1. Presentation of the strategic handling of sustainability risks (Art. 3 SFDR)

    CCI will not only include relevant financial risks in investment decisions as part of its investment processes, it will also consider material sustainability risks.

    For example, when granting loans, CCI attaches importance to project developers or property developers meeting the current requirements of the Building Energy Act (GEG) in their construction projects and preferably achieving high certification levels (DGNB, LEED, BREEAM, etc.). In addition, CCI is guided by the guidelines of the EU Action Plan on Sustainable Finance and, in particular, the requirements of the Taxonomy Regulation. This enables CCI, although it is not directly involved in the construction process as a financier, to work within its own investment decision-making processes to ensure that the financed projects meet the current standards of sustainable and energy-saving real estate. Furthermore, CCI favours refurbishments and renovations instead of demolition/new construction projects, provided that an existing building structure permits this. This is intended to stimulate the closed-loop economy, i.e. the reuse of certain resources, and to increase the useful life of real estate. In addition, CCI makes sure that debtors use sustainable building materials (e.g. with FCS seal) in order to also promote environmental protection in active new construction.

  2. Presentation of the strategic handling of sustainability risks in relation to remuneration components (Art. 5 SFDR)

    All managing directors and employees of CCI are currently provided to the company by its parent company, Competo Capital Partners GmbH, on the basis of an intra-group service and provision agreement. It is transparently regulated that CCI does not act as an employer and that the managing directors and employees placed with it therefore do not receive any remuneration from it, but continue to be remunerated exclusively by Competo Capital Partners GmbH. Against this background, CCI does not currently pay any remuneration to directors or employees and has refrained from establishing its own remuneration policy, which would currently have no scope of application anyway. However, should CCI employ directors or employees as an employer in the future and remunerate them itself, it will draw up a remuneration policy in which sustainability risks in the areas of environment, social affairs and corporate governance are taken into account in an appropriate manner.

  3. Presentation of adverse sustainability impacts (Art. 4 SFDR)

    At the current time, CCI does not yet take into account at the company level the principal adverse impacts of investment decisions on sustainability factors, i.e. adverse impacts in particular on environmental, social and labour concerns, respect for human rights and the fight against corruption and bribery (so-called „Principal Adverse Impacts“). Due to the considerable legal uncertainties in this respect at the current time with regard to the concrete requirements for measuring and reporting these adverse effects, CCI has decided to wait for further legal developments and to implement corresponding processes at a later date.


* The following information serves to implement the transparency requirements of the so-called Disclosure Regulation (Regulation (EU) 2019/2088 on sustainability-related disclosure requirements in the financial services sector or "Sustainable Finance Disclosure Regulation"/"SFDR").
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