SFDR Disclosures

Sustainability Risks in the investment process of Vescalis Capital Management S.à r.l. (VCM)

These disclosures are made pursuant to the EU Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (the "SFDR").

Art. 3 Integration of sustainability risks in the investment process

VCM believes that sustainability risks can threaten the investments at individual asset level and portfolio level underlying the funds it manages. In accordance with the SFDR, "sustainability risks" refers to an environmental, social or governance event or condition that, if it occurs, may cause an actual or potential material negative impact on the value of the investment.

The sustainability risks assessment covers (ESG):

Environmental Factors (E)

Environmental considerations may include, but are not limited to, the following aspects:

• Climate change mitigation;
• Climate change adaptation;
• Protection and preservation of biodiversity and ecosystems;
• Sustainable use and protection of water and marine resources;
• Transition to a circular economy, including waste prevention, reduction and recycling;
• Prevention and reduction of environmental pollution;
• Conservation and restoration of healthy and functional ecosystems;
• Sustainable land use and responsible natural resource management.

Social Factors (S)

Social considerations may include, but are not limited to:

• Compliance with internationally recognized labour standards (including the prohibition of child labour, forced labour and discrimination);
• Compliance with occupational health, safety and welfare standards;
• Fair and appropriate remuneration, equitable working conditions, equal opportunities, diversity, and access to training and development;
• Respect for trade union rights and freedom of association;
• Ensuring adequate product quality and safety standards, including consumer health protection;
• Application of equivalent social standards throughout the value and supply chain;
• Promotion of inclusive initiatives taking into account the interests of local communities and social minorities.

Governance Factors (G)

Governance considerations may include, but are not limited to:

• Responsible, fair and transparent tax practices;
• Implementation of effective anti-corruption and anti-bribery measures;
• Board-level accountability for sustainability matters;
• Executive and board remuneration structures aligned with long-term sustainability objectives;
• Internal mechanisms to enable secure and confidential whistleblowing;
• Respect and protection of employee rights;
• Protection and responsible processing of personal data;
• Transparent, accurate and timely disclosure of information.

VCM has applied in its investment decisions-making process the sustainability risks and has a dedicated team who are assessing and processes in place to assess any risks affecting the investment arising from sustainability issues in the macro environment.

Sustainability risks are considered by applying an appropriate due diligence process in accordance with the characteristics of each relevant product and assessed by a team with the required level expertise. VCM will make sure that procedures are implemented to integrate adequately the sustainability risks into the investment advice.

Art 4: No consideration of sustainability adverse impacts

At this stage, VCM does not consider principal adverse impacts of investment decisions on sustainability factors at entity level, in accordance with Article 4(1)(b) of Regulation (EU) 2019/2088, due to the current size, resources and data availability constraints. VCM continuously monitors the evolving regulatory and operational framework and may reconsider this position in the future.