Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”)

I. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)

SHS is a long-term investor in the healthcare sector. Investment decisions also take into account environmental, social and corporate governance (ESG) criteria insofar as they are relevant to the healthcare sector. Potential risks are identified and assessed as part of a systematic due diligence process. In the event of an investment, the respective SHS portfolio company commits to aligning itself with ESG principles and, at the same time, a plan of action to improve its ESG standing is agreed between SHS and the management and implemented in due course. The successful implementation of these measures is reviewed and evaluated annually (SHS internal scoring model).

II. Principle adverse sustainability impact statement (Article 4 SFDR)

Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors as defined in the SFDR. For this purpose, financial market participants such as SHS Gesellschaft für Beteiligungsmanagement mbH must disclose certain information (in the future, taking into account the Regulatory Technical Standards (RTS)). Currently, SHS Gesellschaft für Beteiligungsmanagement mbH believes that the information provided to it by the portfolio companies in relation to the investments is not yet sufficient (in particular with a view to the extensive requirements of the future RTS) to allow it to do so. Accordingly, it must be assumed that SHS Gesellschaft für Beteiligungsmanagement mbH does not yet take into account any principle adverse impact of investment decisions on sustainability factors as specified in Art. 4 of the SFDR. However, SHS Gesellschaft für Beteiligungsmanagement mbH will monitor developments with regard to available information on an ongoing basis and consider whether it is reasonably possible in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).

III. Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)

As a registered AIFM within the meaning of section 2(4) of the KAGB, SHS Gesellschaft für Beteiligungsmanagement mbH does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. The integration of sustainability risks is considered separately with respect to the determination of the remuneration.