Impressum / Legal Notice
(Valid for all references to “Deistler Family Office” on www.deistler.family and associated materials)
Responsible Entities under German Law (§ 5 TMG, § 18 Abs. 2 MStV)
Deistler Family Office (Legal Definition)
For the purposes of all documents, website references, disclosures, legal statements, policies and regulatory notices provided on this website or in related communications, the term “Deistler Family Office” shall refer collectively to the following legal entities (together the “Deistler Family Office Entities” or “Deistler Group”):
- HD Venture Group LLC
Registered Office / Sitz der Gesellschaft:
30 N Gould St,
STE R,
Sheridan,
WY 82801,
USA
Legal Form:
Limited Liability Company (LLC)
Commercial Register:
State of Wyoming, USA
Contact:
E-Mail: [email protected]
Website: www.hd-venture.com
Unified Corporate Definition Clause (very important)
Legal Definition for All Documentation
For purposes of all legal notices, disclosures, policies, website terms, regulatory statements, agreements, disclaimers, risk disclosures and any related documentation provided on or via www.deistler.family, the term:
“Deistler Family Office”
shall collectively refer to, and shall be deemed to include, HD Venture Group LLC, including their respective directors, officers, employees, affiliates and any entities under common management or control.
Any reference to the “Family Office”, “we”, “us”, or “our” shall be construed accordingly.
Contact Information pursuant to § 5 TMG
E-Mail: [email protected]
Postal Address:
Deistler Family Office
Hans-Thoma Str. 4
61476 Kronberg im Taunus
Germany
Regulatory Status
The Deistler Group does not offer regulated financial services to retail clients.
Any investment activity, co-investment structure, or transaction is conducted privately and exclusively with qualified partners, institutions, or professional investors.
Disclaimer on External Links (§ 7–10 TMG)
Deistler Family Office is not responsible for external content linked to or referenced on this website. Liability arises only if the operator becomes aware of unlawful content and fails to remove or block such content.
Copyright Notice
All content, text, media, analysis, research, documents and data on this website are protected by copyright.
Any use requires prior written permission of the Deistler Group.
Governing Law
This Legal Notice is governed by the laws of the Federal Republic of Germany.
EU SUSTAINABLE FINANCE DISCLOSURE REGULATION (SFDR)
GLOBAL SUSTAINABLE INVESTMENT DISCLOSURE FRAMEWORK
OF DEISTLER FAMILY OFFICE
Last updated: January 2025
I. INTRODUCTION AND REGULATORY CONTEXT
The Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088, “SFDR”) forms a central pillar of the European Union’s Sustainable Finance Action Plan. It establishes harmonised rules on transparency with regard to the integration of sustainability risks, the consideration of adverse sustainability impacts, and the promotion of environmental or social characteristics and sustainable investment objectives in the financial services sector.
SFDR applies to financial market participants and financial advisers within the European Union and, indirectly, to non-EU entities providing products or services to EU investors or acting under delegation or sub-advisory arrangements for EU-regulated entities. In this context,Deistler Family Office (“Deistler”, “we”, “us”, “our”) recognises SFDR as a key regulatory framework impacting our investment vehicles, tailored mandates, co-investment structures and advisory relationships that are, directly or indirectly, in scope of SFDR.
Since the publication of SFDR in 2019, Deistler has treated SFDR as a strategic regulatory priority. We have implemented SFDR Level 1 requirements by March 2021 and have established a dedicated programme to achieve and maintain alignment with the SFDR Level 2 Regulatory Technical Standards (“RTS”).
This SFDR Disclosure Framework outlines Deistler’s approach at:
entity level (Articles 3, 4 and 5 SFDR); and
product level (Articles 6, 8 and 9 SFDR, as applicable),
and is designed to be consistent with our broader sustainable investment and ESG integration framework.
This document is global in scope and is intended to support SFDR-compliant disclosures for all relevant Deistler structures where SFDR applies directly or indirectly (e.g. via delegation to EU AIFMs/UCITS ManCos or advisory relationships with EU-regulated institutions).
