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Lumaux Fund, under the management of Lumaux Management B.V. and in compliance with the EU’s Finance Disclosure Regulation (SFDR) 2019/2088 on sustainability-related disclosures in the financial services sector, assumes its responsibility under the Regulation to publish its policy on the integration of sustainability aspects in the investment strategies and management practices.

Article 3 of the SFDR puts obligation on financial market participants to publish on website information about policies on the integration of sustainability risks on the investment decision-making process. Under Article 2(22) of the SFDR, “sustainability risk” is defined as 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.

Lumaux Fund does not promote environment, social and/or governance characteristics and does not have sustainable investments as its objective as set out in Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector, because in the view of the manager of Lumaux Fund, the costs connected to it are disproportionate to the nature and size of Lumaux Fund. Especially as insufficient data is available on the portfolio companies to determine whether the Fund will meet its set sustainability objectives.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities as set out in Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment

If you have any questions about our SFDR disclosure, please feel free to contact us at L.Krieckaert@lumaux.com.