(Valid for all references to “Deistler Family Office” on www.deistler.family and associated materials)

Responsible Entities under German Law (§ 5 TMG, § 18 Abs. 2 MStV)

Deistler Family Office (Legal Definition)

For the purposes of all documents, website references, disclosures, legal statements, policies and regulatory notices provided on this website or in related communications, the term “Deistler Family Office” shall refer collectively to the following legal entities (together the “Deistler Family Office Entities” or “Deistler Group”):

1. Victoria Mittelstandsbeteiligungsgesellschaft mbH

Registered Office / Sitz der Gesellschaft:
Berliner Straße 46
61449 Steinbach im Taunus
Germany

Legal Form:
Gesellschaft mit beschränkter Haftung (GmbH)

Commercial Register:
Handelsregister des Amtsgerichts Friedberg

Register Number:
HRB10707

Represented by / Vertretungsberechtigt:
Geschäftsführer: Nicolas Alexander Müller

Shareholder Structure / Gesellschafterstruktur:
Sole Shareholder (Alleingesellschafter): Daniel Deistler

Contact:
E-Mail: info@deistler.family
Website: www.ckcf.de

2. HD Venture Group UG (haftungsbeschränkt)

Registered Office / Sitz der Gesellschaft:
Limburger Straße 52
61476 Kronberg im Taunus
Germany

Legal Form:
Unternehmergesellschaft (haftungsbeschränkt)

Commercial Register:
Handelsregister des Amtsgerichts Königstein im Taunus

Register Number:
HRB10827

Represented by / Vertretungsberechtigt:
Geschäftsführer: Hendrik Deistler

Contact:
E-Mail: info@deistler.family
Website: www.hd-venture.com

Unified Corporate Definition Clause (very important)

Legal Definition for All Documentation

For purposes of all legal notices, disclosures, policies, website terms, regulatory statements, agreements, disclaimers, risk disclosures and any related documentation provided on or via www.deistler.family, the term:

“Deistler Family Office”

shall collectively refer to, and shall be deemed to include, HD Venture Group UG (haftungsbeschränkt) and Victoria Mittelstandsbeteiligungsgesellschaft mbH, including their respective directors, officers, employees, affiliates and any entities under common management or control.

Any reference to the “Family Office”, “we”, “us”, or “our” shall be construed accordingly.

Contact Information pursuant to § 5 TMG

E-Mail: info@deistler.family
Postal Address:
Deistler Family Office

c/o HD Venture Group
Limburger Straße 52
61476 Kronberg im Taunus
Germany

Regulatory Status

The Deistler Group does not offer regulated financial services to retail clients.
Any investment activity, co-investment structure, or transaction is conducted privately and exclusively with qualified partners, institutions, or professional investors.

Editorially Responsible Person (§ 18 Abs. 2 MStV)

Hendrik Deistler
Limburger Straße 52
61476 Kronberg im Taunus
Germany

Disclaimer on External Links (§ 7–10 TMG)

Deistler Family Office is not responsible for external content linked to or referenced on this website. Liability arises only if the operator becomes aware of unlawful content and fails to remove or block such content.

Copyright Notice

All content, text, media, analysis, research, documents and data on this website are protected by copyright.
Any use requires prior written permission of the Deistler Group.

Governing Law

This Legal Notice is governed by the laws of the Federal Republic of Germany.

EU SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR)

GLOBAL SUSTAINABLE INVESTMENT DISCLOSURE FRAMEWORK
OF DEISTLER FAMILY OFFICE

Last updated: January 2025

I. INTRODUCTION AND REGULATORY CONTEXT

1. The Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088, “SFDR”) forms a central pillar of the European Union’s Sustainable Finance Action Plan. It establishes harmonised rules on transparency with regard to the integration of sustainability risks, the consideration of adverse sustainability impacts, and the promotion of environmental or social characteristics and sustainable investment objectives in the financial services sector.
2. SFDR applies to financial market participants and financial advisers within the European Union and, indirectly, to non-EU entities providing products or services to EU investors or acting under delegation or sub-advisory arrangements for EU-regulated entities. In this context,Deistler Family Office (“Deistler”, “we”, “us”, “our”) recognises SFDR as a key regulatory framework impacting our investment vehicles, tailored mandates, co-investment structures and advisory relationships that are, directly or indirectly, in scope of SFDR.
3. Since the publication of SFDR in 2019, Deistler has treated SFDR as a strategic regulatory priority. We have implemented SFDR Level 1 requirements by March 2021 and have established a dedicated programme to achieve and maintain alignment with the SFDR Level 2 Regulatory Technical Standards (“RTS”).
4. This SFDR Disclosure Framework outlines Deistler’s approach at:
   • entity level(Articles 3, 4 and 5 SFDR); and
   • product level(Articles 6, 8 and 9 SFDR, as applicable),