II. IMPLEMENTATION OF SFDR LEVEL 1 REQUIREMENTS
By March 2021, Deistler implemented the core SFDR Level 1 requirements for in-scope activities, covering:
Article 3 SFDR – Sustainability Risk Policies
Adoption of internal policies describing how sustainability risks are integrated into investment decision-making and advisory processes, including definitions, governance, procedures and escalation mechanisms.
Article 4 SFDR – Principal Adverse Impacts (PAI)
Assessment of whether and how principal adverse impacts of investment decisions on sustainability factors are considered at the entity and/or product level, including criteria for PAI consideration and related methodologies.
Article 5 SFDR – Remuneration Policies
Integration of sustainability risk considerations into remuneration policies, ensuring that remuneration structures do not encourage excessive risk-taking with respect to sustainability risks.
Articles 6, 8 and 9 SFDR – Product-Level Transparency
Initial classification and disclosure of products with regard to:
integration of sustainability risks (Article 6);
promotion of environmental and/or social characteristics (Article 8);
sustainable investment as an objective (Article 9),
together with relevant pre-contractual disclosures.
The initial SFDR Level 1 implementation included:
mapping of all in-scope products and mandates;
establishment of internal classification criteria;
drafting and publication of relevant website disclosures;
adaptation of due diligence and documentation processes to reflect SFDR requirements.
III. PREPARATION AND ALIGNMENT WITH SFDR LEVEL 2 (RTS)
SFDR Level 2 RTS set out prescriptive and standardised templates for pre-contractual, website and periodic disclosures for products falling under Articles 8 and 9, and detailed requirements for entity-level PAI disclosures.
Deistler has initiated and is continuously enhancing a comprehensive SFDR Level 2 alignment programme, including:
Data Management and Infrastructure
Identification of data requirements for PAI indicators (environmental, social, employee, human rights, anti-corruption and anti-bribery matters);
Integration of ESG data from external providers and internal research;
Establishment of data quality controls and validation checks;
Design of templates and processes to feed RTS Annexes (e.g. Annex II, III, IV, V, etc.).
Methodology Development
Definition of methodologies for each mandatory and, where applicable, additional PAI indicators;
Documentation of calculation approaches, estimation techniques, use of proxies and treatment of data gaps;
Establishment of internal sign-off processes for methodology approval and review.
Governance and Oversight
Extension of governance responsibilities for SFDR-related decisions to relevant committees and oversight functions;
Regular review of SFDR classification of products;
Ensuring coherence between SFDR and other sustainable finance regulations (e.g. EU Taxonomy).
Disclosure Processes
Preparation of standardised pre-contractual SFDR RTS annexes for in-scope products (Articles 8 and 9);
Design of periodic SFDR reporting templates;
Alignment of public website disclosures with RTS detailed requirements.
IV. SUSTAINABILITY GOVERNANCE AND ORGANISATIONAL STRUCTURES
Firmwide ESG and Sustainability Framework
Deistler’s approach to ESG and sustainability integration is anchored in firmwide policies and overseen by senior leadership. Sustainability is integrated into:
investment strategy formulation;
risk management;
product governance;
internal control functions and compliance oversight.
Sustainable Investment Committee
Deistler has established a Sustainable Investment Committee with the following responsibilities:
oversight of sustainability risk integration;
review and approval of SFDR-relevant policies and methodologies;
validation of product classifications under Articles 6, 8, and 9;
periodic review of PAI indicators and associated disclosures;
monitoring regulatory developments in sustainable finance.
Sustainable Investment Regulatory and Third-Party Working Group
Deistler has created a specialised working group dedicated to:
regulatory monitoring in sustainable finance and ESG-related topics;
coordination with external ESG data providers, consultants, auditors and legal counsel;
implementation and maintenance of SFDR-related processes and systems;
ensuring alignment of delegated and outsourced arrangements with SFDR requirements.
Internal Control Functions
Compliance, Risk Management and Internal Audit functions provide second- and third-line oversight over SFDR-related frameworks, including:
review of methodologies and assumptions;
testing of control effectiveness;
verification of disclosures and reporting.