Home Investment Trusts Alternative UCITS Our Team Careers Contact Newsletter ESG and Sustainability Policy Introduction and Purpose This document sets out how Kepler intends to implement Environmental, Social and Governance (“ESG”) initiatives within the firm’s operating model. Kepler must implement appropriate policies and procedures, where appropriate, to integrate ESG considerations into its investment decision-making or advisory processes in order to make investments more sustainable. ESG frameworks seek to ensure a harmonised transparency regime to provide investors with a uniform standard to compare financial products for their ESG risks and sustainable investment objectives. The integration of ESG considerations into investment management processes and ownership practices are done so in the belief that these factors can have an impact on financial performance. ESG processes and procedures focus on non-financial performance indicators that address a company’s approach towards responsible investment, sustainability, its impact on society and the environment, as well as other ethical and corporate governance considerations. Definition ESG or sustainable investments mean any of the following or a combination of any of the following: Environmental (E) investments in an economic activity that contributes to an environmental objective that relate to the quality and functioning of the natural environment and natural systems; Social (S) investment in an economic activity that contributes to a social objective, and that relate to the rights, well-being and interests of people and communities; and Governance (G) issues relate to investments in companies following good governance practices and in particular companies with sound management structures, employee relations, remuneration of relevant staff and tax compliance. Sustainability risk is an ESG event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. Principal adverse impacts are impacts of investment decisions and advice that result in negative effects on ESG factors. Application This policy applies to Kepler when providing investment management or advisory services to its clients. Policy Kepler will adopt the following overarching policies relating to business conducted and ensure it is published on the firm’s website. Corporate Governance The Management Committee of Kepler takes ultimate responsibility under its terms of reference for ensuring sustainability risks are embedded within organisational procedures, systems and controls to ensure that they are properly taken into account in the investment and risk management processes. The governing body will be responsible for ensuring that adequate resource and expertise is allocated within the firm for the integration of ESG risks. The Management Committee will be responsible for the identification, recording, management and where necessary disclosure of conflicts of interest relating to the integration of ESG risks and factors in accordance with Kepler’s Conflicts of Interest Policy. A Senior Partner(s) will be allocated responsibility with their individual Statement of Responsibilities for the integration of ESG risks throughout the business model. Product Governance Kepler will, where relevant, ensure ESG factors are taken into account when identifying the target market and within the product review process. Where the firm has concerns over the ESG practices of an issuer or its industry or market sector or considers that there is a higher likelihood of sustainability risks materialising during the period where its Funds might be exposed to an investment than in other potential investments being considered for investment by the Fund, this may impact upon Kepler’s decision of whether to pursue a particular proposed investment opportunity. Investment and Due Diligence Kepler shall factor in ESG risks when selecting and monitoring investments. ESG risks will be taken into consideration, where appropriate, when making investment decisions or proving investment advice. Where applicable, Kepler shall develop engagement strategies, including for the exercise of voting rights, where available, with a view to reducing the principal adverse impact of investee companies on sustainability factors. Disclosure Kepler will disclose how ESG risks are integrated in the investment decision- making and advisory process on its website. It will disclose the integration of sustainability risks to potential investors in its pre-contractual information and will provide periodic reports to investors on the contribution of investment decisions to the sustainable investment objectives and on how the investment strategy is aligned with the sustainable investment objectives. Sustainability risks will continue to be assessed when evaluating long-term investment decisions, but less consistently when evaluating short-term trading ideas. This reflects the fact that sustainability risks will generally be most relevant the longer is the time horizon. Annual Assessment and Review The firm shall ensure that any information published as per above is kept up to date. Any amendments made shall require a clear explanation of this on the website. Pre-contractual Disclosure Kepler will ensure that appropriate disclosure is included in client/investor documents which are made available for receipt and review prior to investment. For example, the prospectus for a fund in accordance with the AIF/UCITS requirements and/or pre-investment material under MiFID II concerning portfolio management and/or advisory services. Kepler shall use any relevant ESA approved templates in order to meet this requirement. Periodic Reporting In addition to the ongoing internal monitoring of adherence to this policy, Kepler will describe in its periodic reports to investors the sustainability-related impact of the investments by means of relevant indicators. Kepler shall use any relevant ESA approved templates in order to meet this requirement. Last Update: March 2021 © Kepler Partners, 2014 - 2021. Authorised and Regulated by the Financial Conduct Authority. 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