SFDR Disclosure for Puzzle Ventures

Effective Date: April 25, 2024

Introduction

Puzzle Ventures ("we", "us", or "our") is committed to integrating sustainability risks into our investment decision-making and advisory processes. This disclosure aligns with the EU’s Sustainable Finance Disclosure Regulation (SFDR), aimed at enhancing transparency regarding the integration of sustainability risks and the consideration of adverse sustainability impacts in the financial markets.

Policy on the Integration of Sustainability Risks

We acknowledge sustainability risks as integral to our investment analysis and decision-making processes. Sustainability risk is defined as an environmental, social, or governance (ESG) event or condition that could potentially cause a material negative impact on the value of an investment.

Approach

• Assessment: We evaluate potential investments for environmental, social, and governance risks that could impact financial performance.
• Mitigation: We implement strategies to mitigate identified risks, which include active engagement with stakeholders and enhancement of ESG practices.
• Monitoring: Our investments are regularly monitored concerning sustainability risks, adjusting our strategies as necessary to align with our sustainability objectives.

No Consideration of Sustainability Adverse Impacts

As of now, Puzzle Ventures does not consider the adverse impacts of investment decisions on sustainability factors as outlined in Article 4 of the SFDR. This decision is based on our assessment of the available data and methodologies, which do not yet allow for comprehensive and consistent analysis. We will review this policy annually and adapt it according to evolving regulatory requirements and market practices.

Remuneration Policies in Relation to the Integration of Sustainability Risks

Our remuneration policy is designed to foster responsible behavior among our staff, integrating sustainability risk considerations into both performance evaluation and remuneration, thereby aligning with the long-term goals of our investors, which include sustainability considerations.

• Performance Metrics: Sustainability risk assessments are incorporated into the performance metrics for our staff.
• Alignment: Remuneration is aligned with the sustainable investment objectives and risk profiles of the products we manage.

Transparency of Sustainable Investment Objective

(If applicable, details about financial products with a sustainable investment objective are provided below.)

Investment Strategy

• Description: [Describe the sustainable investment strategy, including specific sustainability indicators used.]
• Objective: [Specify the sustainability objective the product aims to achieve.]
• Alignment: [Explain how the strategy aligns with the criteria set forth by the SFDR.]

Additional Disclosures

(Include any other SFDR-related disclosures, such as greenhouse gas emissions, biodiversity impacts, or employee gender diversity ratios, as applicable.)

Changes to Our SFDR Disclosures

We may update our SFDR disclosures periodically to reflect changes in our policies, practices, and the regulatory landscape.

‍