Legal Notice

The information contained on this website does not constitute investment advice, but is for informational purposes only.

The content of this website is protected by copyright. BlackPoint Asset Management GmbH endeavors to observe all property rights or copyrights of third parties or to use license-free documents, graphics, texts, data or video sequences. All brands and trademarks named on the website and possibly protected by third parties are subject without restriction to the provisions of the applicable trademark law and the ownership rights of the respective registered owner. The copyrights to the documents, graphics, texts, data or video sequences published on this website remain with their respective owners.

BlackPoint Asset Management GmbH continuously checks that its websites are up to date. Despite all care, the information may have changed in the meantime. Liability or guarantee for the topicality, correctness and completeness of the information provided cannot be assumed. The same applies to the content of websites to which reference is made via hyperlinks. BlackPoint Asset Management GmbH is not responsible for their content.

BlackPoint Asset Management GmbH reserves the right to make changes or additions to the information provided. In particular, the opinions expressed in our publications can change at any time and without warning. The content, layout and structure of the BlackPoint Asset Management GmbH websites are protected by copyright. The reproduction of information or data, in particular the use of texts, parts of text or images, requires the prior written consent of BlackPoint Asset Management GmbH.

You are welcome to send us complaints by telephone, in writing, by fax or by post using the following contact details:

BlackPoint Asset Management GmbH
Complaint management
Herrnstr. 44
80539 Munich
Germany

As part of your complaint, you should tell us, among other things, the cause and details of the complaint as well as your name and contact options through which we can reach you.

Immediately upon receipt, you will receive a written confirmation of the receipt of your complaint. We will then endeavor to clarify your request as quickly as possible and to comment on it. If this is not possible within a period of two weeks, you will receive an interim notification from us in text form. You will then receive a final statement on your concern no later than four weeks after receipt of your complaint. If this is not possible in individual cases, we will inform you of the reasons for this and a final date for the statement.

BlackPoint Asset Management GmbH is a member of the Association of Independent Asset Managers (VuV), which runs an arbitration board where you can apply for an arbitration procedure:

VuV ombudsman, Stresemannallee 30
60596 Frankfurt am Main
Germany
http://vuv-ombudsstelle.de/

The information provided on our website does not constitute an offer or an invitation to buy or sell fund units, investment advice or any other recommendation.

They are for informational purposes only. The public offering and sale of securities are subject to national laws and other statutory regulations in the individual countries.

The sole basis for the purchase of shares are the current, official sales documents for the respective fund (the current sales prospectus, the key investor information, the current annual report and the current semi-annual report). You can obtain these documents from us and from all paying agents, sales offices and management companies named in the respective sales prospectus. Investors are also strongly advised to seek advice from a financial advisor.

The information presented on the website is only aimed at investors in the countries in which the respective fund is authorized for sale. The information is not intended for publication or use by persons or companies in a country in which the fund is not authorized for sale. If texts or documents are made available in English, this does not mean that sales authorization for English-speaking countries has been granted or applied for. In particular, the information presented on this website is not intended for US citizens or persons with residence or permanent residence in the USA.

BlackPoint Asset Management GmbH is classified as a small securities institution due to its size, total assets and type of activity.

The company is therefore not an important institute within the meaning of the of Section 1 (2) InstitutsVergV. It is not systemically relevant and does not accept any customer money or securities from customers when providing financial services. There are no statutory requirements for remuneration systems for small securities institutions.

The company's remuneration system is appropriate and geared towards sustainable corporate development. The remuneration regulations are in line with the company's strategic objectives; the remuneration system is reviewed annually.

The company's remuneration system provides for fixed and variable components as part of the remuneration for employees and managers. The fixed remuneration component ensures the basic provision of the employees in accordance with their respective activities. A significant dependency of the employees on any variable remuneration can be excluded. The variable remuneration relates to the success resulting from team performance. This avoids inducing individual employees to take disproportionately high risks.

Due to legal regulations (Art. 3 Disclosure Regulation) we are obliged to provide the following information. We do not intend to advertise ecological or social characteristics in our investment strategies or for other specific financial instruments.

As a company, we want to make a contribution to a more sustainable, resource-efficient economy with the aim of reducing the risks and effects of climate change in particular. In addition to observing sustainability goals in our corporate organization, we see it as our task to also sensitize our customers to aspects of sustainability in the design of the business relationship with us.

Environmental conditions, social upheaval and / or poor corporate governance can have a number of negative effects on the value of our customers' investments and assets. These so-called sustainability risks can have a direct impact on the asset, financial and earnings position and also on the reputation of the investment property. Since such risks cannot ultimately be completely ruled out, we have developed specific strategies for the financial services we offer in order to be able to identify and limit sustainability risks.

In order to limit sustainability risks, we try to identify and, if possible, exclude investments in companies that have an increased risk potential. With specific exclusion criteria, we see ourselves in a position to base investment decisions (or investment recommendations) on environmental, social or company-related values. For this purpose, we generally use valuation methods that are recognized in the market.

