Concorde Manager S.à r.l. – Disclosures

We do not assess Environmental, Social and Governance (“ESG”) Factors that may have investment ramifications, and which may have a material impact on the investment’s long-term financial performance. As a result, information on ESG Factors does not form part of our investment recommendation/decision making process.

Negative and positive screening

We will actively engage with our clients to understand whether they have concerns about specific activities and / or industries in order to maintain such exclusions on an on-going basis.

In such cases, we undertake, to the extent possible, to screen target entities and / or products that promote and provide solutions that are consistent with ESG Factors and shall aim at recommending and / or investing in such on an on-going basis, in so far as applicable.

Exclusions

We will not knowingly invest in companies involved in the following activities:

• Arms manufacturing.
• Manufacture of tobacco.
• Hard spirits.
• Gambling.
• Genetically modified organisms.

We will assess these types of investments on a case-by-case basis and any potential for indirect exposure is carefully considered and factored into investment selection.

We will also not invest or limitedly invest in certain sectors or companies whose products, services or activities could be considered contrary to the current trends regarding the promotion of ESG criteria based on the following internationally recognized guidelines and principles:

• The UN Global Compact;
• The OECD Guidelines for Multinational Enterprises;
• The United Nations Guiding Principles on Business and Human Rights;
• The Ottawa Convention (international agreement on the prohibition of anti-personnel mines); and
• The Convention on Cluster Munitions.

Principle Adverse Impacts

We do not undertake an assessment of the Principal Adverse Impacts (“PAIs”) of our decisions on ESG Factors. PAIs are those impacts arising from a particular decision taken which we take that will eventually have a negativ1e effect on ESG Factors.

Alignment of Remuneration provisions with sustainability investments

Whilst the Company does not currently have any employees, no variable remuneration is paid to individual personnel providing services to the Company, unless it is determined to be justified following a performance assessment based on quantitative (financial) as well as qualitative (non-financial) criteria.

Due to this very limited impact on the risk-profile of our clients, as well as the nature of our business, we deem that there is no risk of misalignment with the integration of the sustainability risks, if any, in our investment decision making process.

As such, we believe that our existing structures are sufficient to prevent excessive risk taking in respect of sustainability risks, if any.

Kindly contact info@concordeimg.com for a full copy of our ESG Policy.