PGIM Netherlands B.V. (the “AIFM”)
Statement of Sustainability Risks Integration Policies(the “Sustainability Risks Integration Statement”)
Effective December 13, 2023
INTRODUCTIONRegulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, asamended (the “SFDR”) intends to provide harmonised disclosure requirements for investment products.
The SFDR lays down harmonised rules for ‘financial market participants’ on transparency with regard tothe integration of Sustainability Risks (as defined below) and the consideration of adverse sustainability
impacts in their processes and the provision of sustainability-related information with respect to financial
products. For the purposes of this Sustainability Risks Integration Statement, ‘financial market
participant’ means the AIFM and ‘Financial Products’ mean each separately managed account of theAIFM (“Account”) and each alternative investment fund managed by the AIFM (“Fund”). ‘Sustainability
Risk’ means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could
cause an actual or a potential material negative impact on the value of an investment. This is consistentwith the definitions of “ESG risk” that PGIM Fixed Income (as defined below) uses in its research andinvestment processes. The terms “sustainability risk” and “ESG risk” will be used interchangeably in thisSustainability Risks Integration Statement.
The AIFM is an alternative investment fund manager, authorised by the Autoriteit Financiële Markten(“AFM”) in the Netherlands, with registration number 15003620. The AIFM is required to disclose certain
information on the integration of sustainability risks in the AIFM’s investment decision-making process inrespect of the Financial Products. The AIFM delegates portfolio management to its affiliates as follows:•In respect of the Accounts, the AIFM delegates portfolio management to PGIM, Inc. and/or PGIMLimited.

•In respect of the Funds the AIFM generally delegates portfolio management to PGIM, Inc. which
in turn can also appoint certain affiliated sub-investment managers including PGIM Limited, PGIM
Quantitative Solutions LLC (“PQS”) and PGIM Private Capital Limited (“PPC”) to manage one ormore of the Funds.

•In this Sustainability Risks Integration Statement, the term “Sub-Investment Managers” means
PQS, PPC, and PGIM Fixed Income, a business unit of PGIM, Inc. the latter of which operates inthe Netherlands through the AIFM, in London through PGIM Limited, and in the United States
through PGIM, Inc. (“PGIM Fixed Income”).