and is designed to be consistent with our broader sustainable investment and ESG integration framework.

5. This document is global in scope and is intended to support SFDR-compliant disclosures for all relevant Deistler structures where SFDR applies directly or indirectly (e.g. via delegation to EU AIFMs/UCITS ManCos or advisory relationships with EU-regulated institutions).
   
   

II. IMPLEMENTATION OF SFDR LEVEL 1 REQUIREMENTS

1. By March 2021, Deistler implemented the core SFDR Level 1 requirements for in-scope activities, covering:
2. Article 3 SFDR – Sustainability Risk Policies
   Adoption of internal policies describing how sustainability risks are integrated into investment decision-making and advisory processes, including definitions, governance, procedures and escalation mechanisms.
3. Article 4 SFDR – Principal Adverse Impacts (PAI)
   Assessment of whether and how principal adverse impacts of investment decisions on sustainability factors are considered at the entity and/or product level, including criteria for PAI consideration and related methodologies.
4. Article 5 SFDR – Remuneration Policies
   Integration of sustainability risk considerations into remuneration policies, ensuring that remuneration structures do not encourage excessive risk-taking with respect to sustainability risks.
5. Articles 6, 8 and 9 SFDR – Product-Level Transparency
   Initial classification and disclosure of products with regard to:
   • integration of sustainability risks (Article 6);
   • promotion of environmental and/or social characteristics (Article 8);
   • sustainable investment as an objective (Article 9),

together with relevant pre-contractual disclosures.

2. The initial SFDR Level 1 implementation included:
   • mapping of all in-scope products and mandates;
   • establishment of internal classification criteria;
   • drafting and publication of relevant website disclosures;
   • adaptation of due diligence and documentation processes to reflect SFDR requirements.
     
     

III. PREPARATION AND ALIGNMENT WITH SFDR LEVEL 2 (RTS)

1. SFDR Level 2 RTS set out prescriptive and standardised templates for pre-contractual, website and periodic disclosures for products falling under Articles 8 and 9, and detailed requirements for entity-level PAI disclosures.
2. Deistler has initiated and is continuously enhancing a comprehensive SFDR Level 2 alignment programme, including:
3. Data Management and Infrastructure
   • Identification of data requirements for PAI indicators (environmental, social, employee, human rights, anti-corruption and anti-bribery matters);
   • Integration of ESG data from external providers and internal research;
   • Establishment of data quality controls and validation checks;
   • Design of templates and processes to feed RTS Annexes (e.g. Annex II, III, IV, V, etc.).

1. Methodology Development

• Definition of methodologies for each mandatory and, where applicable, additional PAI indicators;
• Documentation of calculation approaches, estimation techniques, use of proxies and treatment of data gaps;
• Establishment of internal sign-off processes for methodology approval and review.

1. Governance and Oversight

• Extension of governance responsibilities for SFDR-related decisions to relevant committees and oversight functions;
• Regular review of SFDR classification of products;
• Ensuring coherence between SFDR and other sustainable finance regulations (e.g. EU Taxonomy).

1. Disclosure Processes

• Preparation of standardised pre-contractual SFDR RTS annexes for in-scope products (Articles 8 and 9);
• Design of periodic SFDR reporting templates;
• Alignment of public website disclosures with RTS detailed requirements.
  
