STATEMENT OF MGG ADVISERS LTD. (MGG) AND SOFIA ANGELS VENTURES (SAV) FOR NON-CONSIDERATION OF ADVERSE IMPACTS ON ITS INVESTMENT DECISIONS ON STABILITY FACTORS

SAV publishes this Statement on its website pursuant to Delegated Regulation (EU) 2022/1288, Chapter II, Section 3. This Statement aims to ensure that investors can make informed decisions by providing them with access to reliable data, which is to be used and analyzed in a timely and efficient manner.

MGG ADVISERS LTD. is an alternative investment fund manager (AIFM).

The only fund currently managed by MGG ADVISERS LTD. is SOFIA ANGELS VENTURES.

SAV is a fund incorporated with the purpose to acquire and manage shareholdings in certain enterprises with a focus on companies in areas covered by the societal challenges and industrial leaderships of Horizon 2020 such as life sciences, clean energy, Information and Communication Technology or technology in enterprises compliant with certain eligibility criteria.

Nevertheless for the moment MGG and SAV does not consider adverse impacts of their investment decisions on sustainability factors in the manner prescribed by Article 4 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 sector and is fully compliant with Article 4, point (b) of paragraph 1 of the Regulation (EU) 2019/2088.

Currently MGG and SAV do not consider adverse impacts of their investment decisions on sustainability factors, because at this stage, the consideration of the adverse effects of investment decisions on sustainability factors as per art. 4 of the Regulation (EU) 2019/2088 will lead to:

• limitation of the ability to be achieved better diversification of risk and return on investments and
• significant expenditure of resources (human, managerial and financial), which will not result in expected and measurable increase in income in the medium or even long term.

In addition, MGG and SAV have not identified significant interest by the enterprises (potential portfolio companies) to give priority to the consideration of the adverse impacts of investment decisions on sustainability factors over measurable increase in income.

However, our team aligns the SAV investment policy with the ESG principles and tendencies and is constantly improving the level of knowledge, understanding and integration of ESG standards and is dedicated to achieve and maintain best practices in all investment related activities, both in the due diligence process and the entire lifecycle of each investment, including in regard to the ESG related standards when applicable and not contradictory to the obligatory regulations imposed by the applicable EU legislation and EIF constituting documentation.

Pursuant to the requirements of Article 4, point (b) of the Regulation (EU) 2019/2088, MGG and SAV intends to consider the adverse impact of investment decisions on sustainability factors at a later stage when:

• MGG and/or SAV identifies tangible interest by the enterprises (potential portfolio companies) to give priority to the consideration of the adverse impacts of investment decisions on sustainability factors over measurable increase in income and
• When a portfolio company of SAV reaches revenues of BGN 5,000,000 per calendar year.

Information is updated as of 11.06.2024