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Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)


Date of publication: 24.08.2026


I. Sustainability risks


Resvion GmbH (the “Resvion”, LEI: 391200L116NZ5Y5QR292) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. Resvion considers sustainability risks as part of its due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted by using a questionnaire. The results of such assessment are taken into account when the investment decision is being taken. However, Resvion remains free in its decision to refrain from investing or to invest despite sustainability risks in which case Resvion can also apply measures to reduce or mitigate any sustainability risks. At all times, Resvion will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.


II. No consideration of adverse impacts of investment decisions on sustainability factors

Resvion does not consider any adverse impacts of its investment decisions on sustainability factors and, hence, does not use the sustainability indicators listed in Annex I of the Regulatory Technical Standards (Delegated Regulation (EU) 2022/1288, “RTS”) to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery.



Given that the SFDR, the EU Taxonomy and the accompanying RTS are relatively new legislative acts, there is very little or no practical experience or practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by Resvion. Moreover, the burden associated with the consideration of adverse impacts on sustainability factors by using sustainability indicators is disproportionate in light of the very limited significance that such impacts could have in the context of the investment strategy of Resvion Fund I GmbH & Co. KG (the “Fund”): The Fund pursues an investment strategy centred on value creation through active restructuring. This includes, but is not limited to, operational turnaround, capital structure optimisation, strategic repositioning and management enhancement. The Fund actively engages with portfolio companies to implement tailored restructuring plans and adopts an active portfolio management approach, including the provision of strategic, financial and operational guidance and consulting services. Despite this active engagement, it is currently not foreseeable for Resvion whether the information for the identification and assessment of principal adverse impacts can be obtained regularly and in full from all of the Fund’s portfolio companies. In addition, Resvion consists currently of only five individuals who, in addition to collective asset management, do not have the capacity to collect and process data necessary to take principal adverse impacts of their investment decisions on sustainability indicators into account.


If and to the extent that the legal uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, Resvion will re-evaluate considering principal adverse impacts of its investment decisions in due course. In the meantime, Resvion remains free in its decision to use part of the sustainability indicators listed in Annex I of the RTS and/or an own set of indicators.


III. Remuneration disclosure

As a registered alternative investment fund manager within the meaning of section 2 (4) of the KAGB, Resvion does not have, and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB.