Regulatory information

Qurtuba Management S.à r.l. ("Qurtuba Management") is a Luxembourg alternative investment fund manager within the scope of Article 3 of the Law of 12 July 2013 on alternative investment fund managers, as amended. The competent supervisory authority is the Commission de Surveillance du Secteur Financier (CSSF).

Registered office: 2-4, Parc d'Activités Capellen, L-8308 Capellen, Luxembourg. RCS Luxembourg: B302689.

These disclosures are made under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR).

Integration of sustainability risks (Article 3 SFDR)

A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. Qurtuba Management takes sustainability risks into account in its investment decision-making and risk management for the funds it manages:

• Before an investment is made, relevant sustainability risks are identified as part of due diligence, in proportion to the asset class and strategy concerned.
• Where an investment adviser is appointed or portfolio management is delegated, Qurtuba Management assesses how the adviser or delegate identifies and manages sustainability risks, and monitors this as part of its ongoing oversight.
• Material sustainability risks are monitored alongside other investment risks under Qurtuba Management's risk management policy and reported to its management.

The likely impact of sustainability risks on the returns of a fund is described in that fund's offering documents.

No consideration of principal adverse impacts (Article 4 SFDR)

Qurtuba Management does not currently consider the principal adverse impacts of its investment decisions on sustainability factors, within the meaning of Article 4(1)(b) SFDR. The reasons are:

• Funds managed by Qurtuba Management may pursue different strategies, set by their sponsors, across private-market assets for which consistent and comparable adverse-impact data is often unavailable.
• Producing the full statement required under the SFDR regulatory technical standards would rely on estimates for most indicators, which Qurtuba Management does not consider would give investors reliable information.
• The size, nature and scale of Qurtuba Management's activities make this approach proportionate.

Qurtuba Management reviews this position at least once a year and will reconsider it as data availability improves and as the EU review of SFDR progresses.

Remuneration policy and sustainability risks (Article 5 SFDR)

Qurtuba Management's remuneration policy is consistent with sound and effective risk management, including the integration of sustainability risks:

• Where variable remuneration is awarded, the assessment of individual performance includes adherence to Qurtuba Management's risk management and sustainability risk policies, and no remuneration is linked to the performance of an individual fund in a way that could encourage risk-taking beyond the fund's risk profile, including in relation to sustainability risks.
• The remuneration of staff in control functions is independent of the performance of the funds they oversee.

A summary of the remuneration policy is available free of charge on request.

Fund-level disclosures

Where a fund managed by Qurtuba Management promotes environmental or social characteristics (Article 8 SFDR) or has sustainable investment as its objective (Article 9 SFDR), the disclosures required by Article 10 SFDR are made available on this website.

Qurtuba Management handles complaints promptly, fairly and free of charge, in line with CSSF Regulation No 16-07 on out-of-court complaint resolution.

1. How to make a complaint. Write to the Complaints Officer, Qurtuba Management S.à r.l., 2-4, Parc d'Activités Capellen, L-8308 Capellen, Luxembourg, or email complaints@qurtubacapital.com. Please include your name and contact details, the fund concerned (if any), a description of the complaint and copies of relevant documents.
2. Acknowledgement. We acknowledge receipt in writing within 10 business days.
3. Response. We respond as promptly as possible and no later than one month after receipt. If we cannot do so, we will tell you why and when you can expect an answer.
4. Escalation. If you are not satisfied with our response, you may ask for your complaint to be reviewed by a member of senior management.
5. Referral to the CSSF. If you have not received an answer, or a satisfactory answer, within one month of sending your complaint, you may ask the CSSF to deal with it under its out-of-court complaint resolution procedure. The request must be filed with the CSSF within one year of filing your complaint with us. Details: www.cssf.lu/en/customer-complaints.

Complaints may be submitted in English.

The following are available free of charge on request to info@qurtubacapital.com:

• Summary of the remuneration policy
• Conflicts of interest policy
• Complaints handling policy