# Notice to the shareholders of SUMUS Fund
Luxembourg, 14 July 2021
Dear Shareholder,
The members of the board of directors (the "Board of Directors") of SUMUS Fund, an investment company with variable capital incorporated under the laws of the Grand Duchy of Luxembourg, and governed by Part I of the law of 17 December 2010 on undertaking for collective investments, as amended, hereby inform you of the following modifications made to the prospectus of the Company dated February 2021 (the “Prospectus”).
The modifications mentioned below apply to all the Sub-Funds of the Company.
- 
## PART A – GENERAL INFORMATION
	- Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”) requires investment fund managers of undertakings for collective investment in transferable securities and alternative investment funds (the “IFM(s)”) to comply by 10 March 2021 with harmonized rules on transparency with regard to sustainability risks and the consideration of adverse sustainability impacts and the provision of sustainability-related information.


In order to comply with SFDR, a new Section 26 SFDR DISCLOSURES, which reads as follows, has been inserted in the Prospectus:
None of the Sub-Funds of the SICAV are complying with Article 8 or Article 9 of SFDR and the investments underlying these Sub-Funds do not take into account the EU criteria for environmentally sustainable economic activities.
The SFDR disclosures set out below relates to all the Sub-Funds of the SICAV.
- 
### Classification of the Sub-Funds under SFDR

The Sub-Funds are not financial products subject to Article 8 or Article 9 of SFDR.
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### Integration of Sustainability Risks and Assessments into Investment Decisions

The Sub-Funds’ investment objective and policies are set out in each Sub-Fund's appendix and it should be understood that the Sub-Funds have no objective or commitment to invest in companies that promote environmental or social characteristics or that qualify as ‘sustainable investments’ for the purposes of SFDR.
However, the Investment Manager integrates sustainability risks and opportunities into its research, analysis and investment decision-making processes by formally tracking and monitoring sustainability
factors across a defined set of indicators depending of data currently available on the market. As for the Sub-Funds’ holdings, ESG relevant news are monitored closely to take measures in order to reduce risk or capitalize on possible opportunities. The Investment Manager firmly believes that the consideration of these risks and opportunities can help to enhance long-term risk adjusted returns for investors.
- 
### Likely Impact of Sustainability Risks on the Returns of the Sub-funds

The likely impacts of sustainability risks are difficult to quantify. Although the environmental, social and governance practices of a company/issuer may influence its long-term value, there can be no guarantee regarding the performance of individual investments, nor on the returns of the relevant Sub- Fund’s portfolio as a whole despite the integration of sustainable risks.
- 
### Consideration of the Principal Adverse Impact on Sustainability Factors

Notwithstanding the above, the Investment Manager does not currently consider the adverse effects of investment decisions on sustainability factors for the Sub-Funds within the meaning of article 7.2 of SFDR, mainly because there is currently a lack of available data to determine and assess the principal adverse effects.
- Following the end of the Brexit transition period, UK administrators included in the ESMA register of benchmark administrators in accordance with the Regulation (EU) 2016/1011 of the European Parliament and of the Council of 8 June 2016 on indices used as benchmarks in financial instruments and financial contracts or to measure the performance of investment funds (the “BMR”) have been deleted as the BMR is no longer applicable to them. UK administrators that were originally included in the register as EU administrators qualify now as third country administrators and are benefitting from the transitional period provided for by article 51 (5) of the BMR. UK administrators will have until the end of the BMR transitional period of 31 December 2021 to apply for recognition or endorsement in the EU, in order for the benchmarks provided by these UK administrators to be included in the ESMA register again.

Section 27 USE OF BENCHMARKS of the Prospectus has been amended in order to change the registration status of the benchmark administrator, MSCI Limited, following its deletion from the ESMA register.
- 
## PART B – SPECIFIC INFORMATION
	- Performance fee calculationIt is specified in the description of the performance fee calculation that the performance fee is payable quarterly in arrears. In the Prospectus dated 15 February 2021, the performance fee was payable annually in arrears, at the end of the performance period. This change is aligned with the ESMA guidelines on performance fees for UCITS and certain types of AIFs which entered into force on 6 January 2021 (the “ESMA Guidelines”) and will not have any negative impact on the Shareholders of the Company.


In compliance with the ESMA Guidelines, concrete examples have also been added in the description of the performance fee calculation of each sub-fund.
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## Modifications made to the sub-fund SUMUS – Thematic Fund
	- Net Asset Value Calculation DayThe net asset value calculation day of SUMUS – Thematic Fund will be changed as follows:


| BEFORE | AFTER |
| --- | --- |
| The net asset value is calculated andpublished three Business Daysfollowing the applicable Valuation Day before 5 p.m. | The net asset value is calculated andpublished on the next Business Dayfollowing the applicable Valuation Day before 5 p.m. |

- As a consequence of the change of calculation day of the net asset value, the settlement cycle for subscriptions and redemptions will be reduced to two (2) Luxembourg bank business days instead of four (4) Luxembourg bank business days.

The new prospectus will come into force on 16 July 2021.
For further information on the above modifications, you are invited to consult the new prospectus available at the registered office of the Company.
On behalf of the Board of Directors

Translation (ENIT, 2021-07-14):
# Modifiche apportate al comparto SUMUS – Thematic Fund
- Giorno di calcolo del Valore patrimoniale nettoIl giorno di calcolo del valore patrimoniale netto di SUMUS - Thematic Fund sarà modificato come segue:


| PRIMA | DOPO |
| --- | --- |
| Il valore patrimoniale netto è calcolato epubblicato tre Giorni lavorativisuccessivi al Giorno di valutazione applicabile, entro le ore 17. | Il valore patrimoniale netto è calcolato epubblicato il Giorno lavorativo successivoal Giorno di valutazione applicabile, entro le ore 17. |

- In conseguenza della variazione del giorno di calcolo del valore patrimoniale netto, il ciclo di regolamento per le sottoscrizioni e i rimborsi sarà ridotto a due (2) giorni lavorativi bancari lussemburghesi invece di quattro (4) giorni lavorativi bancari lussemburghesi.

Il nuovo prospetto informativo entrerà in vigore in data 16 Iuglio 2021.
Per ulteriori informazioni in merito alla suddetta modifica, La invitiamo a consultare il nuovo prospetto informativo disponibile presso la sede legale della Società.
In nome del Consiglio di Amministrazione