  

IV. SUSTAINABILITY GOVERNANCE AND ORGANISATIONAL STRUCTURES

1. Firmwide ESG and Sustainability Framework
   Deistler’s approach to ESG and sustainability integration is anchored in firmwide policies and overseen by senior leadership. Sustainability is integrated into:
   • investment strategy formulation;
   • risk management;
   • product governance;
   • internal control functions and compliance oversight.
2. Sustainable Investment Committee
   Deistler has established a Sustainable Investment Committee with the following responsibilities:
   • oversight of sustainability risk integration;
   • review and approval of SFDR-relevant policies and methodologies;
   • validation of product classifications under Articles 6, 8, and 9;
   • periodic review of PAI indicators and associated disclosures;
   • monitoring regulatory developments in sustainable finance.
3. Sustainable Investment Regulatory and Third-Party Working Group
   Deistler has created a specialised working group dedicated to:
   • regulatory monitoring in sustainable finance and ESG-related topics;
   • coordination with external ESG data providers, consultants, auditors and legal counsel;
   • implementation and maintenance of SFDR-related processes and systems;
   • ensuring alignment of delegated and outsourced arrangements with SFDR requirements.
4. Internal Control Functions
   Compliance, Risk Management and Internal Audit functions provide second- and third-line oversight over SFDR-related frameworks, including:
   • review of methodologies and assumptions;
   • testing of control effectiveness;
   • verification of disclosures and reporting.
     
     

V. ESG INTEGRATION AND SUSTAINABILITY RISK MANAGEMENT

1. Definition of Sustainability Risks
   Deistler defines sustainability risks in line with SFDR as environmental, social or governance events or conditions that, if they occur, could cause an actual or potential material negative impact on the value of an investment.
2. Integration into Investment Decisions
   Sustainability risks are considered within the broader investment process, including:
   • issuer- and asset-level analysis;
   • sectoral and thematic risk assessment;
   • portfolio construction and allocation decisions;
   • ongoing monitoring and review.
3. Tools and Approaches
   • qualitative and quantitative ESG assessments;
   • third-party ESG ratings and internal research;
   • engagement with investee entities, where appropriate;
   • scenario analyses and stress testing, where relevant.
4. Interaction with Traditional Financial Risks
   Sustainability risks are evaluated alongside traditional risk categories (e.g. market, credit, liquidity, operational risks) and may influence investment decisions and risk mitigation strategies.
   
   

VI. PRINCIPAL ADVERSE IMPACTS (PAI)

1. Entity-Level PAI Approach (Article 4 SFDR)
   Deistler has established an internal framework for assessing principal adverse impacts of investment decisions on sustainability factors at entity level. This includes:
   • consideration of relevant PAI indicators;
   • identification of data sources;
   • evaluation of data limitations;
   • development of procedures to mitigate or address identified adverse impacts, where possible.
2. Product-Level PAI Considerations
   For certain products, Deistler may explicitly consider PAIs at product level and reflect this in:
   • pre-contractual documentation;
   • periodic reporting;
   • website disclosures in line with SFDR RTS.
3. Further methodological detail is provided inAnnex C – PAI Methodology Framework.
   
   

VII. PRODUCT CLASSIFICATION UNDER SFDR (ARTICLES 6, 8, 9)

1. Article 6 Products
   These products:
   • do not promote environmental or social characteristics nor have sustainable investment as an objective;
   • nonetheless integrate sustainability risks into investment decisions where such risks are considered relevant and material.
2. Article 8 Products
   These products:
   • promote, among other characteristics, environmental or social characteristics;
   • may invest in companies following good governance practices;
   • are subject to pre-contractual and periodic SFDR RTS disclosures specifying how characteristics are met.
3. Article 9 Products
   These products:
   • have sustainable investment as their objective;
   • are subject to the most stringent SFDR RTS disclosure standards;
   • must demonstrate alignment with their stated sustainable investment objective, including “do no significant harm” assessments and good governance practices.
4. Deistler maintains product-specific SFDR documentation as outlined inAnnex B – Product Classification and Disclosure Framework.
   
   

VIII. PARTNERSHIP WITH CLIENTS, INVESTORS AND CO-INVESTORS

1. Deistler aims to support clients and co-investors in aligning their financial objectives with sustainability preferences and regulatory obligations.
2. This includes:
   • dialogue on sustainability objectives;
   • provision of SFDR-related data and reporting, subject to contractual agreements;
   • support for institutional investors in meeting their own SFDR and broader ESG disclosure obligations.
3. Our goal is to deepen partnerships with clients and co-investors by enabling them to achieve both financial and sustainability-related investment objectives.
   
