The organisational structure of Paribus Kapitalverwaltungsgesellschaft mbH enables it to perform the functions and duties assigned to it pursuant to the German Investment Code (KAGB) – such as portfolio management, risk management, conflicts of interest management, liquidity management and valuations – entirely on its own. In certain areas, however, we do cooperate with companies with special expertise in order to make use of their services.

In this context, Paribus Kapitalverwaltungsgesellschaft has made sure that services are outsourced to external service providers in accordance with the provisions of Section 36 KAGB, and will continue to ensure that this is the case if additional services are outsourced.

Paribus Kapitalverwaltungsgesellschaft has outsourced investor support to the trust company Paribus Trust GmbH.

Paribus Kapitalverwaltungsgesellschaft mbH is subject to reporting obligations under the German Investment Code (KAGB) and the German Banking Act (KWG).

Dedicated reporting and supervision meet the requirements of supervisory regulations and separate reports that are to be submitted to the German Federal Financial Supervisory Authority (BaFin) from reports addressed to investors. In particular, the latter involve the preparation of annual reports and the calculation and preparation of net asset values.

• The annual reports of the closed-end alternative investment funds are published as downloadable documents in the fund portfolio by 30 June of each year.

• The net asset values of the closed-end alternative investment funds are published as downloadable documents in the fund portfolio The key date for valuations is normally 31 December of each year.

The reports we are obliged to submit to BaFin include, for example, notification of any changes to the articles of association or partnership agreement of Paribus Kapitalverwaltungsgesellschaft, notification of a change of anti-money-laundering officer or notification of any outsourcing.

Paribus Kapitalverwaltungsgesellschaft has outsourced complaint management to the trust company Paribus Trust GmbH.

To this end, Paribus Kapitalverwaltungsgesellschaft mbH has rolled out a procedure to process complaints appropriately and immediately and integrated it into its corporate processes. This complaint management system meets the legal requirements.

One way in which we constantly improve the processes is to use the reports that are filed with us to optimise our processes and procedures continuously.

If you have a complaint, please use one of the following channels to communicate with Paribus Trust GmbH:

• Clients can file complaints with Paribus Trust GmbH by post, phone or email.

No matter the complaint, customer satisfaction is the priority for Paribus Trust GmbH.

It goes without saying that we hope you will have no reason to complain. However, if you do have a complaint, please provide us with your contact details, your investor number (if you have it), the AIF in question and the reason for your complaint. You are also welcome to use the contact form.

Whenever we receive a complaint, we send confirmation of receipt to the person who lodged it and start processing the complaint with a view to resolving it. Firstly, we will send you confirmation that we have received your complaint. We will normally process your complaints within two or three working days. If we are unable to process your complaint within this period of time, we will notify you of the next steps we are going to take immediately.

The person in charge of incoming complaints:

Stephanie Brumberg (Complaints Manager):

• or
• Phone: +49 40 8888 00 6-0

We have transferred the performance of bookkeeping and accounting services to Mazars GmbH & Co. KG Wirtschaftsprüfungsgesellschaft Steuerberatungsgesellschaft in the form of an outsourcing contract. This includes the traditional responsibilities of financial accounting as well as the preparation of annual financial statements.

Paribus Kapitalverwaltungsgesellschaft mbH has transferred compliance to Mazars Rechtsanwaltsgesellschaft mbH in the form of an outsourcing contract. On behalf of Paribus Kapitalverwaltungsgesellschaft, Mazars Rechtsanwaltsgesellschaft makes sure that the complex legal landscape is constantly checked and adhered to. It is subject both to statutory regulations and regulations imposed by the company itself.

Paribus Kapitalverwaltungsgesellschaft mbH is in charge of creating closed-end AIF (public and special AIF) for the Paribus Group. We develop the investment idea and build a legal structure for the investment project. This also entails deciding on the investment criteria and investment policy. Investment calculations, the preparation of sensitivity analyses, compliance with all legal and tax requirements to which the AIF is subject and the description of risks and opportunities are all key elements. The structure of the AIF is published in the prospectus (only for a public AIF) and in the key investor information.

