Regulatory documents
The content published on atifund.pl is addressed exclusively to professional clients within the meaning of Art. 2 point 13a of the Act of 27 May 2004 on investment funds and management of alternative investment funds. It does not constitute an offer within the meaning of Art. 66 of the Polish Civil Code, an investment recommendation or investment advice.
1. Legal status and registration data
ART-Tech Alternatywna Spółka Inwestycyjna Sp. z o.o. (ART-Tech Alternative Investment Company Ltd.) is an alternative investment company within the meaning of Art. 8a(1) of the Act of 27 May 2004 on investment funds and management of alternative investment funds (consolidated text: Journal of Laws 2024, item 1034, as amended — hereinafter: "the IFA").
- Full legal name: ART-Tech Alternatywna Spółka Inwestycyjna Spółka z ograniczoną odpowiedzialnością
- Legal form: sp. z o.o. (limited liability company — alternative investment company)
- Registered office: ul. Mogilska 65, 4th floor, 31-545 Kraków, Poland
- ZASI No. (KNF national number): PLZASI00321
- Short name (AIC manager): Art-Tech ASI sp. z o.o.
- KRS: 0000994565
- NIP: 6751771209
- REGON: 523253851
- Date of entry in the AIC register: 2022-08-16
- AIC type: Internally managed AIC
- Share capital: fully paid up (per current KRS extract)
- Registry court: District Court for Kraków-Śródmieście in Kraków, 11th Commercial Division of the National Court Register
2. KNF supervision and AIC register entry
The Company conducts its activity on the basis of an entry in the register of managers of alternative investment companies (ZASI) maintained by the Polish Financial Supervision Authority, in accordance with Art. 70zb of the IFA. The Company's ZASI national number is PLZASI00321 (date of entry: 2022-08-16).
The Company's activity is supervised by the Polish Financial Supervision Authority (KNF), with its registered office at ul. Piękna 20, 00-549 Warsaw.
- KNF website: knf.gov.pl
- ZASI / AIC register: zasi.knf.gov.pl
3. Target audience — professional clients
Pursuant to Art. 70k of the IFA in conjunction with Art. 2 point 13a of the IFA, participation rights in ART-Tech ASI may be acquired exclusively by professional clients. The offering is not addressed to retail clients or to an unspecified addressee (prohibition of public offering — Art. 2 point 10a of the IFA).
The definition of a professional client includes, among others: banks, investment firms, investment funds, pension management companies, insurance undertakings, large enterprises meeting specific financial thresholds, and natural persons who have requested professional client treatment and meet the requirements set out in the IFA.
4. Investment risk warning
Investment in an alternative investment company carries the risk of partial or total loss of invested capital. The most significant categories of risk include:
- Market risk — the value of assets may be subject to significant fluctuations;
- Liquidity risk — AIC interests are not regularly traded on a regulated market;
- Credit and concentration risk — arising from concentration of investments in specific sectors or companies;
- Currency risk — for investments denominated in a currency other than PLN;
- Regulatory risk — changes in legislation and taxation;
- Operational risk and early-stage risk — particularly relevant for investments in start-ups and private companies.
Past performance is no guarantee of future results. Before making an investment decision, you should review the full product documentation and, if necessary, seek advice from an independent adviser.
5. SFDR disclosures (sustainability)
In accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector ("SFDR"):
Art. 3 SFDR — Strategy for integrating sustainability risks
The Company does not currently apply systematic integration of sustainability risks in its investment decision-making process within the meaning of Art. 3(1) SFDR. This decision reflects the scale of activity (boutique fund) and the nature of investments in early-stage assets, where standard ESG metrics are not yet available.
Art. 4 SFDR — Principal adverse impacts on sustainability factors (PAI)
Given that it employs fewer than 500 persons, the Company applies the "comply or explain" option provided for in Art. 4(1)(b) SFDR and does not currently consider principal adverse impacts of investment decisions on sustainability factors in the manner required for extended-scope entities. This results from the proportionality of requirements to the scale and nature of the Company's activity. The Company monitors developments in market practice and may implement extended disclosures in the future.
Art. 5 SFDR — Remuneration policy and sustainability
The Company's remuneration policy is consistent with the integration of sustainability risks to the extent appropriate to the scale of activity — remuneration of board members and management staff is not linked to parameters that would encourage excessive risk-taking, including ESG risk.
Art. 6 SFDR — Product classification
Products managed by the Company are classified as products referred to in Art. 6 SFDR — they do not promote environmental or social characteristics within the meaning of Art. 8 SFDR and do not have sustainable investment as their objective within the meaning of Art. 9 SFDR.
6. Conflict of interest management policy
In accordance with Art. 70zb(1) point 3 of the IFA and Art. 14 of the AIFMD (Directive 2011/61/EU), the Company applies a policy for identifying and managing conflicts of interest, comprising:
- Identification of potential conflicts between the Company, its board members and employees on the one hand, and investors and portfolio companies on the other;
- Prevention procedures (segregation of functions, restrictions on personal account dealing, rules on gifts and benefits);
- Procedures for managing conflicts that could not be avoided (reporting to the management board, disclosure to investors);
- Annual review of the policy by the management board.
The full text of the conflict of interest policy is available on written request sent to: inwestycje@atifund.pl.
7. Remuneration policy (summary)
In accordance with Art. 13 of the AIFMD and the ESMA Guidelines on sound remuneration policies (ESMA/2013/232), the Company applies a remuneration policy that:
- Promotes sound and effective risk management;
- Does not encourage excessive risk-taking inconsistent with the risk profile, AIC rules or investment objectives;
- Is consistent with the business strategy, objectives, values and interests of the Company and its investors;
- Comprises fixed and variable components in appropriate proportions.
8. Anti-money laundering (AML)
The Company is an obliged institution within the meaning of Art. 2(1) point 7 of the Act of 1 March 2018 on counteracting money laundering and terrorist financing (consolidated text: Journal of Laws 2023, item 1124, as amended).
The Company applies internal procedures comprising:
- Identification and verification of the client and the beneficial owner (KYC);
- Ongoing transaction monitoring;
- Assessment of money laundering and terrorist financing risk;
- Reporting of transactions to the General Inspector of Financial Information in accordance with Art. 72 of the AML Act;
- Staff training and the appointment of an officer responsible for AML.
9. Documents available for download
The full text of the following documents is made available on written request or in the course of the investment process, after verification of professional client status:
10. Contact
For matters related to regulatory documentation, please contact:
ART-Tech ASI Sp. z o.o.
ul. Mogilska 65, 31-545 Kraków, Poland
E-mail: inwestycje@atifund.pl