   

IX. DISCLAIMER AND LIMITATIONS

1. This SFDR Disclosure Framework provides a high-level summary of Deistler’s approach to SFDR implementation. It does not constitute legal, tax, regulatory or investment advice.
2. Product classifications, methodologies and disclosures may evolve over time in response to:
   • regulatory developments;
   • supervisory expectations;
   • changes in market practice;
   • data availability and technological advancements.
3. Deistler reserves the right to amend this Framework and associated annexes where necessary and will update disclosures as required under applicable law and guidance.
   
   

X. CONTACT

Questions regarding Deistler’s SFDR framework may be directed to:

Sustainable Investment & Regulatory Affairs
Deistler Family Office
Email: info@deistler.family

ANNEX A – ENTITY-LEVEL SFDR DISCLOSURES (ARTICLES 3, 4 AND 5)

A.1 Article 3 – Sustainability Risk Policies

Deistler has adopted a written Sustainability Risk Policy that:

1. Defines sustainability risks in connection with investment decisions and advisory services.
2. Describes how such risks are integrated into investment analysis and decision-making, including:
   • assessment of material sustainability factors;
   • integration of ESG data and research into due diligence;
   • ongoing monitoring of sustainability risks at portfolio level.
3. Specifies governance arrangements for oversight of sustainability risks, including:
   • allocation of responsibilities to portfolio managers, risk management and compliance;
   • escalation procedures in case of material risk findings;
   • periodic reporting to senior management and relevant committees.
     
     

A.2 Article 4 – Principal Adverse Impacts (PAI)

1. Deistler has established a framework for evaluating whether it considers principal adverse impacts of investment decisions on sustainability factors at entity level, taking into account:
   • data availability and quality;
   • nature and scale of investment activities;
   • proportionality and feasibility constraints.
2. Where Deistler considers PAIs at entity level, it:
   • discloses a statement on due diligence policies with respect to such impacts;
   • outlines the methodologies and indicators used;
   • explains actions taken and planned to mitigate adverse impacts;
   • reports on adherence to relevant codes of conduct or international standards, where applicable.
3. Where Deistler does not consider PAIs at entity level for specific reasons, such reasons are transparently disclosed in accordance with SFDR requirements.
   
   

A.3 Article 5 – Remuneration Policies and Sustainability Risks

1. Deistler’s remuneration policies are designed to:
   • align with sound and effective risk management;
   • not encourage excessive or imprudent risk-taking;
   • take sustainability risks into account, as relevant.
2. This includes:
   • incorporating qualitative assessment of risk management behaviours, including ESG-related risk;
   • ensuring that variable remuneration is not structured to incentivise disregard for sustainability risks;
   • periodic review to ensure consistency with SFDR and other regulatory frameworks.

ANNEX B – PRODUCT CLASSIFICATION AND DISCLOSURE FRAMEWORK

1. Deistler maintains an internalProduct Governance and Classification Framework under which each in-scope product is assessed and categorised as:
   • Article 6;
   • Article 8; or
   • Article 9.
2. The classification process includes:
   • assessment of the product’s investment strategy and objectives;
   • evaluation of whether environmental or social characteristics are promoted;
   • determination of whether sustainable investment is the product’s objective;
   • review of portfolio construction guidelines, exclusion criteria, engagement policies and sustainability overlays.
3. For Article 8 and 9 products, Deistler:
   • prepares RTS-compliant pre-contractual disclosures (Annexes II–V as appropriate);
   • publishes website disclosures describing characteristics or objectives, methodologies, data sources, and indicators;
   • provides periodic disclosures demonstrating how characteristics have been met or objectives achieved, in line with RTS templates.
4. This framework is subject to periodic review and may be updated in light of regulatory guidance and supervisory practice.
   
