Authorization

Digital Transformation Capital Partners GmbH is licensed as an investment firm (Wertpapierinstitut) pursuant to the German Investment Firms Act (Wertpapierinstitutsgesetz, WpIG) under the supervision of the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin).

Scope of Authorization

Digital Transformation Capital Partners GmbH holds a license pursuant to Section 15 of the German Investment Firms Act (WpIG) for investment brokerage (Anlagevermittlung, Section 2 (2) No. 3 WpIG) and investment advisory services (Anlageberatung, Section 2 (2) No. 4 WpIG), in each case without acquiring ownership or possession of funds or securities of clients or acquiring or disposing of financial instruments for its own account when providing these investment services.

Responsible Supervisory Authority

German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht, BaFin)

Marie-Curie-Strasse 24 – 28, 60439 Frankfurt am Main, Germany

Phone: +49 228.4108 0

Fax: +49 228.4108 1550

www.bafin.de

poststelle@bafin.de

Statutory Compensation Scheme

Digital Transformation Capital Partners GmbH is assigned to the Compensatory Fund of Securities Trading Companies (Entschädigungseinrichtung der Wertpapierhandelsunternehmen, EdW).

Behrenstrasse 31, 10865 Berlin, Germany

Phone: +49 30 203699 5626

Email: mail@e-d-w.de www.e-d-w.de

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Customer Complaints

A complaint or issue of dissatisfaction can be submitted, free of charge, in the following ways to Digital Transformation Capital Partners GmbH’s complaints management function:

In writing to:
Digital Transformation Capital Partners GmbH
Dr. Stefan Graiche
Am Sandtorpark 2
20457 Hamburg

By phone: +49 151 67828470

By email: stefan.graiche@dtcp.capital

On receipt of your communication, we will undertake an assessment as to whether this is a complaint in connection with our investment services and should be handled in line with our internal complaints policy. 

If that is the case, we will provide an acknowledgement of your complaint promptly and will keep you informed of our progress in reviewing your complaint. 

We will ensure that we investigate the complaints effectively, impartially, competently and diligently. We will seek additional information where necessary. Our assessment of the complaint will be made promptly, adequately and without conflicts of interest. We will assess the remedial action or redress that is appropriate if the complaint is upheld and will also assess whether another respondent party is solely or jointly responsible for the issue raised within the complaint. We will communicate our position on the complaint to you and inform you about your options, including that you may be able to take civil action. 

When an answer cannot be provided within three business days, we will inform you about the causes of the delay and indicate when the investigation by us is likely to be completed. We will provide you with details of who is internally responsible for handling your complaint and who will provide you with updates. 

All final answers to you will be provided on paper or in another durable medium, to the extent that you have not expressly demanded an oral answer only. Alternatively, oral complaints can only be answered orally if you consent to this. 

We will ask you to confirm if you are satisfied with our conclusion. Where the offer of remedial action or redress is accepted, we will ensure that we comply with the terms of this. If you are not satisfied with our conclusion, we will not close your complaint and will continue to seek resolution.

Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)

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Date of publication: March 2021

Date of update: November 2023, implementation of recent legislative and regulatory developments as well as editorial amendments

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I. Sustainability risks

Digital Transformation Capital Partners GmbH (“DTC”) (LEI: 391200N4AVRS726J8498) integrates sustainability risks in its investment advisory decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. In its due diligence process, DTC conducts thorough due diligence work on all investment opportunities. Such due diligence work includes ESG related aspects and assessments to the extent relevant. This also includes an assessment of sustainability risks. The results of such due diligence work are taken into account when providing investment advice. At all times, DTC will apply the principle of proportionality taking due account of the relevance of ESG aspects in light of the specific investment opportunities as well as its transactional context.

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II. No consideration of adverse impacts of investment decisions on sustainability factors

DTC does not consider adverse impacts of its investment advice on sustainability factors 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.

DTC believes in the societal and business benefits of a responsible Environmental, Social and Governance (ESG) policy. Through its investment advisory processes, DTC seeks to identify, grow and improve the Funds’ portfolio companies it advises, ensuring a long-term sustainable value creation. DTC recognizes that ESG principles can contribute to creating value for investors and all other stakeholders – both in terms of mitigating risks and seizing opportunities. However, for the time being the funds advised by DTC – and therefore DTC itself – do not consider the adverse impacts of investment decisions on ESG factors within the meaning of Art. 4 SFDR. This decision is mainly based on the absence of sufficient data for the performance of an adequate assessment of the potential adverse impact of the investment advise on Sustainability Factors as well as due to lack of relevant disclosures from target investments that are – as of now – in general not legally obliged to report on sustainability data. The data situation may change once the Corporate Sustainability Reporting Directive is fully implemented and in force and there are additional guidelines from the authorities for (voluntary) sustainability reporting also for small and medium enterprises. DTC will re-evaluate the conditions in the end of 2024. As soon as DTC starts considering adverse sustainability impacts of its investment advice, DTC will disclose the relevant information to investors and on this website.

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III. Remuneration disclosure

As a securities institution within the meaning of Section 2 (16) of the German Securities Institutions Act ("WpIG"), DTC is not required to introduce a remuneration policy or guideline in accordance with the requirements of the WpIG. However, DTC has established a remuneration policy on a voluntary basis and considers ESG aspects in such policy. More precisely, some of DTC’s staff may be eligible for a variable remuneration which is granted on a discretionary basis. The determination of variable remuneration is not based solely on quantitative criteria (such as the value of instruments sold, sales volumes, establishment of targets for sales or new clients) but also on qualitative criteria. One of the qualitative criteria can be the consideration of ESG related aspects. Further, and where applicable, DTC will ensure that the implementation of bonus systems in general does not lead to an excessive assumption of risks which also includes sustainability risks.

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IV. Product Specific Information within the meaning of Art. 10 SFDR

Where can I find more product specific information online regarding Digital Infrastructure Vehicle II SCSp SICAV-RAIF (DIV II), DIV II Matrix Co-Invest 2nd SCSp and DTCP Growth Equity III SCSp SICAV-RAIF (GE III)?

-  More product-specific information can be found on the website: www.fundrock-lis.com/esg/ -