SFDR Disclosure

Per SFDR definitions, the firm does not consider the adverse impacts of investment decisions on sustainability factors: Whilst the firm consistently considers potential environmental, social and governance factors (both positive and negative) in its investments, our primary goal is to seek to achieve attractive risk-adjusted returns for investors from the full set of opportunities available to us, as part of which we consider ESG risks to be important factors to which we give due weight. We therefore do not seek to avoid or minimise principal adverse impacts of our investment decisions on sustainability factors as part of our investment decision making process, and hence we consider the firm as coming under the SFDR category of “does not consider impacts on sustainability factors”, and our SFDR disclosures vary as a result of this.

Sustainable Remuneration Policy: We are committed to the integration of sustainability risks in our firmwide activities, hence our pay strategy also reflects this, including a required consideration of what each person has done as regards ESG (both in our investing activities and in our corporate activities) in their annual self-assessment that is used (among other inputs) for determining promotions, salary reviews and discretionary pay. In particular, as regards members of the investment team, our strategies are designed to optimise financial results for our investors, and therefore we actively seek to avoid taking on risks (including ESG risks) that may compromise investors’ long-term interests. Taking ESG factors into account is thus an important part of our goal of long-term sustainable financial performance, which is a core component of determining remuneration.

 Our remuneration strategy includes the following pillars:

·         Risk management: Our risk management processes seek to ensure that ESG factors are considered in assessments of investment risks. Our compensation policies contribute to ESG consideration through discouraging risks that undermine the goal of sustainable long-term financial performance, in particular through those policies’ link to pay, including bonuses.

·         Team pay: Our policies and procedures seek for team members’ pay to reflect (among other factors) consideration for and integration of sustainability metrics. This helps us to strengthen and achieve our ESG goals by making such commitments a component of staff assessment across the firm.

·         Gender pay gap: We are committed to hiring and retaining more women across our firm. We are also dedicated to ensuring our team members receive fair pay, and our policies support equality in this regard. Our periodic reviews assess pay equity for comparable roles, to ensure this pillar is central to our remuneration policies and procedures.

·         Periodic assessment: The above are reviewed and assessed periodically. We ensure our metrics are relevant, up-to-date and accurate, and our ESG Remuneration Strategy is integrated into annual financial statements.

For further information on the Firm’s approach with respect to sustainability, ESG or other matters, please contact:

Edgar Senior, CEO

edgar.senior@tresidor.com