According to 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, financial market participants and financial advisors are required to disclose information on their website related to their sustainability strategies. These are:

- sustainability risk policies within the investment process (according to Art. 3)

- adverse sustainability impacts at corporate level (Art. 4)

- remuneration policies in relation to the consideration of sustainability risks (Art. 5)


The following paragraphs contain this information for Penguin Capital:

Penguin Capital's understanding of sustainability

Sustainabilityis of high importance to Penguin Capital Management GmbH in its acting as a company. This includes ecological and social aspects as well as governance in its own actions as well as in their partners (Ecological, Social and Governance- ESG).

Penguin Capital currently does not offer any funds with ecological or social aspects (as of Art. 8 SFDR) or target sustainability goals (as of Art. 9 SFDR).

Sustainability risk policies within the investment processes according to Art. 3

The investment process of Penguin Capital includes a thorough due diligence review of each investment opportunity based on several criteria. Some of these criteria reflect sustainability risks, as sustainability risks always include investment risks. Currently, there is no focus on sustainability risks.

Adverse sustainability impacts at entity level according to art. 4

According to art. 4, SFDR, financial market participants and financial advisors shall provide information about whether and how they consider principal adverse sustainability impacts (PAI). This information shall be published on their websites.

This shall be based on Regulatory Technical Standards (RTS) which were first published and became effective in August 2022 and are binding from January1st, 2023.

Currently, Penguin Capital is analyzing the RTS and the related obligations. Penguin Capital Management GmbH will implement these requirements by the time they come into force.

Remuneration policies in relation to the integration of sustainability risks

The remuneration of management and employees of Penguin Capital consists of fixed and variable parts. The variable parts are linked to criteria and targets to be achieved by the company and the respective employees and managers.

The definition of these targets and the relationship between fixed and variable compensation is aimed at a positive long term corporate development which includes aspects of sustainable management principles. Currently there is no direct link to ESG criteria in the remuneration policy.

dated: November 2nd, 2022