The investment policy and prospectus are submitted to BaFin for approval as a prerequisite for the public AIF to be admitted to the market.

The AIF usually enters into an agency agreement with Paribus Invest GmbH in order to raise investment capital. Paribus Invest presents the AIF set up by Paribus Kapitalverwaltungsgesellschaft to financial intermediaries for addition into their portfolios.

Money laundering is a criminal offence in Germany and other countries. Identification of the investor in accordance with the German Money Laundering Act (GWG) prevents money laundering.

Paribus Kapitalverwaltungsgesellschaft has outsourced compliance with the procedures of the German Money Laundering Act (GWG) to the trust company Paribus Trust GmbH.

We have transferred the duties of internal auditing to Mazars GmbH & Co. KG Wirtschaftsprüfungsgesellschaft Steuerberatungsgesellschaft in the form of an outsourcing contract.

Mazars conducts audits in line with an audit schedule.

Paribus Kapitalverwaltungsgesellschaft mbH sets up and manages closed-end alternative investment funds for private, semi-professional and professional investors. We work with numerous external contractual partners and affiliated companies through the sequence of processes of the entire value chain of an AIF. Conflicts of interest can arise within and between departments, other Paribus Group companies, external business partners, Managing Directors and employees of Paribus Kapitalverwaltungsgesellschaft and the managed AIF and its investors.

How we resolve conflicts of interest

Conflicts of interest are resolved in such a way that

• the AIF managed by Paribus Kapitalverwaltungsgesellschaft and its investors are treated fairly,
• the risk of loss to its investors is minimised, and
• no unrelated interests influence the decisions made by our employees.

For this reason, we have implemented organisational measures to enshrine these guidelines as minimum standards.

We handle any and all conflicts of interest that arise in line with the highest standards of integrity and loyalty. We work continuously to identify and resolve conflicts of interest proactively and at an early stage in order to avoid all types of apparent and actual misconduct and ensure that these standards are adhered to.

How we avoid conflicts of interest

We have implemented organisational measures to prevent, avoid or resolve potential or actual conflicts of interest. In particular, these include:

• a clear internal separation of duties on both the management and employee levels,
• constant monitoring of all the business activities of Paribus Kapitalverwaltungsgesellschaft by risk management and the (external) compliance department, and
• ongoing checks by the internal auditors.

How we document conflicts of interest

Once identified, a conflict of interest is documented and monitored continuously by the conflicts of interest management team, regardless of whether it actually exists or might possibly arise.

How we deal with unavoidable conflicts of interest

Unavoidable conflicts of interest are disclosed to investors in the sales documents.

Paribus Kapitalverwaltungsgesellschaft mbH concentrates all activities relating to the management of an AIF and each investment into portfolio management. In particular, this relates to implementation of the investment criteria when investments are selected and executed and maximising their profitability in order to accomplish the goal of the investment. However, it also includes financing with equity and/or debt, optimising the management of the asset during the life of the AIF and liquidity management. All portfolio management measures are coordinated with the custodian.

It is important to note that responsibilities within Paribus Kapitalverwaltungsgesellschaft are structured in such a way that portfolio management is kept strictly separate from risk management – even up to the management level.

On the basis of KaMaRisk (minimum risk management requirements for capital investment companies) and Commission Delegated Regulation (EU) No 231/2013, Paribus Kapitalverwaltungsgesellschaft mbH has implemented a risk management system which contains the following processes:

• Definition of a risk strategy and/or a risk profile
• Risk identification
• Risk categorisation
• Risk assessment and limitation
• Risk control
• Risk monitoring
• Risk reporting

This way, we identify, measure, assess and control the risks of the AIF – both the actual and potential risks. In every management phase of the AIF, this gives us a complete overview of the risk factors and enables us to make situational decisions at all times. Taking sustainability risks into consideration is another part of this.

The remuneration system of Paribus Kapitalverwaltungsgesellschaft mbH is governed by Section 37(1) of the German Investment Code (KAGB).