Regulatory disclosures
Sustainability disclosures
This page contains the website disclosures made by Novus Management S.à r.l. ("the AIFM"), a Luxembourg société à responsabilité limitée registered with the Luxembourg Trade and Companies Register under RCS B290643 and acting as alternative investment fund manager of the Novus Cognitive Alpha Fund (the "Fund"), pursuant to its obligations under Articles 3 and 4 of 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").
Article 3 — Integration of sustainability risks
Under Article 3 SFDR, the AIFM is required to publish on its website information about its policies on the integration of sustainability risks in its investment decision‑making process. For these purposes, "sustainability risk" is defined in Article 2(22) 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 an investment.
The Fund pursues a multi‑strategy, systematic and AI‑driven approach to liquid digital assets. The investment universe consists of cryptocurrencies, stablecoins and related listed digital‑asset instruments traded on regulated venues and major centralised and decentralised exchanges. These instruments are not issued by operating companies and do not generate the traditional corporate sustainability data (for example, emissions intensity, governance ratings, human‑capital metrics) of the kind contemplated by SFDR and its supporting technical standards.
The AIFM has nevertheless considered whether sustainability risks are likely to be financially material for the Fund. Based on the nature of the asset class, the short holding periods inherent in the systematic strategy, and the absence of issuer‑level sustainability data for the majority of in‑scope instruments, the AIFM does not currently view sustainability risks as a primary driver of the Fund's risk‑adjusted returns. Accordingly, sustainability risks are not embedded as a distinct factor within the quantitative signals used by the strategy.
The AIFM monitors developments in the regulatory framework, in industry sustainability‑data coverage for digital assets, and in the academic and supervisory literature on the energy profile and governance characteristics of relevant protocols. Where the AIFM becomes aware of a sustainability‑related event materially affecting the value of an instrument held by the Fund (for example, a protocol‑level governance failure, a regulatory action driven by environmental factors, or a sanctions event with a sustainability dimension), this information is reviewed within the Fund's broader risk‑management framework and may, where appropriate, lead to a re‑assessment of the position.
In line with Article 6 SFDR, the assessment of the likely impacts of sustainability risks on the returns of the Fund is also addressed in the Fund's pre‑contractual offering documentation (the Private Placement Memorandum and subscription documents), which prevails over this website disclosure in the event of any inconsistency. This policy is reviewed at least annually and updated as required.
Article 4 — Principal adverse impacts statement
Under Article 4 SFDR, financial market participants are required to publish and maintain on their website either (i) a statement on their due‑diligence policies with respect to the principal adverse impacts ("PAI") of their investment decisions on sustainability factors, or (ii) clear reasons why they do not consider such adverse impacts, together with information as to whether and when they intend to do so.
Novus Management S.à r.l. has determined that it does not currently consider principal adverse impacts of its investment decisions on sustainability factors within the meaning of Article 4(1)(b) SFDR. The AIFM has reached this position for the following reasons:
- The AIFM and the funds it manages invest exclusively in liquid digital assets (cryptocurrencies, stablecoins and related listed digital‑asset instruments) that are not issuer‑based financial instruments of the type addressed by the mandatory PAI indicators set out in Annex I of Commission Delegated Regulation (EU) 2022/1288. The quantitative data required to compute the majority of those indicators — including, but not limited to, greenhouse‑gas emissions and carbon footprint of investee companies, exposure to fossil‑fuel sector activities, board gender diversity, exposure to controversial weapons, and violations of UN Global Compact principles — is not produced by, or applicable to, the assets in which the funds invest.
- The AIFM does not, at this stage, meet the size threshold set out in Article 4(3) SFDR, namely an average of more than 500 employees on its balance‑sheet date, and is therefore not subject to the mandatory consideration regime applicable to large financial market participants.
- Producing a PAI statement based on indicators that are not meaningfully measurable for the underlying assets would risk providing investors with information that is not robust, verifiable, or comparable across periods. The AIFM considers that this would not serve the transparency objectives of SFDR and could be misleading.
The AIFM keeps this position under continuous review. It will reconsider Article 4 application if (a) the size threshold in Article 4(3) SFDR becomes relevant, (b) sustainability‑data coverage for digital assets reaches a standard the AIFM judges to be robust, verifiable and comparable, or (c) the regulatory technical standards or supervisory guidance are extended or revised in a manner that meaningfully addresses digital‑asset specifics. Any change to this position will be reflected in an updated statement published on this page, with a revised "Last updated" date.
Product‑level classification (Articles 6, 8 and 9)
The Novus Cognitive Alpha Fund is classified as an Article 6 product under SFDR. The Fund does not promote environmental or social characteristics within the meaning of Article 8 SFDR, and it does not have sustainable investment as its objective within the meaning of Article 9 SFDR. The investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities within the meaning of Regulation (EU) 2020/852 ("EU Taxonomy"). Pre‑contractual disclosures relating to the Fund are set out in the Fund's offering documentation.
Remuneration policy
Consistent with Article 5 SFDR, the AIFM has integrated information about the consistency of its remuneration policy with the integration of sustainability risks into the policy itself. Given the position set out above — that sustainability risks are not currently a primary driver of the Fund's risk‑adjusted returns — the AIFM's variable remuneration arrangements do not incentivise risk‑taking with respect to sustainability factors. The remuneration policy is reviewed at least annually.
Contact
Questions about these disclosures should be addressed to the AIFM at info@265.capital, marking the subject line "SFDR — sustainability disclosures".
Important notice
This page is a regulatory disclosure made pursuant to SFDR. It is not an offer or solicitation to subscribe for securities and does not constitute investment advice. Any investment decision in respect of the Novus Cognitive Alpha Fund must be based exclusively on the Fund's definitive offering documentation. In the event of any inconsistency between this page and the offering documentation of the Fund, the offering documentation prevails.