In order to comply with the sustainable finance disclosure regulation (SFDR), Valemount Management B.V. (Valemount) makes the following disclosures.

Integration of sustainability risks

A sustainability risk means "an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment".

Before any investment decisions are made on behalf of a fund that Valemount manages, an investment decision process is followed which in regard to specific investments includes the approval of the board. Part of the investment decisions process is that Valemount assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are considered by Valemount when making investment decisions.

In addition, Valemount pays staff a combination of fixed remuneration and variable remuneration (including a possible bonus). Variable remuneration for relevant staff also takes into account compliance with all policies and procedures which are in effect within Valemount, including those relating to taking into account sustainability risks on the investment decision making process.

Employees are made aware of the applicable policies and procedures when starting their employment with Valemount.

Classification

Valemount has classified the current fund (the Fund) as an "investment vehicle without durable characteristics or aims (Article 6 SFDR)" based on the SFDR.

No consideration of sustainability adverse impacts

In accordance with article 4 sub 1 (b) of the SFDR, Valemount states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR. Given the small size of the organisation of Valemount, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.

Note 1: Regulation (EU) 2019/2088

Valemount Management B.V.

De Lind 39
5061 HT Oisterwijk

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