No consideration of sustainability adverse impacts

This statement addresses requirements as set out in SFDR specifically relating to the consideration of principal adverse impacts of investment decisions on sustainability factors. Under the SFDR, principal adverse impacts shall be understood as those impacts of investment decisions and advice that result in negative effects on sustainability factors.

SysCat Capital does not consider the adverse effects of investment decisions on sustainability factors and therefore does not prepare a so-called principal adverse sustainability impact statement (PAI statement) annually. SysCat Capital does not promote ecological or social characteristics and does not have sustainable investments as its objective. Due to the very short-term nature of the investment strategy of SysCat Capital, the investment decisions are not expected to materially influence environmental, social, or governance outcomes. Therefore, SysCat Capital does not actively seek to reduce adverse impacts on sustainability factors.

In addition, taking into account adverse effects of investment decisions on sustainability factors would bring that SysCat Capital must obtain necessary information to be able to report on those factors. SysCat Capital believes that there is currently insufficient reliable data available to determine the potential negative effects of its investments in relation to sustainability. If data is available, the data is generally not available on a daily basis, meaning that any available information tends to be static or slow-moving relative to SysCat Capital's trading frequency.

SysCat Capital believes that, also considering the nature, scale and the phase in which it finds itself (managing one fund without promoting sustainable factors), the costs of including sustainable adverse impacts in the investment process do not outweigh the expected benefits. At this stage, SysCat Capital does not consider principal adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR regulation.

The foregoing does not prevent SysCat Capital from reconsidering the decision to not consider adverse effects of investment decisions on sustainability factors if relevant circumstances arise. For example, if the majority of investors value the consideration of adverse effects of investment decisions on sustainability factors (and thus a PAI statement). However, this is not anticipated at the time of publication of this information.

Dated 2025-08-26