No consideration of adverse impacts of investment decisions on sustainability factors

Statement pursuant to Article 12 of Commission Delegated Regulation (EU) 2022/1288,

including information pursuant to Article 4 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector

Dear Investors and Clients,

Serdika Capital AD is a socially conscious manager and, in its capacity as a financial market participant, makes efforts to achieve long-term sustainable returns on the investments of its clients and investors in alternative investment funds (AIFs).

Notwithstanding the above, having regard to its size, the nature and the scale of its activities in relation to the management of AIFs and individual client portfolios, the AIFM does not consider the principal actual or potential adverse impacts of its investment decisions on sustainability factors, within the meaning of Article 4 of Regulation (EU) 2019/2088, and does not apply specific procedures for the identification and assessment of principal adverse impacts.

For the past year 2024 and as at the date of this statement, Serdika Capital AD does not consider adverse impacts of its investment decisions on sustainability factors, within the meaning of Regulation (EU) 2019/2088, for the following reasons:

  • the absence of regulated and publicly available methods for companies to disclose the presence or absence of ESG data, which could enable the formation of objective and reliable information on sustainability factors;

  • the lack of a universally applicable digital reporting format through which large companies present data on key performance indicators related to environmentally sustainable economic activities, allowing comparability of data and the avoidance of misleading information or other forms of misinformation;

  • the scale of the AIFM’s activities – including the size, nature and scope of its business and the types of financial services provided – does not justify the consideration of adverse sustainability impacts of investment decisions;

  • the costs required for the AIFM to consider adverse impacts of investment decisions, within the meaning of Article 4 of Regulation (EU) 2019/2088, would not be proportionate or economically justified in relation to the expected revenues, should such impacts be taken into account;

  • a potential investment target may restrict the exposure of AIFs and discretionary portfolio management mandates to certain companies, industries or sectors, and the AIFM may refrain from investment opportunities for managed AIFs and portfolios that do not meet its sustainability criteria. Consequently, an AIF or portfolio managed by the AIFM may achieve lower performance compared to other funds that do not seek to invest on the basis of such criteria;

  • the AIFM provides its discretionary portfolio management clients with the opportunity to define specific ESG-related investment requirements prior to the conclusion of a portfolio management agreement. In this manner, Serdika Capital AD acts with due care and diligence towards its clients, while also assessing their sustainability preferences.

Given the specific nature of the target investments set out in the investment strategies of the managed AIFs, and considering that the framework for the assessment of environmentally sustainable economic activities is expected to gain increasing social and economic relevance, Serdika Capital AD does not exclude the possibility that, in the event of a sustained change in at least some of the reasons outlined above, it may begin to consider the principal adverse impacts of its investment decisions on sustainability factors, within the meaning of Article 4(1)(a) of Regulation (EU) 2019/2088.

It should be noted that, even at present, Serdika Capital AD conducts an in-depth assessment, to the extent permitted by the resources of the AIFM and available sources of information, of the degree of environmental sustainability of its investments.

Yours sincerely,
The Management of Serdika Capital AD

Scope and period covered

The information disclosed above covers the period 1 January 2024 – 31 December 2024 and was declared on 27 May 2025.

The information provided on this web site should not be considered by investors as an offer, advice or recommendation for purchase or sale of shares in the alternative investment funds or any other financial or non-financial assets. The shares of AIFs are intended for professional investors as defined by MIFID. The value of the funds’ shares and the income therefrom may decline, the profit is not guaranteed and investors may not recover the full amount invested. Investments in alternative investment funds are not guaranteed by a guarantee fund, established by the State or any other warranty. The past performance of the funds is not necessarily indicative of future results.