FCM Frederic Capital Management GP S.à r.l., LEI: 529900UME8AQN69CGH66, is an alternative investment fund manager within the meaning of the Luxembourg act of 12 July 2013 on alternative investment fund managers (the “AIFM Law”) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).

Article 3 SFDR – Sustainability Risk Policies Statement

FCM Frederic Capital Management GP S.à r.l. addresses sustainability risks in its investment decision-making process insofar as relevant. “Sustainability risk” 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.

During the due diligence on potential investments, FCM Frederic Capital Management GP S.à r.l. conducts a careful analysis of the investment’s exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, FCM Frederic Capital Management GP S.à r.l. decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk.

FCM Frederic Capital Management GP S.à r.l. regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.

Article 4 SFDR – No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors

FCM Frederic Capital Management GP S.à r.l. does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters.

The standardized catalog of PAI indicators (“PAII”) provided in Annex I of the regulatory technical standards issued under the SFDR is not tailored to the specific needs of the investment strategy of FCM Frederic Capital Management GP S.à r.l.

Many target funds and portfolio companies neither systematically collect PAII nor are they legally required to do so, and they often lack the internal resources to implement such reporting.

As a result, the available data is generally insufficient for meaningful PAI analysis, and on occasions where data is obtainable, it tends to offer little in terms of comparability and fails to provide additional insights for FCM Frederic Capital Management GP S.à r.l. Therefore, collecting data on PAII will not only increase the administrative burden and costs but also fail to provide a new perspective for FCM Frederic Capital Management GP S.à r.l.

FCM Frederic Capital Management GP S.à r.l. is open to considering PAI in the future if it becomes evident that doing so would significantly enhance the ability of FCM Frederic Capital Management GP S.à r.l. to identify and mitigate possible adverse impacts of the investments while maintaining operational efficiency and cost-effectiveness.

Article 5 SFDR – Remuneration Disclosure

As a registered alternative investment fund manager within the meaning of the AIFM Law, FCM Frederic Capital Management GP S.à r.l. does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the AIFM Law. Sustainability risks are not considered with respect to the determination of remuneration.