Advise on Investments

General Principles

The Fund does not promote environmental and/or social characteristics, nor does it have sustainable investment as its objective within the meaning of Articles 8 or 9 of the SFDR. Therefore, the Fund’s Sustainability Risk Policy focuses on the requirements of Article 6 of the SFDR. The investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities. In compliance with SFDR, the Fund implements a policy for the integration of sustainability risk in its investment decision-making process and risk management procedures.

Integration of Sustainability Risks in the Investment Decision-Making Process

The Fund, as part of its investment decision-making process and risk management framework, carries out due diligence and monitors a spectrum of risk factors. Therefore, Sustainability Risk is assessed among several other risk factors, as part of the risk management framework of the Fund.

In this respect, the Fund considers ESG factors along with other risk factors as part of its wider investment decision-making process, meaning that although the Fund takes Sustainability Risk into consideration when making an investment decision, it does not by itself prevent the Fund from making an investment. The Fund does not apply any risk limits or thresholds that relate exclusively to Sustainability Risk as a separate category of risk.

When assessing ESG factors, the Fund relies on information from external data providers, and although a qualitative and/or quantitative review is performed on the data sources, the Fund cannot be responsible for the accuracy of this data.

Where the Fund delegates the portfolio management function to a Third-Party Investment Manager (“IM”), the IM will be responsible for the pre-trade assessments and investment decision-making process in accordance with the outsourcing agreement between the IM and the Fund and the Fund’s Offering Memorandum. In such case, the Fund shall ensure that the IM has a policy on whether Sustainability Risk is integrated into the investment decision-making process.

No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors

The Fund does not consider Principal Adverse Impacts (“PAI”) on Sustainability Factors when making investment decisions, mainly due to its size and scale of its activities. In addition, it does not consider PAI to be relevant to the Fund.

The Fund closely monitors regulatory developments under SFDR and other applicable ESG-related laws and regulations and will re-evaluate its decision on whether or not to consider PAIs each year.

Definitions

 Remuneration Policy

The Fund’s remuneration policy does not encourage excessive risk taking, including risk taking in terms of Sustainability Risks. In this respect the Fund does not award any performance-based remuneration which is linked to the performance of the Fund or to the level of risks (including Sustainability Risks, which may have an impact on the return of the investment). Therefore, there is no incentive to under- or over- estimate the level of risk assessed (including Sustainability Risk) which ensure promotion of sound and effective risk management.