PCA PARTNERS

PCA Partners S.à r.l., operates as alternative  investment fund manager register with the Commission de Surveillance du Secteur Financier (CSSF) (the “AIFM”) .

In compliance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the “SFDR”), the AIFM provides the following disclosures:

Policy on Sustainability Risks:

Pursuant to Article 3, 4 and 5 of the SFDR, the AIFM is required to publishes information concerning its policies regarding the integration of sustainability risks policy and principal adverse impact policy in its activity.

Investment Objective and ESG Characteristics:

The alternative investment funds (AIFs) managed by the AIFM do not prioritize sustainable investments as their investment objective, nor do they endorse ESG characteristics, in accordance with Articles 8 and 9 of SFDR (the "AIF"). ESG considerations are not mandatory for the investment decision-making process. However, although the investment policy of the AIFs does not explicitly prioritize sustainable investments or ESG criteria, it is acknowledged that certain underlying investments may have connections with sustainable investments and/or ESG, which are not expressly factored into the investment process. The investments underlying these AIFs do not align with the EU criteria for environmentally sustainable economic activities, as specified by the Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment and amending the SFDR (the “Taxonomy Regulation”).

Principal adverse impacts:

The AIFM does not take into account principal adverse impacts at the level of the investment processes of the AIFs it manages as their investment policies do not promote any environmental and/or social characteristics and there are risks of greenwashing and financial risks relating to greenwashing. However, the AIFM would also pay particular attention if and when the AIFs it manage would express their wish to have an ESG targets integrated in the future in the investment objectives