The fund
Clearly structured. Transparent in costs.
A Dutch mutual fund (fonds voor gemene rekening) with an open-end structure. You can enter monthly, and the cost structure is designed so that the manager only earns when you earn.

Fund characteristics
FGR, tax transparent
No tax at fund level. Assets and results are attributed directly to the participant; for Dutch private individuals usually in box 3. The assets are held in the name of Stichting Juridisch Eigenaar Keystone21 Fonds.
Open-end, monthly
The net asset value (NAV) is determined monthly by an independent party. On the dealing day you enter or exit at that value.
Four years or more
The fund has an indefinite term. We recommend at least four years: one full market cycle.
Quarterly reports
Each quarter you receive a report in your personal online environment. In addition to the NAV development, it explains the relevant developments in the fund and the market.
| Costs | Amount | Explanation |
|---|---|---|
| Management fee | 1.5% per year | On the fund's assets, for management |
| Service fee | 0.5% per year | For third-party costs: administrator, annual accounts, supervision. If insufficient, the manager pays the difference |
| Performance fee | 15% | On profit after other costs, only above the High Water Mark |
| Entry costs | none | |
| Exit costs | 1% | Only on exit within four years; for the benefit of the fund and the remaining participants |
Transaction and bank costs are charged to the fund's assets. The management and performance fees are exempt from VAT.
The High Water Mark: you never pay twice for the same profit
The High Water Mark is the highest level the value of your subscription ever reached at the end of a quarter. The manager only receives a performance fee again when that level is exceeded. If the value first falls and then recovers, no performance fee is due on that recovery.
- Entire term. The High Water Mark is never reset.
- Per subscription. Each participant's own moment of entry counts.
- Per quarter. Calculated on profit after the other fund costs and the management fee.
This keeps interests aligned: the manager only earns on new value created for you.
Documents
Read these documents before participating. The Information Memorandum always prevails. The documents are available in Dutch; articles of association and annual reports are available on request.
Sustainability information
Keystone21 values a sound sustainability policy. At the same time, the fund is bound by the context of the products it invests in: Bitcoin and regulated listed products. This means the following.
- Not a 'green' fund. The fund does not promote environmental or social characteristics (Article 8 SFDR) and does not have sustainable investment as its objective (Article 9 SFDR). The investments do not take into account the EU criteria for environmentally sustainable activities.
- Sustainability risks are considered. To a limited extent, with the emphasis on the energy consumption of the Bitcoin network: policy or rules on this can affect value.
- Adverse impacts not yet considered. This requires reliable data on, among other things, the CO2 emissions and energy consumption attributable to the fund’s investments. Bitcoin has no issuer that reports on this, and for listed Bitcoin products such figures are not available in a standardised form. Collecting them ourselves would be too costly given the current size of the fund. This decision may be reconsidered.
- Remuneration. A remuneration policy is not required and has not been adopted. If variable remuneration is introduced, we will take incentives to take (sustainability) risks into account.
The full disclosure under the Sustainable Finance Disclosure Regulation (SFDR, Regulation (EU) 2019/2088) is in section 5.9 of the Information Memorandum.
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