   

ANNEX C – PRINCIPAL ADVERSE IMPACT (PAI) METHODOLOGY

1. Scope and Indicators
   Deistler identifies mandatory PAI indicators as defined under SFDR RTS and may, where appropriate, consider additional voluntary indicators. These indicators may cover:
   • greenhouse gas emissions;
   • biodiversity impacts;
   • water-related impacts;
   • waste and resource management;
   • social and employee matters;
   • respect for human rights;
   • anti-corruption and anti-bribery matters.
2. Data Sourcing and Quality
   • Use of multiple data providers, supplemented by internal research where appropriate;
   • Assessment of data coverage, consistency and quality;
   • Documentation of the use of estimates, proxies and assumptions;
   • Mitigation of data quality issues through validation checks and cross-comparisons.
3. Methodologies
   • Calculation approaches aligned with RTS requirements;
   • Aggregation of PAI indicators at portfolio and entity level;
   • Periodic review of methodologies to reflect market and regulatory developments.
4. Actions and Engagement
   • Consideration of escalation or engagement with investees where PAIs are identified;
   • Evaluation of potential portfolio-level mitigation measures;
   • Documentation of actions taken and planned.
     
     

ANNEX D – SUSTAINABILITY RISK INTEGRATION PROCEDURES

1. Sustainability risks are integrated at:
   • idea generation;
   • pre-investment due diligence;
   • investment approval;
   • portfolio monitoring;
   • periodic review and rebalancing.
2. Tools and documentation include:
   • ESG risk checklists;
   • sectoral ESG risk maps;
   • internal ESG memos;
   • risk dashboards and alerts.
3. Deistler documents how sustainability risks may affect expected returns and risk profiles and, where necessary, may adjust investment decisions accordingly.
   
   

ANNEX E – GOVERNANCE AND OVERSIGHT ARCHITECTURE

1. Board and Senior Management Oversight
   • Oversight of sustainable investment strategy and SFDR alignment;
   • Review and approval of key sustainability policies.
2. Sustainable Investment Committee
   • Detailed oversight over methodologies, product classification and disclosures;
   • Monitoring of regulatory developments.
3. Compliance and Risk Functions
   • Ongoing control and monitoring of SFDR implementation;
   • Review of disclosures and documentation.
4. Internal Audit
   • Independent periodic reviews of SFDR-related frameworks, methodologies and controls.
     
     

ANNEX F – SUSTAINABILITY DATA VENDOR REGISTRY

Deistler may use sustainability data from external providers, including (names illustrative):

Each vendor is engaged under contractual arrangements covering:

• scope of data usage;
• data quality and reliability;
• confidentiality and intellectual property;
• data protection and security;
• audit and review rights.
  
  

ANNEX G – ESG DATA QUALITY, VALIDATION AND AUDIT FRAMEWORK

1. Data Quality Controls
   • Coverage analysis;
   • Consistency checks;
   • Outlier detection;
   • Cross-validation of multiple sources where feasible.
2. Governance of Methodologies
   • Documentation of all sustainability-related methodologies;
   • Periodic review by the Sustainable Investment Committee;
   • Version control and change management.
3. Audit and Assurance
   • Inclusion of sustainability data processes within internal audit programmes;
   • External reviews or assurance where appropriate and feasible.
     
     

ANNEX H – EU TAXONOMY INTERACTION (WHERE APPLICABLE)

1. For products in scope of the EU Taxonomy Regulation, Deistler:
   • assesses alignment of underlying activities with Taxonomy criteria where data permit;
   • discloses Taxonomy alignment in accordance with SFDR RTS requirements;
   • updates methodologies in line with evolving Taxonomy Delegated Acts and guidance.
     
     

ANNEX I – STEWARDSHIP, ENGAGEMENT AND ESCALATION FRAMEWORK

1. Where Deistler exercises stewardship and engagement, it may:
   • engage with investees on material sustainability issues;
   • encourage improved disclosure of ESG metrics;
   • escalate concerns where material sustainability risks or adverse impacts are identified.
2. Engagement activities may be reflected in:
   • product literature;
   • periodic sustainability reports;
   • SFDR-linked disclosures where relevant.
     
     

ANNEX J – SFDR TEMPLATE DISCLOSURES (ARTICLES 8 AND 9 PRODUCTS)

For products classified as Article 8 or 9, Deistler prepares pre-contractual and periodic disclosures using the standardised SFDR RTS templates (such as Annexes II–V RTS), adapted to the product’s specific features. These templates:

• describe environmental or social characteristics or sustainable investment objectives;
• explain how they are met or pursued;
• detail methodologies, data sources and limitations;
• present PAI-related indicators and results where applicable.