SUSTAINABLE FINANCE
DISCLOSURES REQUIREMENTS

The European Commission's Sustainable Action Plan has three objectives: (1) To reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth; (2) To manage financial risks stemming from climate change, environmental degradation, and social issues; and (3) To foster transparency and long-termism in financial and economic activity. It is a response to recommendations from the high-level expert group on sustainable finance, which were formed by a Commission in 2016 with the purpose to produce policy recommendations for the development of the EU sustainable finance strategy and its action plan. The purpose of this regulation was to assist the EU in transforming its economy and financial system to a more sustainable model, enabling the achievement of policy goals set out in the European Green Deal.

Already, the European Parliament has adopted an amendment to Regulation 2016/1011 to introduce a framework for EU climate transition and EU Paris-aligned benchmarks, an amendment to the Delegated Regulation 2017/565 to integrate environmental, social, and governance (ESG) considerations into investment advice and portfolio management, and an amendment to Delegated Regulation (EU) 2017/2359 to integrate ESG considerations and preferences into the investment advice for insurance-based investment products. The Sustainable Finance Disclosure Regulation ("SFDR") applies to financial market participants and financial advisors, while the complementary Taxonomy Regulation seeks to establish criteria to determine whether an economic activity qualifies as environmentally sustainable.

SFDR which is part of a broader legislative package under the European Commission's Sustainable Action Plan, came into effect on 10 March 2021. To meet the SFDR disclosure requirements, EPITOME MANAGEMENT identifies, assesses and, where possible and appropriate, seeks to manage sustainability risks for the Partnership as part of its risk management process. EPITOME MANAGEMENT believes that the integration of this risk analysis could help to enhance the long-term value of the portfolio and lead to better risk-adjusted returns for its investors. However, there can be no guarantee that the incorporation of sustainability risks will enhance the overall returns of the Partnership.

For the avoidance of doubt, the Partnership is not promoting environmental or social characteristics within the meaning of article 8 of SFDR nor has sustainable investment as its objective within the meaning of article 9 of SFDR. For the purposes of Article 6 of the EU Taxonomy Regulation, the AIFM confirms that the investments underlying this financial product (i.e. the Partnership) do not take into account the EU criteria for environmentally sustainable economic activities.

As regards disclosures obligations under article 4(1) of SFDR it is confirmed that EPITOME MANAGEMENT does not take into account the negative impacts due to investments - Article 4 (1) (b).

-----

Epitome Management Sarl
2C, Parc d'Activités, L-8308 Capellen, Grand Duché de Luxembourg
RCSL registration number: B279828

info@epitome.fund
+352 277 295 91