No Consideration of Sustainability Adverse Impacts

IK Investment Partners AIFM, together with IK Investment Partners Limited and their principal group companies (“IK”), will consider ESG factors as part of the Fund’s investment process but, at this stage, will not consider adverse impacts of investment decisions on “sustainability factors” as specifically contemplated by the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (“SFDR”). IK has elected not to do so at the present time as it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategies of its funds.

IK continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance.

IK intends to work towards considering adverse impacts of investment decisions on sustainability factors, as prescribed by the SFDR, in due course.

Date: 10 March 2021