Important Policies and Disclosures

General

This website, any Limmat Capital group social media profile or webpage that contains a link to this website, and any third-party content that is linked to or included on the foregoing (“Linked Content”) are collectively referred to as the “Content.”

The Content is provided for your information only and does not constitute investment advice or convey an offer or solicitation of any type with respect to any securities or other financial products. No assurances can be given that any aims, assumptions, expectations, and/or goals expressed or implied in the Content were or will be realized, or that the strategies and other activities described in the Content have continued or will continue at all or in the same manner as is described. Past performance should not be considered indicative of future performance.

Limmat Capital, its affiliates and members, and any party or person associated with or acting on behalf of the foregoing shall have no liability for any errors (as a result of negligence or otherwise, to the fullest extent permitted by law in the absence of fraud) in the Content or its production or for the consequences of any party’s reliance on the Content.

Limmat Capital does not endorse any information or beliefs discussed in any Linked Content and makes no representation as to the accuracy or adequacy of any Linked Content. All trademarks, logos, information, and photos are owned by Limmat Capital or its affiliates or used with permission. The reproduction or retransmission of the Content (other than Linked Content) is prohibited without the prior written consent of Limmat Capital.

Limmat Capital Alternative Investments, which is authorized and regulated by the Swiss financial market regulator FINMA may retain copies of communications to or from our business and otherwise gather personal information that you may share in the course of our dealings with you. This information will be used for the purposes of providing services, keeping records, processing applications for employment, processing subscriptions and redemption, and regulatory compliance and, accordingly, may be transferred outside of Switzerland.

Data Protection

One or more of the following privacy notices may be applicable to you depending on how Limmat Capital collects personal information as governed by the E.U. General Data Protection Regulation (“GDPR”) and other applicable regulations.

• The Privacy Notice is available here.
• The Non-EEA Personal Data Privacy Notice is available here.
• The Swiss Data Protection Notice is available here.

Governance

Limmat Capital’s corporate governance structure includes the Limmat Capital Board, the Business Management Committee and Limmat Capital’s other decision-making committees. The committees are responsible for supervising the management of the relevant business area to ensure that we conduct business appropriately, with integrity, and with due regard for the interests of all stakeholders.

In line with best practices, Limmat Capital implemented “three lines of defense” model.

• Each unit is responsible for ensuring that a risk and control environment is established as part of day-to-day operations.
• The independent compliance and risk function oversees the risk management activities of each unit
• The third line of defense is conducted by the Business Management Committee, assisted by external compliance monitor and auditors who report independently to the Committee and the Board of Directors of the company and provide independent assurance over the first and second lines of defense.

Regulation

Effective regulation has a vital role to play in fostering innovations that are positive for society. We at Limmat Capital support good rule-making and have maintained open and constructive dialogue with authorities in Switzerland and abroad.

Limmat Capital is regulated in Switzerland and the funds we manage are regulated by the respective regulatory bodies in Luxembourg, Switzerland, and the Cayman Islands. Of course, we abide by the rules and regulations in the many jurisdictions we invest in.

Business Continuity and Disaster Recovery

Limmat Capital developed a Business Continuity Plan outlining how we will respond to events that significantly disrupt our business. If, after a significant business disruption, you cannot contact us through normal channels, you should contact our Disaster Recovery Officer, at rr@limmatcapital.ch or limmat.dro@gmail.com.

Read our notice here.

Corporate Social Responsibility

We at Limmat Capital take our fiduciary obligations seriously. We strive to operate our business in a responsible and ethical manner. Our decisions are determined by our guiding principles and take into account not only financial, management, and growth prospects data points but also issues related employees, human rights, the environment, bribery, consumers and corporate governance.

It is our strong belief that investors will reward companies who conduct their business responsibly. In turn, investors will be rewarded by knowing they have made a positive impact on the world. We are committed to doing our part in making the world a better place for all. We weigh the impacts of our decisions on in terms of environmental, social, and governance (ESG) aspects at both corporate and fund strategy levels.

Environmental Responsibility

Limmat Capital is mindful of its environmental impact and seeks to adhere to the relevant environmental standards in the countries in which it operates, wherever possible.

The SFDR Sustainability Risk Policy is available here.

Principal Adverse Impact Statement

EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (“SFDR” or the “Regulation”) entered into force on 10 March 2021. The Regulation requires firms that manage investment funds to provide information to investors with regards to the integration of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social characteristics, and sustainable investment with respect to the investment funds they manage.

This document specifically addresses Article 4 of the Regulation:

Financial market participants shall publish and maintain on their websites:

((a) where they consider principal adverse impacts of investment decisions on sustainability factors, a statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available; or

(b) where they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons for why they do not do so, including, where relevant, information as to whether and when they intend to consider such adverse impacts.

Limmat Capital Alternative Investments AG (“Limmat Capital”) applies the definition of Principal Adverse Impacts (“PAI”) contemplated by Recital 20 of the Regulation:

Principal adverse impacts should be understood as those impacts of investment decisions and advice that result in negative effects on sustainability factors.

Information regarding the consideration of Principal Adverse Impacts

Limmat Capital does not consider the adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the Regulation.

Article 4(1)(b) of the Regulation requires financial market participants to provide clear reasons why they do not consider the adverse impacts of investment decisions on sustainability factors. Although Limmat Capital is committed to incorporating ESG factors into its investment decisions, it believes that considering the current investment objective, strategy and guidelines of Limmat Capital SICAV – LC Equity Fund (the “Fund”) and how Limmat Capital in its capacity as investment manager of the Fund considers it best to undertake the investment processes, it would be challenging to comply with the PAI regime of the SFDR.