Blackbird Digital Assets Trading GP S.à r.l. (the “AIFM”) is in the process of being registered as an alternative investment fund manager with the Commission de Surveillance du Secteur Financier (CSSF) pursuant to Article 3 of the Luxembourg law of 12 July 2013 on alternative investment fund managers, as amended.
In accordance with Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), the AIFM provides the following disclosures in respect of the alternative investment fund it manages (the “AIF”).
Pursuant to Article 3, 4 and 5 of the SFDR, the AIFM is required to publishes information concerning its policies regarding the integration of sustainability risks policy and principal adverse impact policy in its activity.Policy on Sustainability Risks:
The AIF has no sustainability risks which are deemed to be relevant in respect of the Partnership pursuant to article 6 of SFDR. Therefore, sustainability risks are not integrated into the investment decisions. Indeed, the AIF does not pursue or promote ESG objectives for the moment nor has Sustainable Investments’ objectives. The AIFM considers applying ESG criteria to the investment process may exclude certain assets for non-investment reasons and therefore some market opportunities available to the Partnership.
Investment Objective and ESG Characteristics:
The AIF managed by the AIFM do not prioritize sustainable investments as their investment objective, nor do they endorse ESG characteristics, in accordance with Articles 8 and 9 of SFDR (the "AIF"). ESG considerations are not mandatory for the investment decision-making process. However, although the investment policy of the AIFs does not explicitly prioritize sustainable investments or ESG criteria, it is acknowledged that certain underlying investments may have connections with sustainable investments and/or ESG, which are not expressly factored into the investment process. The investments underlying this AIF do not align with the EU criteria for environmentally sustainable economic activities, as specified by the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment and amending the SFDR (the “Taxonomy Regulation”).
Principal adverse impacts:
The AIFM does not take into account principal adverse impacts at the level of the investment processes of the AIF it manages as its investment policies do not promote any environmental and/or social characteristics. However, the AIFM would also pay particular attention if and when the AIF it manages would express its wish to have ESG targets integrated in the future in the investment objectives.