Context, objectives and definitions

In accordance with Article 3 of Regulation (EU) 2019/2088 ("Disclosures" or "SFDR") and Article L. 533-22-1 of the CMF (resulting from Article 29 of the Energy-Climate Law), financial market participants publish on their websites information about their policies on integrating sustainability risks into their investment decision-making process, including for French participants, risks associated with climate change as well as on biodiversity risks.

The objective of this policy is to increase transparency on how financial market participants integrate relevant sustainability risks, which are material or likely to be material, into their investment decision-making processes.

The policy is based on the principle of dual materiality:

Sustainability risk: Impact of external events on product performance (How is the impact of external events on the performance of the financial product integrated into the risk management policy?)
Negative impacts on sustainability: Impact of investments made on external sustainability factors (How does the entity ensure that investments made do not cause significant harm to environmental and social objectives?)

Definitions

| Sustainability risk | A sustainability risk is an environmental, social or governance event or situation which, if it occurs, could have a material adverse effect, actual or potential, on the value of the investment. Sustainability factors include environmental, social and personnel issues, respect for human rights and the fight against corruption and bribery.

In their sustainability risk policy, made public pursuant to Article 3 of the Regulation of the European Parliament and of the Council on the publication of sustainable investment and sustainability risk information and amending Directive (EU) 2016/2341, [French] asset management companies include information on risks associated with climate change as well as biodiversity risks. | | --- | --- | | Environmental risks (climate change) | Physical risks, resulting from damage directly caused by meteorological and climatic phenomena, such as :

the loss in value of investments held by portfolios managed [and advised] and issued by entities affected by these climatic events;
an increase in the frequency and cost of claims paid by insurers to policyholders; Climate change and biodiversity loss are included in this risk.

Transition risks, which result from adjustments made with a view to a transition: exposure to changes brought about by the ecological transition, in particular the environmental objectives defined by the Taxonomy regulation , in particular when these are poorly anticipated or occur suddenly. These risks are linked, for example, to :

impairment of assets as a result of regulatory changes that would penalise or even prohibit certain activities deemed to emit too much greenhouse gas (GHG);
losses following the end of certain financed activities deemed too polluting or GHG emitting;

Induced liability risks (legal and reputational risks), linked to the financial impact of claims for compensation from funded companies by those who suffer damage due to climate change, such as :

investments that finance the development of industries and activities that pollute or emit high levels of greenhouse gases;
professional insurance, operator liability, infrastructure construction. | | Social risk | Social risk involves analysing the company's relationship with its stakeholders: employees, customers, suppliers and civil society. It includes the protection of employees in terms of health and safety, the fight against discrimination, their well-being, respect for human rights within the supply chain, the company's philanthropic approach, its relations with local communities, customer satisfaction, etc. | | Governance risk | Governance risk encompasses the competence of the company's management team, the structure of the chief executive's remuneration package and its legitimacy, as well as the existence of checks and balances. This last point is assessed by analysing the composition of boards of directors, the suitability of directors' profiles to the company's needs, their independence, respect for minority shareholders, business ethics and the company's commitment to CSR issues. | | Negative impact on sustainability (PAI) | Principal adverse impacts on sustainability (PAI): impacts of investment decisions that have or are likely to have a material adverse effect on sustainability factors (environmental, social and labour issues, respect for human rights and the fight against corruption and bribery). |

Identification of ESG and sustainability risks (Art.3 SFDR)

Activities concerned

CSAM provides the following services which are subject to sustainability risks:

AIF management (AIFMD)
Portfolio management on behalf of third parties (MiFID)
Investment Advice (MiFID)

CSAM applies this policy in an undifferentiated manner by major category of financial instrument.

Exposure to ESG or sustainability risks

Summary of the approach

Extra-financial criteria	CSAM does not take ESG criteria (social, environmental and governance criteria) into account when implementing its investment policy.
SFDR	CSAM does not promote environmental or social governance (ESG) criteria. Its objective is not a sustainable investment but a replication of the bitcoin price.
Taxonomy	The fund does not promote environmental and social characteristics.

Content, frequency and means used to inform investors of the criteria relating to the ESG objectives taken into account in the investment policy and strategy

CSAM's ESG approach is included in the Fund Prospectus and the Annual Report. CSAM responds to specific requests from certain investors on a case-by-case basis.