This Sustainability Risks Integration Statement describes how (or whether) the Sub-Investment Managers
integrate Sustainability Risks into their investment decision-making process in respect of certain FinancialProducts. The AIFM acknowledges that the consideration of sustainability factors in the investment
decision-making process can have a significant impact on the risk-return of Financial Products. TheSustainability Risks considered by the Sub-Investment Managers will vary depending on the strategy ofthe Financial Products and also the industry and/or individual issuer. These generally include
environmental Sustainability Risks, social Sustainability Risks and governance Sustainability Risks.
INTEGRATION OF SUSTAINABILITY RISKS IN THE INVESTMENT DECISION MAKING PROCESS
Each Sub-Investment Manager has their own approach to the integration of Sustainability Risks (assummarised below). The SFDR permits financial market participants to explain why for certain products it
may not be possible or relevant for that firm to integrate Sustainability Risks into its investment decision
making process for a particular product (even where the financial market participant is generally
integrating Sustainability Risks). Accordingly, certain Financial Products may be excluded from thesepolicies where it is not possible for the Sub-Investment Manager to integrate Sustainability Risks into theinvestment decision making process. Financial Products which may be excluded include, for example,
Financial Products involving algorithmic, quantitative or high-frequency trading and macro strategies.
Where a Financial Product has been excluded from these policies, this will be set out in the offering
documents for that Financial Product. The below summarises how (or whether) each Sub-Investment
Manager integrates Sustainability Risks in their investment decision-making process in respect of certain
Financial Products.
PGIM Fixed Income
PGIM Fixed Income focuses on public fixed income investments, including broad market strategies, sectorspecific strategies, long duration strategies and alternative strategies.
GeneralThe following is a summary of the sustainability risk integration policy of PGIM Fixed Income.
PGIM Fixed Income believes that ESG factors impact the performance of investment portfolios, and it has
integrated them into its investment analysis and decision-making processes across all of its strategies.
PGIM Fixed Income believes that analysing credit-material ESG factors leads to higher risk adjusted excess
returns.
PGIM Fixed Income defines “ESG risk” and “ESG opportunity” as an environmental, social or governanceevent or condition that, if it occurs, could cause a material negative or positive impact on thefinancial/economic value of an investment. Together, PGIM Fixed Income considers such ESG risks andopportunities to be “credit-material ESG factors.” Because PGIM Fixed Income defines credit-material ESG
factors purely as those it believes have the potential to materially affect the value of specific investments,2and distinct from the consideration of ESG impacts, those factors are incorporated into the evaluation ofissuers’ credit profiles in the management of all client portfolios.
As part of the credit research process, PGIM Fixed Income’s analysts review information related to ESGfactors, which may be provided by the issuer or obtained from third-party ESG research providers oralternative data sources (e.g., NGO analyses, governmental and inter-governmental studies, etc.). PGIM
Fixed Income analysts may supplement this information through engagement with the issuer.
To the extent an ESG factor is considered by the analyst to have a material or a potentially material
adverse impact on the financial value of the issuer, PGIM Fixed Income’s analysts will incorporate suchrisks into their fundamental credit ratings. Fundamental credit ratings are in turn a key factor in PGIM
Fixed Income’s relative value assessments, and PGIM Fixed Income’s portfolio managers will consider
material Sustainability Risks when assessing the overall relative attractiveness of potential investments.
Equally, ESG factors that are considered to be materially or potentially materially positive will also bereflected in PGIM Fixed Income’s fundamental analysis and considered in relative value assessments.
Although PGIM Fixed Income’s views are often informed by quantitative metrics, its ultimate decision on
how ESG issues should influence its investment decisions is largely qualitative, as with other types of risks
and opportunities.
An important focus of PGIM Fixed Income’s sovereign research is on macroeconomic stability and debtsustainability. ESG issues feature in this analysis and, in particular, the sovereign credit ratings process. In
addition to a fundamental macroeconomic score that captures pertinent macroeconomic strengths andvulnerabilities, PGIM Fixed Income’s sovereign ratings framework is also based upon a comprehensive
assessment of qualitative aspects that guide policy making. These aspects include institutional strengths
and weaknesses, and potential governance issues, as well as social issues that could affect relevant
macroeconomic variables. Nevertheless, while PGIM Fixed Income carefully considers the relevant ESG
issues, it believes these factors should always be considered within a broader macroeconomic context
and the issuer’s overall risk profile.
Debt investors are a critical stakeholder for corporate and sovereign issuers reliant on debt financing
markets. PGIM Fixed Income sees issuer engagement as an important tool in its investment process
insofar as it helps PGIM Fixed Income to gain a more holistic understanding of the issuers, from both thefundamental and ESG impact perspectives. PGIM Fixed Income believes that this, in turn, helps it achieve
better investment and, where applicable, ESG outcomes for clients and investors. As a result, PGIM Fixed
Income’s analysts are encouraged to initiate discussions with issuers should an ESG issue surface duringthe research process. During these discussions, PGIM Fixed Income analysts probe management on theESG issues seen as material and assess the issuer’s plans to address them. At times, PGIM Fixed Incomepoints out to issuers PGIM Fixed Income’s assessment of credit-material ESG risks as well as the impacts
that their policies, practices or products have on the environment and society, and where applicablediscuss the implications these may have for their funding costs and future market demand for any newissue bonds.

