Sustainability related disclosures

ACP Healthtech Management GmbH (“ACP Healthtech”), LEI: […], is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information 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 (“SFDR”).

Art. 3 SFDR –Sustainability risk policies statement

ACP Healthtech addresses sustainability risks in its investment decision-making process insofar as relevant. “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. During the due diligence on potential investments, ACP Healthtech conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, ACP Healthtech decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. ACP Healthtech regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.

Art. 4 SFDR – No consideration of principal adverse impacts

ACP Healthtech does not consider principal adverse impacts of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters. ACP Healthtech does not use sustainability indicators. The standardized catalog of Key Performance Indicators (KPIs) provided by Annex I of the regulatory technical standards (RTS) issued under the Sustainable Finance Disclosure Regulation (SFDR) is not tailored to the specific needs of the. ACP Healthtech early-stage investment strategy.

In many instances, data will be insufficient for analyzing PAI, and on occasions where data is obtainable, it tends to offer little in terms of comparability and fails to provide additional insights for ACP Healthtech Therefore collecting data on PAI will not only increase the administrative burden and costs but also fail to provide a new perspective for ACP Healthtech.

ACP Healthtech is open to considering PAI in the future if it becomes evident that doing so would significantly enhance the ability of ACP Healthtech to identify and mitigate possible adverse impacts of the investments while maintaining operational efficiency and cost-effectiveness.

Art. 5 – Remuneration Disclosure

As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) ACP Healthtech does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.