ESG Disclosures
Integration of Sustainability Risks into the Investment Process
Unlike investment vehicles which promote environmental, social and governance (“ESG”)
characteristics or have a specific sustainability or impact objective that may result in a constrained
investment universe, the Fund seeks to maximize financial performance, whereby ESG
considerations are input factors within the investment process that the Investment Manager
considers appropriate to pursue the Fund’s investment objective. As part of its investment
process, the Fund includes all relevant financial risks in its investment decision and evaluatesthese on an ongoing basis. In doing so, relevant sustainability factors and sustainability risks areassessed and taken into account, including ESG events or conditions that could have a material
impact on the investment in question, its return and in turn, the Net Asset Value of the Fund.
Sustainability factors within the meaning of Regulation (EU) 2019/2088 of the European
Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in thefinancial services sector (the “SFDR”) are defined as environmental, social and employee matters,
respect for human rights, anti-corruption and anti-bribery matters. The Investment Manager’sanalysis of the management of sustainability risks incorporates governance analysis sourced byboth internal and external data providers. It covers the boards' independence, experience andeffectiveness, executive pay practices, ownership structure and reliability of reported financials inrespect of the underlying companies in which the Fund invests. The Investment Manager engages
with the underlying companies via dialogue and voting rights. In exercising the Fund’s voting rights
in its investments, the Investment Manager considers ESG factors, as appropriate. The
governance guidelines establish a consistent philosophy and approach to corporate governanceand the exercising of voting rights.
Principal Adverse Impacts
The Company, and in turn, the Investment Manager, do not currently consider the principal
adverse impacts of investment decisions on sustainability factors, within the meaning of SFDR,
because whilst ESG risks are incorporated into the Investment Manager’s investment decision
making processes, the Fund’s objective, and in turn the Investment Manager’s objective in respectof the Fund, is to achieve [total return through growth of capital and current income]. Further, therelevant information required to appropriately assess the principal adverse impacts of theInvestment Manager’s investment decisions on sustainability factors is not yet available.
The Company and the Investment Manager will keep this decision to not consider the principal
adverse impacts of investment decisions on sustainability factors within the meaning of SFDR
under review and will formally re-evaluate this decision on a periodic basis.
Risk Factors
Sustainability Risk
Sustainability risks within the SFDR are ESG events or conditions whose occurrence could havean actual or potential principal adverse impact on the value of the Fund’s investment. Sustainability
risks can affect all known types of risk (for example, market risk, liquidity risk, counterparty risk
and operational risk), and as a factor, contribute to the materiality of these risk types. Sustainability
risks may impact the value of the companies in which the Fund invests and, as a result, the Net
Asset Value of the Fund itself.