3The issues on which PGIM Fixed Income engages from a sustainability perspective as described above arelargely the same as those factoring into its fundamental credit analyses. Feedback from these meetings isused to inform PGIM Fixed Income’s fundamental credit ratings and ESG Impact Ratings. The ESG issues
raised, as well as management’s response to the comments (when applicable), are then noted in PGIM
Fixed Income’s engagement notes and can inform our overall analysis of the issuer.
In line with PGIM Fixed Income’s bottom-up, fundamental credit approach, it views issuers’ credit profilesfrom a holistic perspective, rather than separating them into distinct components that must then bereconciled. Therefore, PGIM Fixed Income does not evaluate issuers’ Sustainability Risks in isolation, butinstead integrates them directly into its fundamental credit ratings, and thus into its relative value
assessments. In addition, there is often not a clear demarcation of what should be deemed an “ESG risk”
instead of a “traditional risk.” Indeed, a given ESG factor is usually deemed financially material for anissuer is precisely because it is highly relevant to the issuer’s business model. So, while PGIM Fixed
Income’s portfolio managers are provided with information on Sustainability Risks and take Sustainability
Risks into account when making an investment decision, Sustainability Risk would not by itself prevent
PGIM Fixed Income from making any investment. Instead, Sustainability Risk forms part of the overall
assessment of an issuer’s credit risk, and thus of the assessment of its relative value. PGIM Fixed Income
does not apply any absolute risk limits or risk appetite thresholds which relate exclusively to Sustainability
Risk as a separate category of risk.
− Environmental and Social
The environmental and social factors considered during PGIM Fixed Income’s research assessment,including Sustainability Risks which may cause a material negative impact on the value of potential
investments should those risks occur, will vary depending on the asset class, industry and/or individual
issuer.
The environmental and social potentially considered by PGIM Fixed Income may include, but are notlimited to:Environmental risks, which may materialize through various channels, including but not limited, toreputational damage, litigation, policy costs, input costs, remediation costs, physical damage, operational
disruptions, etc. These risks and potential costs/disruptions may be related to issues such as climatechange; pollution of air, water and land; harm to biodiversity through changes in land use, deforestationand ecosystem damage; energy inefficiency; generation and poor management of hazardous and nonhazardous waste; and high water consumption/withdrawal needs, especially in water stressed areas.
Climate and other environmental risks are considered both from a “transition” risk perspective, which
focuses on the risk to investments as the world moves towards a more sustainable environmental andsocial model, and a “physical” risk perspective, which considers tangible risks due to physical changes in
the natural environment, including but not limited to, hurricanes, flooding, droughts, heatwaves, soildegradation, loss of ecosystem services, water shortages. Social risks, which may also materialize through4

various channels, including but not limited to, reputational damage, litigation, policy costs, recalls, labourcosts, operational disruptions, reduced productivity. These risks and potential costs/disruptions may berelated to issues such as poor occupational health and safety and process safety; poor product safety
and quality; privacy and data security weaknesses; poor labour relations and/or human capitalmanagement, including diversity and inclusion; breaches of employee rights/ labour rights; human rights
violations; child labour/ forced labour; and infringements of rights of local communities/ indigenous
populations.
− Governance
The quality of governance can be an important investment consideration and it is incumbent on PGIM
Fixed Income’s analysts to assess governance structures and practices of the issuers PGIM Fixed Income
considers for investment as part of the credit research process. PGIM Fixed Income’s governance analysis
is asset class and sector specific and may include the following issues: alignment of interests between
management, controlling shareholders and other providers of capital; related party transactions; board
quality, effectiveness and oversight; management incentives; audit and accounting issues; quality of risk
management; business ethics and conduct issues (e.g., bribery and corruption; anti-competitive practices;
and advertising/sales practices); and supply chain sustainability practices. Analysts are also required toassess certain issuers against four key themes of good governance (sound management structures,
employee relations, remuneration of staff and tax compliance. This assessment is required only forinvestee companies (including corporate issuers and quasi-sovereigns).
PQS
PQS offers a broad array of investment management services, including quantitative equity and global
multi-asset strategies that invest across a range of asset classes. PQS’ goal is to meet client investment
objectives by closely managing portfolio exposure to expected risk and return.
ALTHOUGH PQS CONSIDERS A VARIETY OF ESG FACTORS ACROSS ITS STRATEGIES, CURRENTLY, PQS
DOES NOT INTEGRATE SUSTAINABILITY RISKS INTO ITS INVESTMENT DECISION MAKING PROCESS FORANY FUND THAT IT MANAGES BECAUSE THE RELEVANT ALGORITHM UNDERLYING THE FUND WAS
NOT CONSTRUCTED TAKING INTO ACCOUNT MATTERS SUCH AS SUSTAINABILITY RISKS.
PPCPPC originates investments on behalf of its clients primarily in private credit.
Currently PPC does not integrate Sustainability Risks into its investment decision making for the Fund it
manages because the Fund is no longer open for investment nor is it making investments.

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DISCLOSURE
The SFDR requires the AIFM to publish on a website information about its policies on the integration ofSustainability Risks in the investment decision-making process. The AIFM satisfies this requirement bydisclosing this Sustainability Risks Integration Statement on a website for the purposes of, and inaccordance with, Article 3 of the SFDR.
APPROVAL AND REVIEWThis Sustainability Risks Integration Statement has been approved by the AIFM, is effective from 13
December 2023 and will be reviewed on an annual basis by the AIFM and updated, as necessary, for any
changes or new arrangements.

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