The identification of suitable investments can consist in the fact that we invest (or recommend) in investment funds whose investment policy is already equipped with a suitable and recognized sustainability filter to reduce sustainability risks. The identification of suitable investments to limit sustainability risks can also consist in using recognized rating agencies for product selection in financial portfolio management (or for recommendations in investment advice). The specific details result from the individual agreements.

Our company's strategies for incorporating sustainability risks are also incorporated into the company's internal organizational guidelines. The observance of these guidelines is decisive for the evaluation of the work performance of our employees and thus has a significant influence on future salary development. In this respect, the remuneration policy is in line with our strategies for including sustainability risks (Art. 5 Disclosure Regulation).

Sustainability risks

Information on how to deal with sustainability risks and the most important negative effects on sustainability factors in accordance with the Disclosure Ordinance:

As a financial market participant i.S. From Art. 2 No. 1 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability-related disclosure obligations in the financial services sector (Disclosure Ordinance), BlackPoint Asset Management GmbH is obliged to provide the following information. We do not intend to advertise ecological or social characteristics in our investment strategies or for other specific financial instruments.

Investment decisions can have negative effects on the environment (e.g. climate, water, biodiversity), social and employee issues and also be detrimental to the fight against corruption and bribery.

In principle, we have a considerable interest in fulfilling our responsibility as a financial service provider and in helping to avoid such effects as part of our investment decisions (or investment recommendations). However, according to the current state of affairs, the implementation of the legal requirements specified for this is unreasonable due to the existing and still threatening bureaucratic framework conditions. In addition, essential legal issues are still unanswered.

In order to avoid legal disadvantages, we are currently prevented from making a public statement that and in what way we take into account the negative effects on sustainability factors (environmental issues, etc.) as part of our investment decisions (or investment recommendations). We are therefore obliged to declare on our website that we will not take this into account for the time being and until further clarification (Art. 4 Para. 1 b) Disclosure Regulation or Art. 4 Para. 5 b) Disclosure Regulation).

However, we expressly declare that this approach does not change our willingness to make a contribution to a more sustainable, resource-efficient economy with the aim of reducing the risks and effects of climate change and other ecological or social grievances in particular.

Description and publication of the participation policy in accordance with Section 134b AktG

We are an asset manager within the meaning of Section 134a (1) No. 2 AktG and must therefore comply with the provisions of Sections 134b and 134c AktG and describe and publish our participation policy within the meaning of Section 134b (1) AktG.

We do not exercise any of our customers' shareholder rights. No general meetings are attended, no voting rights are exercised for customers, notifications from stock corporations are only taken into account as part of mandatory notifications and there is no active communication with the company or with other shareholders. These statements apply to individual asset management mandates via individual custody accounts.

Therefore, the participation policy for individual asset management mandates via individual custody accounts was defined as follows:

1. We do not exercise any shareholder rights within the meaning of Section 134b (1) No. 1 AktG that are based on participation in the company. In particular, no rights relating to the general meetings of stock corporations are exercised. The right to a share in the profits within the meaning of §§ 60ff. AktG and subscription rights are exercised in consultation with the customer.
2. The monitoring of important company matters within the meaning of Section 134b (1) No. 2 AktG is carried out by taking note of the companies' statutory reporting in financial reports and ad hoc notifications.
3. An exchange of views with corporate bodies and / or stakeholders within the meaning of Section 134b (1) No. 3 AktG does not take place.
4. There is no cooperation with other shareholders within the meaning of Section 134b (1) No. 4 AktG.
5. If there are conflicts of interest within the meaning of Section 134b (1) No. 5 AktG, these will be disclosed to those affected in accordance with the statutory provisions and the further course of action will be clarified with those affected.
6. There is no annual reporting on the implementation of the participation policy within the meaning of Section 134b (2) AktG, as there is no corresponding exercise of rights.
7. The publication of the voting behavior within the meaning of Section 134b (3) AktG is not carried out as there is no participation in voting.

For the mutual fund managed by us (BlackPoint Evolution Fund), we pursue the policy of confronting stock corporations in which our fund is invested in the event of breaches of compliance with ESG criteria. The cooperation of the fund administration company of our mutual fund with IVOX Glass Lewis exerts influence on general meetings of companies with regard to ESG criteria.

IVOX Glass Lewis is a subsidiary of Glass, Lewis & Co., the leading independent governance analysis and proxy voting company with a worldwide client base of more than 1,200 organizations / companies who collectively manage more than $ 25 trillion in assets. Glass Lewis empowers institutional investors to make informed voting decisions at more than 22,000 meetings per year by identifying and assessing governance, business, legal, political and accounting risks at issuers based in 100 countries.

> IVOX Glass Lewis 2022 Policy Guidelines