compliance with the before mentioned integration of Sustainability Risks in the investment decision making process by the AIFM is overseen by the risk management function of the AIFM.
The impacts following the occurrence of a Sustainability Risk may be numerous and vary depending on the specific risk, region and asset class. In general, where a sustainability risk occurs in respect of an asset, there will be a negative impact on, or entire loss of, its value.
Such assessment of the likely impact must therefore be conducted at portfolio level, further detail and specific information is given in each relevant Compartment.
In accordance with article 7 of Regulation EU 2020/852 on the establishment of a framework to facilitate sustainable investment, the investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The Sub-Fund is committed to active stewardship, including the consideration of ESG issues, and to developing processes to maintain best practices as they evolve across the industry. However, at the present time, the Sub-Fund is considered to fall within the scope of Article 6 of the SFDR as it does not promote environmental or social characteristics and does not pursue a specific sustainable investment objective. Consequently, sustainability risks are not integrated into the investment decisions and are deemed not to be relevant, as (i) as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis is unlikely to have a relevant impact on the potential reduction of sustainability risks that the investment strategy of the Sub-Fund may generate and (ii) the information reported to the Sub-Fund in relation to its Portfolio Investments does not necessarily enable the Sub-Fund to do so. The General Partner and the AIFM shall continue to review and consider their obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.
The General Partner and the AIFM do not consider the adverse impacts of investment decisions on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters (“Sustainability Factors”) outside the sustainability risks, because the Sub-Fund’s investments only have a limited impact on the Sustainability Factors due to the small size of their operations and the use of existing (native) digital infrastructure. The Sub-Fund does not take into account the EU criteria for environmentally sustainable economic activities.

The Fund does not promote environmental or social characteristics nor has it sustainable investment as its objective. The IFM sets out below the key information required in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR) and the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (EU Taxonomy).
The SFDR defines Sustainability Risk as 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 an Investment.
Neither the AIFM and the IFM nor the Sub-Fund integrate Sustainability Risks as part of its investment decisions. In view of the target strategy of the Sub-Fund, it is not excluded that underlying investment vehicles take into account Sustainability Risks, but this criterion does not form part of the current investment strategy of the Sub-Fund. This results from the original design of the Sub-Fund and its investment strategy, as well as the target investors’ base. Moreover, this is also the result of the peculiar target industry (Crypto-Assets) which is relatively immature in respect of the provision of the necessary data and information enabling to perform objective and comprehensive Sustainability Risk measurements and assessments.
Sustainability Risks can manifest themselves in different ways, including but not limited to the below and it is possible that Sustainability Risks could have a negative impact on the financial profile, profitability or reputation of the Sub-Fund:
• failure to comply with environmental, social or governance standards resulting in reputational damage causing fall in demand for products and services or loss of business opportunities for a company or industry group;
• changes in laws, regulations or industry norms giving rise to possible fines, sanctions or change in consumer behaviour affecting a company or an entire industry’s prospects for growth and development;
• changes in laws or regulations, may generate higher demand for, and thus undue increase in prices of securities of companies perceived as meeting higher ESG standards; or
• changes in laws or regulations may incentivize companies to provide misleading information about their environmental, social or governance standards or activities.
To the extent that a Sustainability Risk occurs or occurs in a manner that is not anticipated by the IFM, there may be a sudden, material negative impact on the Sub-Fund, and hence on the Net Asset Value of the Sub-Fund.
Neither the AIFM and the IFM nor the Fund consider the adverse impacts of investment decisions on Sustainability Factors. This results from the original design of the Fund and its investment strategy, as well as the target investor base. Moreover, this further depends on the lack of clear, reliable and structured data on principal adverse impacts from portfolio companies, potential target investments as well as data providers at this point in time. The combination of the abovementioned factors restricts the ability to consider such factors as part of our investment decision-making process in a comprehensive and coherent manner. However, the Sub-Fund will be monitoring for the time being the key developments in this area and re-assess its approach.
The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The Sub-Fund does not promote environmental or social characteristics nor has it sustainable investment as its objective. The IFM sets out below the key information required in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR) and the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (EU Taxonomy).
The SFDR defines Sustainability Risk as 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 an Investment.
Neither the AIFM and the IFM nor the Sub-Fund integrate Sustainability Risks as part of its investment decisions. In view of the target strategy of the Sub-Fund, it is not excluded that underlying investment vehicles take into account Sustainability Risks, but this criterion does not form part of the current investment strategy of the Sub-Fund. This results from the original design of the Sub-Fund and its investment strategy, as well as the target investors’ base. Moreover, this is also the result of the peculiar target industry (Crypto-Assets) which is relatively immature in respect of the provision of the necessary data and information enabling to perform objective and comprehensive Sustainability Risk measurements and assessments.
Sustainability Risks can manifest themselves in different ways, including but not limited to the below and it is possible that Sustainability Risks could have a negative impact on the financial profile, profitability or reputation of the Sub-Fund:
• failure to comply with environmental, social or governance standards resulting in reputational damage causing fall in demand for products and services or loss of business opportunities for a company or industry group;
• changes in laws, regulations or industry norms giving rise to possible fines, sanctions or change in consumer behaviour affecting a company or an entire industry’s prospects for growth and development;
• changes in laws or regulations, may generate higher demand for, and thus undue increase in prices of securities of companies perceived as meeting higher ESG standards; or
• changes in laws or regulations may incentivize companies to provide misleading information about their environmental, social or governance standards or activities.
To the extent that a Sustainability Risk occurs or occurs in a manner that is not anticipated by the IFM, there may be a sudden, material negative impact on the Sub-Fund, and hence on the Net Asset Value of the Sub-Fund.
Neither the AIFM and the IFM nor the Sub-Fund consider the adverse impacts of investment decisions on Sustainability Factors. This results from the original design of the Fund and its investment strategy, as well as the target investor base. Moreover, this further depends on the lack of clear, reliable and structured data on principal adverse impacts from portfolio companies, potential target investments as well as data providers at this point in time. The combination of the abovementioned factors restricts the ability to consider such factors as part of our investment decision-making process in a comprehensive and coherent manner. However, the Sub-Fund will be monitoring for the time being the key developments in this area and re-assess its approach.
The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.