ESG - Environment, Social & Governance

Sustainability Impacts (Art. 4 SFDR)

As to Art. 4 of the Disclosure Regulation (Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector), Immutable Insight Capital Management GmbH in its capacity as manager of alternative investment funds is obliged to provide information on the consideration of adverse impacts of investment decisions on sustainability factors, i.e. adverse impacts in particular on environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery (so-called "Principal Adverse Impacts").

The consideration of PAI is largely dependent on the availability of relevant information in the market. It is possible that necessary data is not available to a sufficient extent and in the required quality for all assets in which Immutable Insight Capital Management GmbH invests in the course of its activities. The measuring and reporting of adverse effects of investment decisions on sustainability factors also require the implementation of a corresponding internal process in accordance with the legal requirements. As relevant legislative procedures have not yet been completed at the current time, there are still numerous unresolved questions with regard to the concrete requirements for the measuring and reporting of PAI. Therefore, at present, Immutable Insight Capital Management GmbH does not yet consider the most important adverse impacts of investment decisions on sustainability factors at company level and will first await further legal developments. Insofar, respective processes will only be implemented at a later date.

Sustainability Risks Related to Compensation Policy (Art. 5 SFDR)

The remuneration policy of Immutable Insight Capital Management GmbH adheres to the consideration of environmental, social and corporate governance sustainability risks, as Immutable Insight Capital Management GmbH pursues strategies for acting sustainably in the aforementioned areas at company and product level, each of which covering a broad spectrum. Immutable Insight Capital Management GmbH invests primarily in digital assets such as coins and tokens embedded in blockchain technology. Despite discussions about its environmental friendliness, this blockchain technology already consumes less energy than the conventional financial sector. Moreover, it has substantial potential to significantly accelerate the urgently needed transformation of the economy towards CO2 neutrality and, thus, to provide a significant contribution to climate protection. Furthermore, Blockchain technology also provides many people with easy access to various markets in which they were previously unable to participate due to existing barriers. Therefore, this form of investment also significantly concerns a social dimension. In the interest of good corporate governance, Immutable Insight Capital Management GmbH takes strict care to ensure at any time that its investments do not promote any blockchain system where there are indications of significant money laundering activities.

The remuneration of employees of Immutable Insight Capital Management GmbH is paid from the revenues generated by the company by conducting business in adherence to these guidelines for sustainable actions. The remuneration policy is therefore already designed to take sustainability risks in the areas of environment, social affairs and corporate governance into account and adheres to considering those. In addition, the remuneration system of Immutable Insight Capital Management GmbH is designed to avoid discrimination against employees on the grounds of gender. This means that a significant social aspect is also taken into account when determining the level of remuneration.