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Sustainable Finance Disclosure Regulations


The General Partner will have regard to 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 (the “Sustainable Finance Disclosure Regulation”) and the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (the “Taxonomy Regulation”) when making investment decisions and Fund reporting, noting that parts of the EU Taxonomy Technical Screening Criteria are still in development.

 1. Integration of Sustainability Risk

A sustainability risk means “an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment.” Sustainability risks are integrated into the investment decisions of the General Partner and are taken into account during the investment process in a manner proportionate to each product’s investment objective and in the same way as the General Partner approaches other forms of risk management in relation to its products. This is done primarily as part of the due diligence process, whereby should an investment have a material exposure to a sustainability risk, the General Partner may, as part of its wider evaluation process, choose not to make an investment on the basis of this and other risks and in accordance with the relevant investment and risk management policies.

2.Principle Adverse Impacts of Investment Decisions on Sustainability Factors

The General Partner intends to comply with Article 4 of the Sustainable Finance Disclosure Regulation However, in accordance with Article 7(1) of the Sustainable Finance Disclosure Regulation, fund-specific disclosures with respect to principal adverse impacts do not apply until 30 December 2022.

3. Remuneration Policies and Sustainability Risks

The General Partner’s remuneration policies are consistent with the integration of sustainability risks in that the remuneration arrangements of the General Partner have been designed in a manner that (i) is consistent with and promote sound and effective risk management, (ii) does not encourage risk-taking that is inconsistent with the risk profile of the Fund, and (iii) does not impair compliance with the General Partner’s duty to act in the best interests of the investors in the Fund.

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