SFDR mandatory disclosures

Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (SFDR):

I. Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)

FCM Frederic Capital Management GP S.à r.l. („FCM S.à r.l.“) is a long-term investor, that is well aware of its environmental, social and governance (ESG) duties towards stakeholders. Accordingly, ESG criteria are taken into account in all investment decisions insofar as relevant for the respective investment. When considering investment opportunities FCM S.à r.l. will conduct an ESG due diligence according to its ESG policy to assess the potential sustainability risks. Sustainability risk under the SFDR means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

However, FCM S.à r.l. generally does not strive to promote environmental or social characteristics or to make sustainable investments as specified by Art. 8 or 9 SFDR.

II. No consideration of sustainability adverse impacts (Article 4 SFDR)

Art. 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors as defined in the SFDR. For this purpose, financial market participants such as FCM S.à r.l. must disclose certain information (presumably from July 2022 on taking into account the Regulatory Technical Standards (RTS)). FCM S.à r.l.believes that the information provided to them by the target funds and portfolio companies in relation to the investments is not yet sufficient (in particular with a view to the comprehensive requirements of the RTS) to allow them to do so. Currently, it must be assumed that FCM S.à r.l. does not yet take into account any principle adverse impact of investment decisions on sustainability factors in terms of Art. 4 SFDR. However, FCM S.à r.l. will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Art. 4 SFDR-framework (including the future RTS).

III. Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)

According to Art. 5 SFDR financial market participants have to include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks. As a registered AIFM within the meaning of Art. 2 AIFM law, FCM S.à r.l. does not have a remuneration guideline (remuneration policy) in accordance with the requirements of Art. 3 AIFM law. Accordingly, no information can be provided on the consistency of a remuneration policy with the integration of sustainability risks.