Disclosure of Climate-related Risks by Fund Manager

May 2023

Governance of Climate-related Risks

The Company’s governance structure consists of oversight of climate-related risks at the Board level and the implementation of climate-related risk management policies and practices at the management level.

The Board is responsible for overseeing the incorporation of climate-related risks into the investment management and risk management process of the Fund. The board reviews the Risk Management Policy, which provides a framework for managing key risks, including climate-related risks at least annually. In particular, the Board receives annual updates from management to oversee progress and stay informed on climate-related risk management.

Management is accountable for the incorporation of climate-related risks into the investment management, risk management and disclosure process. In particular, the responsibilities for managing climate-related risks have been assigned to the COO that reports to the Board periodically. Management will monitor the status and progress of efforts to manage climate-related risks.

Identification and Assessment of Climate-related Risks

The Company identifies climate-related risks by reviewing the Fund(s)’s investment strategies and determining if climate-related risks are relevant. In particular, the Company reviews for relevance of climate-related risks at least annually by completing a relevance assessment based on strategies for which climate-related risks are typically considered relevant or irrelevant, which is reviewed by the COO. The Company has determined climate-related risks are relevant.

The Company conducts a further assessment by using a qualitative method to determine if climate-related risks are material for the Fund(s) at least annually by completing a materiality assessment based on proportion of holdings in industries or geographic areas subject to high climate-related risks, which is reviewed by the COO The company has determined that climate-related risks are not material.

The method of assessing relevance and materiality of climate-related risks require subjective judgements and may include consideration of third-party data that is incomplete or inaccurate. The assessment methodology may change or evolve over time. Relevance and materiality have been assessed based on certain qualitative and quantitative factors concerning the strategy as well as industry practices and subjective estimates, which may change. Any such changes may affect the assessment conclusions and previous assessments may no longer remain valid. There can be no guarantee that the Company will correctly identify and assess the impact of climate-related risks associated with its asset management activity.