SFDR Information

Information Requirements SFDR

Effective Date: 12 August 2025

In implementation of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial sector (the “Sustainable Finance Disclosure Regulation”, hereinafter abbreviated to “SFDR”), we answer the following questions on our website:

Do we take sustainability risks into account in our investment process?
Do we consider the main adverse impacts of investment decisions on sustainability factors?
Do we take sustainability risks into account in our remuneration policy?
 

Integrating sustainability risks into the investment process

For the purposes of the SFDR, ‘sustainability risk’ means an environmental, social or governance event or circumstance that, if it occurs, could cause an actual or potential material adverse impact on the value of the investments.

In principle, Limestone Fund invests in investments that avoid or limit sustainability risks as much as possible. The other most important selection criteria in the due diligence phase are the investment philosophy and strategy of the fund manager, the track record of the fund manager, the quality of the investment team and other risks specific to infrastructure projects.

Calx Capital Management (hereinafter ‘Calx’) considers adverse impacts of investment decisions on sustainability factors.

Policy

Calx considers the most significant possible adverse effects of the selected investments on “sustainability factors” (as referred to in Article 4(1)(a) SFDR) to be:

Ecological

greenhouse gas emissions (CO2, NOX and particulate matter);
reduction of biodiversity;
reduction of water quality and/or quantity;
pollution;
use fossil fuels;
inefficient use of energy.
 

Social and employment affairs

violation of human rights;
discrimination.

Corruption and bribery

Calx’s due diligence process examines whether these securities may be present in the potentialinvestments. If that is the case, then this is considered a sustainability risk and Calx willassess whether adequate control measures have been taken. Calx does not invest in investments if it considers the control measures to be insufficient.

For Calx, sustainability is not an end in itself: no specific sustainability goals are pursued. It is sufficient to determine whether an overweight investment has a negative impact on sustainability factors and, if so, whether the associated sustainability risk is acceptable.

Calx does not promote any environmental and/or social characteristics with its funds (the Calx funds are not “light green investments” within the meaning of Article 8 SFDR) nor is it focused on sustainable investments (the Calx funds are also not “dark green investments” within the meaning of Article 9 SFDR).

Remuneration policy and sustainability risks

Calx’s remuneration policy does not contain any incentives that could lead to sustainability risks being neglected when making investment decisions and when monitoring investments.

Additional information under Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment (Taxonomy Regulation):

The underlying investments of this financial product do not take into account the EU criteria for environmentally sustainable economic activities.