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Digital Ocean Ventures

01/

Information Policy (AIFM Disclosure)

Digital Ocean Ventures Starter Spółka z ograniczoną odpowiedzialnością has been carrying on activity as an external Manager of Alternative Investment Companies since 21 January 2025, on the basis of an entry in the Register of Managers of Alternative Investment Companies maintained by the Polish Financial Supervision Authority.

Managers of Alternative Investment Companies (AIFMs) within the meaning of the Polish Act of 27 May 2004 on Investment Funds and on the Management of Alternative Investment Funds (the "AIF Act") are subject to the supervision of the Polish Financial Supervision Authority (the "KNF") as entities carrying on activity in the capital market — to the extent of the obligations imposed on them under the relevant legal provisions in connection with their participation in that market.

Pursuant to Article 70a(6) of the AIF Act, an AIFM operates its own website on which it publishes, in particular, the information and announcements required by law.

In accordance with Article 2 of the Polish Act of 21 July 2006 on Supervision of the Financial Market, the objective of the KNF, in exercising supervision of the financial market, is to ensure the proper functioning of that market, its stability, security and transparency, confidence in the financial market, as well as to ensure the protection of the interests of participants in that market, including by means of reliable information regarding the functioning of the market, and through the pursuit of the objectives set out, inter alia, in the Polish Act of 29 July 2005 on Supervision of the Capital Market. The supervision of the capital market is intended to ensure the proper functioning of the capital market, in particular the safety of trading and the protection of investors and other participants of the market, as well as compliance with the rules of fair trading.

An AIFM is required to conduct its activities in accordance with the law and with the principles of fair trading, and the persons exerting influence on the conduct of the activities of an AIFM are required to perform their duties in accordance with the principles of fair trading and in a manner that does not infringe the interests of investors of the Alternative Investment Company; accordingly, such persons may not participate in undertakings that potentially lead to the circumvention of legal provisions, or that directly violate generally applicable legal norms.

Scope of supervision exercised by the KNF over an AIFM entered in the Register of Managers of Alternative Investment Companies

  • An AIFM entered in the Register of Managers of Alternative Investment Companies is subject to substantially limited obligations vis‑à‑vis the supervisory authority, in particular reporting obligations consisting of providing the KNF, on an annual basis, with information solely on the aggregate value of the assets comprising the investment portfolios of the managed Alternative Investment Companies and on their five largest investments.

    In particular, the financial statements of the AIFM and of the Alternative Investment Company are not transmitted to, and are not subject to verification by, the KNF.

    Likewise, the KNF does not supervise or verify the composition of the investment portfolio of the Alternative Investment Company, nor any changes to its internal documents, namely its investment policy and investment strategy. The AIF Act provides for no restrictions on the actual composition of such portfolio, or on the precise content of the investment policy and strategy of an Alternative Investment Company.

    The catalogue of investments of an Alternative Investment Company remains open in view of the absence of statutory restrictions as to the permissible investments made by such company, or as to principles of investment diversification and liquidity management, provided that they remain consistent with the exclusive object of activity of the Alternative Investment Company, with the principles of fair trading, and that they duly safeguard the interests of investors of the Alternative Investment Company.

  • In respect of the managed Alternative Investment Companies there is also no obligation to enter into an agreement with a depositary (a bank or an investment firm) holding and maintaining a register of all of the assets of the company, and performing the material function of an entity controlling the activities undertaken by the AIFM.

  • There is likewise no obligation for the AIFM to mandatorily adopt and maintain, inter alia, a remuneration policy or internal regulations concerning the system of internal control, including legal compliance, audit or risk management.

  • In view of the limited scope of regulation applicable to a registered AIFM, and consequently of the limited scope of supervision exercised by the KNF over such an entity, investors of the Alternative Investment Company must take into account the existence of an elevated investment risk associated with investments in participation rights of the Alternative Investment Company.