SFDR

Date of publication: 12.12.2025

Sustainability risks

Evolutiq Search Fund Capital Management GmbH (LEI: 391200U4A5PL9HNMPB59, the “evolutiq”) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. Evolutiq considers sustainability risks as part of its due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted through an informal process as appropriate in light of the circumstances of the individual case. The results of such assessment are taken into account when the investment decision is being taken. However, evolutiq remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case evolutiq can also apply measures to reduce or mitigate any sustainability risks. At all times, evolutiq will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

No consideration of adverse impacts of investment decisions on sustainability factors

Given that the SFDR, the EU Taxonomy and the accompanying RTS, which determine the sustainability indicators to be used and provide details on mandatory processes to obtain the respective data at portfolio company level, are relatively new legislative acts, there is very little practical experience or practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by evolutiq. Further, the information that would need to be obtained from portfolio companies in connection with the disclosures required under the SFDR and the accompanying RTS is extensive and there is currently only little practical experience with how the market, in particular co-investors and investees react to and deal with these disclosure obligations and information requirements. Moreover, the burden associated with considering adverse impacts on sustainability factors by using sustainability indicators is disproportionate in light of the limited relevance that such impacts could have in the context of the Fund’s investment strategy: In general, the Fund will only hold minority interests in its portfolio companies which are generally not sufficient to encourage the companies to collect and report the relevant data. It is currently not foreseeable for evolutiq whether the information for the identification and assessment of principal adverse impacts can be obtained regularly and in full from all portfolio companies on a regular basis as required by Art. 4 SFDR.

If and to the extent that the legal uncertainties will be resolved, a practicable market and administrative practice will evolve and data availability can be ensured, evolutiq will re-evaluate considering principal adverse impacts of its investment decisions in Q1 2027. In the meantime, evolutiq remains free in its decision to use part of the sustainable indicators listed in Annex I of the RTS and/or an own set of indicators.

Remuneration disclosure

As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”), evolutiq does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB.