Ludus GP S.à r.l.

In accordance with the provisions of the 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 („SFDR“), the following publications are hereby made:
SFDR-Disclosure of the integration of sustainability risks in the investment decision-making process (Art. 3 SFDR), and
SFDR-Statement on the consideration of principle adverse impacts on investment decisions (Art. 4(1)b) SFDR)

Ludus GP S.à r.l.
Ludus GP S.à r.l., is a Luxembourg private limited liability company, with registered seat at 6, rue Dicks, 1417 Luxembourg, Grand Duchy of Luxembourg and registered with the Luxembourg Trade and Companies‘ Register (Registre de Commerce et des Sociétés, ”RCS”) under number B 256265 (“Ludus GP”).
Ludus GP requested the Luxembourg supervisory authority of the financial sector (Commission de Surveillance du Secteur Financier, „CSSF“) to be registered as an alternative investment fund manager pursuant to article 3(3) of the Luxembourg law of 12 July 2013 on alternative investment fund manager, as amended, and was registered as such.
Ludus GP acts as registered AIFM exclusively for the Luxembourg based alternative investment fund Ludus SCS, a Luxembourg common limited partnership (société en commandite simple), with registered office at 6, rue Dicks, 1417 Luxembourg, Grand Duchy of Luxembourg, registered with the RCS under number B2556456 (“Fund”), performs the investment and risk management for the Fund and is therefore solely and finally responsible for the investment and risk management.
SFDR – sustainability risks
Under the SFDR Ludus GP qualifies as a financial market participant, and is therefore, based on article 3 SFDR, required to disclose information about its policies on the integration of sustainability risks in its investment decision-making process.
Sustainability risks are defined in article 2 (22) of the SFDR as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
Ludus GP acknowledge that the sustainability risks (i.e. the three named categories environmental, social and governance, “ESG-Risks”) may have an impact (positive or negative) on the value of the investments made by Ludus GP, and thus on the investments of its customers.
The three categories of ESG-Risks can be described as follows:
“Environmental risks” are the risks of any negative financial impact stemming from financial risks posed by Ludus GP and may take the form of physical, transition or liability risks. The environmental risks are mainly related to climate or environmental events resulting from climate change (the “physical risks”) and the uncertainty on society’s response to climate or environmental change (the “transition risks”) while the liability risks are the risks of potential losses due to litigation against Ludus GP because of negative environmental impact (the “liability risk”).
“Social risks” are the risk of any negative financial impact stemming from the current or prospective impacts of social factors, such as human rights, labour law policies, fair working conditions, wellbeing, health, safety, inclusion, interests of people and communities, and which are by nature difficult to quantify.
“Governance risks” are the risk of any negative financial impact stemming from governance, matters (including the governance of ESG factors), such as deficient ethical standards, lack of anti-money and terrorism financing procedures, poor leadership and poor internal controls.
Integration of sustainability risks
Even if Ludus GP does no take active investment decisions for the Fund based on sustainability risks as part of its investment decision-making process, Ludus GP does not invest in certain sectors or companies whose products, services or activities are obviously considered contrary to the current trends regarding the promotion of sustainability criteria. Therefore, some sectors/Industries/companies are completely excluded from investment on environmental, social or governance grounds.
No consideration of sustainability risk – Statement on the consideration of principle adverse impacts on investment decisions
Ludus GP is aware of the sustainability risks and issues and its growing importance in today’s societies and is committed to manage Ludus SCS in a socially responsible manner. It is also aware of the importance of responsible investing and the positive impact of it. However, the investing focus lays on Turkish start-ups and venture capital companies, which by nature are very small and do not typically, involve significant sustainability risks. Considering the size, nature and scale of its activities, and as the primary objective of the Fund is to achieve attractive returns by investing in start-ups and venture capital companies, Ludus GP considers that it is not proportionate for it to comply with the detailed technical standards under the SFDR relating to the principal adverse impacts of its investment decisions on sustainability factors.
Therefore, at this stage, Ludus GP does not yet take into account any principle adverse impact on its investment decisions on sustainability factors as specified in the SFDR.

Ludus GP S.à r.l.
Grand Duchy of Luxembourg [date]