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”) The following information is given in light of the consideration of sustainability-related aspects in accordance with the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27th of November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).
Date of Publication: 09 June 2023

Art. 6 SFDR – Transparency of the integration of sustainability risks Lucid Capital Management GmbH ("Lucid Capital”) 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, the Lucid Capital 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, Lucid Capital 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. Lucid Capital regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.

Art. 7 SFDR – No consideration of principal adverse impacts Lucid Capital 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. Lucid Capital does not use sustainability indicators. Considering the numerous legal uncertainties currently related to the application of the provisions of the SFDR and the Regulatory Technical Standards (RTS) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, Lucid Capital is not in a position to commit to such standard in light of its fiduciary duty to its Fund and its investors. Lucid Capital will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to Lucid Capital.

Transparency of remuneration policies in relation to the integration of sustainability risks As a registered alternative investment fund manager (AIFM) under the German Investment Code (Kapitalanlagegesetzbuch, "KAGB"), Lucid Capital does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. Therefore, Lucid Capital does not consider sustainability risks when determining remuneration, as defined by Article 5 of the SFDR.