Disclosure Obligation

Description of the Methods of Fulfilling Obligations Under Sections 239 and 241 of Act No. 240/2013 Coll., on Investment Companies and Investment Funds

The manager of a special fund is required to fulfill disclosure obligations with respect to investors in accordance with Sections 239 and 241 of the ZISIF.

1/ Pursuant to Section 239 of the ZISIF, information shall be provided to investors as follows:

a)     the current value of a unit, investment share, or other interest in an investment fund; and, whenever securities or book-entry securities issued by the fund are issued or redeemed, information regarding the amount at which such securities or book-entry securities are issued or redeemed

Published on the fund‘s website

b)     for each calendar month, information on the number of securities or book-entry securities issued and redeemed, and

Published on the fund‘s website

c)     for each calendar month, information on the composition of the fund’s assets as of the last day of the month.

Published on the fund‘s website

2/ Pursuant to Section 241 of the ZISIF, information shall be provided to investors as follows:

a)     the investment strategy of this fund, in particular

·       the main types of assets that may be acquired for the fund’s portfolio,
·       the investment limits that must be observed with respect to the assets referred to in point 1,
·       details regarding the fund’s management techniques and the conditions for their use,

Specified in the fund’s articles of association

b)     details regarding the conditions for the use of leverage, including details on the types of transactions that may be entered into using leverage, the counterparties to such transactions, the risks associated with the use of leverage, and any limits on the degree of leverage used,

Specified in the fund’s articles of association

c)     information on agreements providing for the provision of an investment instrument from the fund’s assets as financial collateral or comparable security under the law of a foreign country,

Specified in the fund’s articles of association

d)     information regarding the home country of its master fund, if it is a sub-fund, and information regarding the home countries of the investment funds or foreign investment funds in whose securities or book-entry securities it invests, if it invests more than 49% of the value of its assets in securities or book-entry securities issued by an investment fund or a foreign investment fund,

Not applicable (only in the case of master-feeder structures)

e)     information on the conditions under which a change in this fund’s investment strategy may occur and the manner in which such a change is implemented,

Specified in the fund’s articles of association

f)      information on the main legal consequences relating to the investor’s contractual obligation in connection with their investment in the fund, in particular information on

·       the jurisdiction for resolving disputes arising from the contract,
·       the governing law for the contractual relationship, and
·       the existence or absence of directly applicable European Union regulations or international treaties governing the recognition and enforcement of court decisions in the country where the fund is domiciled, in the case of a foreign special-purpose fund,

The contract under which the investor acquires securities issued by the fund

g)     information necessary to identify the fund manager, administrator, custodian, principal sponsor, and auditor, as well as a description of the activities of these entities in relation to the fund and the investor’s fundamental rights,

Specified in the fund’s articles of association

h)     information on how the requirements under Section 32 are met

“The capital of an investment company authorized to exceed the relevant limit and the capital of a foreign entity licensed under Section 481 that is not comparable to a self-managed investment fund, as referred to in Sections 30 and 31, may be invested only in liquid assets in the legal sense (hereinafter referred to as “assets”), which can be converted into cash within a short period of time, provided that such assets do not contain a speculative element.”

Not applicable (compliance with this obligation is ensured by the fund manager)

i)      information regarding which activities—comprising the management or administration of an investment fund or a foreign investment fund—were delegated to another party, and a description of which depositary activities were delegated to another party pursuant to Section 78, including information necessary to identify the delegated party and information regarding any conflicts of interest arising from the performance of the delegated activities,

Specified in the fund’s articles of association

j)      information on the procedures for valuing the fund’s assets and liabilities and the method of such valuation, including the method for valuing assets that are difficult to value,

Specified in the fund’s articles of association

k)     information on the management of the fund’s illiquidity risk, including a description of the redemption of securities and book-entry securities issued by the fund under normal and extraordinary circumstances and in cases where redemption requests have already been submitted,

Specified in the fund’s articles of association

l)      information on all discounts, premiums, fees, and expenses of the fund that are borne directly or indirectly by the investor, and information on their maximum amounts,

Specified in the fund’s articles of association

m)   information on whether, in the event that any investor obtains a special benefit or a right to a special benefit, other investors also have such a benefit or right, a description of such special benefit or right to a special benefit and a list of the investors who will receive such benefit or right, including a description of the legal and economic ties of such investors to the fund or to the fund manager and administrator,

Not applicable (investors do not receive any special advantage)

n)     the fund’s most recent annual report that meets the requirements of Article 22 of the Directive of the European Parliament and of the Council on Alternative Investment Fund Managers,

Published on the fund‘s website

o)     the procedures and conditions for the issuance and redemption of securities or book-entry securities issued by this fund,

Specified in the fund’s articles of association

p)     information on the current value of this fund’s capital, or, where applicable, the current market price or current value of the securities or book-entry securities issued by this fund,

Published on the fund‘s website

q)     information on the fund’s historical performance, if such information is available,

Specified in the fund’s articles of association

r)      a description of the core services provided by the primary service provider for this fund, a description of how any conflicts of interest arising from the services provided by the primary service provider will be addressed, and information regarding any transfer of the primary service provider’s liability to compensate for damages—which would otherwise be borne by the primary service provider—to another party,

Not applicable (only if a principal sponsor exists)

s)     details of provisions in the depositary agreement that permit the transfer or further use of the fund’s assets by the depositary,

Specified in the fund’s articles of association

t)      information on how and when the information specified in paragraphs 3 and 4 is made available, i.e.,

-   the proportion of the fund’s total assets that is subject to special measures due to its low liquidity; this figure shall be expressed as a percentage,

-    new measures adopted to manage the risk of insufficient liquidity of the fund, and

-    the fund’s risk profile and the risk management system implemented by the fund manager.

If the fund invests using leverage:

-   changes in the degree of leverage used, guarantees provided in connection with the use of leverage, as well as any changes regarding the authorization to continue using the financial collateral or comparable security provided under the law of a foreign country, and

-   the level of leverage used by the fund.

Published on the fund‘s website

u)     information on whether the depositary has agreed with the authorized party under Section 82(1)(b) on compensation by the authorized party for the loss of investment instruments, as well as information on any changes to and the nature of such changes in this agreement.

Specified in the fund’s articles of association

v)     information regarding sustainability risks pursuant to Article 6(1) of Regulation (EU) 2019/2088 of the European Parliament and of the Council21) and information pursuant to Articles 5 through 7 of Regulation (EU) 2020/852 of the European Parliament and of the Council22).

Published on the fund‘s website

The fund manager shall provide all of the above information in an impartial and clear manner and in such a way that the information is not misleading. This information shall be updated regularly and reviewed periodically as necessary.