TWE CREATE THE FUTURE

INTRODUCTORY PROVISIONS

Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on the disclosure of information related to sustainability in the financial services sector („SFDR”) establishes harmonized rules for Alternative Investment Company Managers regarding transparency with regard to the introduction of sustainability risks into their activities and the consideration of adverse sustainability effects in their operations, as well as with regard to their presentation of sustainability-related information on financial products. Under the SFRD, an obligation has been imposed on Alternative Investment Company Managers to report on the manner in which they have a sustainable investment policy or fail to implement such a policy. ESG policies(E – environment, S – community, G – corporate governance) address an integrated approach to investment, taking into account environmental, social and good governance practices. From ASI’s investment perspective, ESG considers, among other factors, such as:

• 1. sustainability,
• 2. investment risk,
• 3. values for investors,
• 4. reputation and legitimacy to invest.

In summary, according to the so-called Green Deal, the implementation of ESG policies in Alternative Investment Companies is expected to contribute to sustainable development, minimize investment risks, and serve to attract investors and build a positive reputation.

RISKS TO SUSTAINABLE DEVELOPMENT

According to the provisions of Article 2, paragraph 22 of the SFDR, sustainability risk means a situation or environmental, social or management-related conditions that, if they occur, could have, actual or potential, a material adverse effect on the value of an investment. ZASI declares that it has not drawn up strategies at the level of its organization defining a methodology for taking into account environmental, social or management-related conditions that, if they occur, could have, actual or potential, a material adverse effect on the value of the investment. ZASI declares that, it has not adopted strategies to take into account risks for sustainable development, as part of its activities (management of ASI), and therefore – in its current activities, these risks are not taken into account. In conclusion, in view of the above, ZASI does not include sustainability risks in the compensation structure of those responsible for ZASI’s operations, including not having a policy to reduce incentives for excessive investment risk in terms of including sustainability risks. ZASI does not rule out introducing strategies to address sustainability risks in the future.

MAIN ADVERSE EFFECTS OF INVESTMENT DECISIONS ON SUSTAINABLE DEVELOPMENT

According to the SFDR, major adverse effects on sustainable development should be understood as – those effects of investment decisions that adversely affect sustainability factors. i.e. environmental, social and labor issues, human rights issues, and anti-corruption and anti-bribery issues, and to which Article 4 and Article 7 of the SFDR refer. ZASI declares that when making investment decisions, no consideration is given to their adverse effects on sustainability factors, due to the specific nature of investment activities and the nature of deposits, and the limited availability of sustainability indicators. How and to what extent we consider the issue of major adverse impacts on sustainability factors may change over time, and consequently this statement may change. In particular, our assessment is that over time there will be an increase in the coverage of data that is necessary to take into account major adverse impacts on sustainability factors in the investment decision-making process. As the regulation and practice of sustainability-related disclosures in the financial services industry develops, industry standards for considering the adverse effects of investment decisions on sustainability factors are developed, and as the availability of sustainability data from potential investee companies increases, ZASI may include analysis of the adverse effects of investment decisions on sustainability in its strategy. ZASI’S ASI-MANAGED INVESTMENTS DO NOT PROMOTE ENVIRONMENTAL AND SOCIAL ASPECTS OR MAKE SUSTAINABLE INVESTMENTS. ZASI-MANAGED INVESTMENTS DO NOT TAKE INTO ACCOUNT EU CRITERIA FOR ENVIRONMENTALLY SUSTAINABLE ECONOMIC ACTIVITIES. In accordance with the disposition of Article 12 of the SFDR, ZASI shall ensure that any information published in accordance with Articles 3, 5 or 10 of the SFDR is kept up to date, and accordingly, ZASI shall periodically review the need for such updates. In the event that a financial market participant changes such information, it shall publish an understandable explanation of such change on the same website, which ZASI also implements.