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Sustainability Risk Integration Policy (SDFR)


1.1 This Sustainability Risk Integration Policy (the "Policy") sets out the principles that the Company
applies in integrating sustainability risks into the investment process.

1.2 This Policy is made available to prospective investors in the Company (the "Alternative Fund") on the website

1.3 "Sustainability factors" means environmental, social, and employment issues, compliance with
human rights and anti-corruption and anti-bribery matters.

1.4 "SFDR Regulation" means Regulation (EU) 2019/2088 of the European Parliament and of the Council of
27 November 2019, on sustainability disclosure in the financial services sector, as amended by
as amended.

1.5 "Sustainability Risk" means an environmental or social event or situation
or governance situation that, if it were to occur, could have an actual or potential
significant adverse impact on the value of the investment.

1.6 "Sustainable investment", means an investment as defined in Article 2(17) of the SFDR Regulation, i.e. an investment
in an economic activity that contributes to environmental objectives, such as investments measured for example
key resource efficiency indicators on energy use, renewable energy, raw materials,
water and land, waste production, greenhouse gas emissions, or indicators of its impact on biological
diversity and the circular economy, or investments in economic activity that contributes to social
objectives, in particular investment that contributes to tackling inequalities, or investment that promotes social cohesion,
social integration and labor relations, or investments in human capital or economically or socially
disadvantaged communities provided that such investments do not significantly undermine any of those objectives
and the investee companies comply with good governance practices, in particular with regard to sound
governance structures, employee relations, remuneration of relevant employees, and tax compliance

2.1 The Company's attitude to the extent to which sustainability risks are taken into account in investment
decisions depend on the nature of the investment in question and the investment strategy.

2.2 The Company does not consider the adverse sustainability implications of its investment decisions because our investment strategy is based on frequent algorithmic trading. We hold positions within a few hours, on most days. The negative impact on sustainability is therefore utterly irrelevant given the nature of the investment strategy. 



Update 23.2.2023

Approved by Renata Tmejová - Member of the Management Board

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