Sustainable Finance Disclosure Regulation (SFDR) Statement/Sustainability-Related Disclosure Obligations.

Disclosure requirements on sustainability-related disclosure obligations in the financial services sector pursuant to Regulation (EU) 2019/2088.

S-UBG Aktiengesellschaft Unternehmensbeteiligungsgesellschaft für die Regionen Aachen, Krefeld und Mönchengladbach (S-UBG) is a capital management company within the meaning of the German Investment Code (KAGB). It publishes the following information on its website in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosure requirements in the financial services sector (the “SFDR”).

Unless information is explicitly provided in relation to a specific S-UBG, the following information relates to S-UBG’s management and investment decision-making processes in general.

I. DEALING WITH SUSTAINABILITY RISKS IN THE INVESTMENT PROCESS
S-UBG supports the European Union’s efforts to increase transparency on sustainability issues and considers sustainability risks as part of the investment decision-making process and due diligence prior to any investment. “Sustainability risk” means an environmental, social or governance event or condition, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.

After due consideration, S-UBG reserves the right to decide not to invest or to invest despite sustainability risks, in which case S-UBG may take measures to reduce or mitigate any sustainability risks. The benchmark for a decision by S-UBG in dealing with sustainability risks is the principle of proportionality. This means that the effort involved should always be proportionate to the size and type of investment as well as the transactional context and the associated scope.

We regularly review our strategy to ensure that it takes into account new risks as well as investor concerns.

II. DEALING WITH ADVERSE SUSTAINABILITY IMPACTS
S-UBG’s approach is to consider adverse impacts of investment decisions on sustainability factors.

“Key adverse impacts on sustainability factors” are those impacts of investment decisions that have adverse impacts on sustainability factors.

“Sustainability factors” are environmental, social and labor concerns, respect for human rights, and anti-corruption and anti-bribery.

A concept is currently being developed to integrate sustainability indicators into the due diligence process in an even more structured and measurable way prior to investment receipt. Work is also being carried out on implementing controlling with regard to sustainability factors for ongoing portfolio management in order to ensure continuous monitoring of the investments. If adverse effects on sustainability factors become known, S-UBG enters into a mitigation process with the management of the respective investment, whereby the principle of proportionality also applies here. S-UBG has set itself the goal of anchoring sustainability goals in the strategic orientation of its own organization and its portfolio companies. S-UBG’s long-term goal is for its awareness of sustainability to be reflected in the strategies, business organization and risk management of the supervised companies.