DBAG ECF II

DBG Managing Partner GmbH & Co. KG is an AIF capital management company registered under the German Capital Investment Code (Kapitalanlagegesetzbuch, KAGB) and, as such, is required to disclose sustainability-related information in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR).

Information on the integration of sustainability risks in the investment decision‐making process
DBG Managing Partner GmbH & Co. KG integrates sustainability risks into its investment decision-making processes, as described in 2.2. of the guideline "Sustainability and Responsible Investment". A sustainability risk is an environmental, social or governance event or condition, the occurrence of which could cause an actual or a potential material negative impact on the value of the investment.

No consideration of adverse impacts of investment decisions on sustainability factors
DBG Managing Partner GmbH & Co. KG is aware of the relevance of considering sustainability risks in investment decision-making processes. However, it currently does not consider any adverse impacts of its investment decisions on sustainability factors pursuant to Art. 4 SFDR and, hence, does not use the sustainability indicators listed in Annex I of the Delegated Regulation (EU) 2022/1288 (as amended from time to time, RTS) to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery.

Given that the SFDR and the accompanying RTS, which determine the sustainability indicators to be used and provide details on mandatory processes to obtain the respective data at portfolio company level, are relatively new legislative acts, there is – as of now – very little practical experience or practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions. Additionally, DBG Managing Partner GmbH & Co. KG is currently not in a position, in its view, to compile all the data required in a systematic, consistent manner and at reasonable costs.

This decision is subject to regular review by the management of DBG Managing Partner GmbH & Co. KG. If and to the extent that the legal uncertainties will be resolved, a practicable market and administrative practice will evolve in this regard and data availability can be ensured, DBG Managing Partner GmbH & Co. KG will re-evaluate considering principal adverse impacts of its investment decisions.

Information on the remuneration policy
As a registered AIF capital management company, DBG Managing Partner GmbH & Co. KG does not have a formulated remuneration policy in accordance with the requirements of the KAGB. However, DBG Managing Partner GmbH & Co. KG appropriately considers sustainability risks as part of its remuneration policy and its remuneration policy is consistent with the inclusion of sustainability risks. The remuneration system of DBG Managing Partner GmbH & Co. KG does not offer any incentives to take sustainability risks in relation to DBG Managing Partner GmbH & Co. KG or the alternative investment funds it manages.