ESG Policy

Terra Partners Asset Management Limited (the “Company”) generally pays due regard to environmental, social and governance (“ESG”) considerations when entering into or holding an Investment. However, these considerations are integrated within the holistic analysis of an Investment, and the deliberation of ESG considerations is not formalized in the manner that is considered by the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”). Therefore, for the purposes of SFDR, TPAM does not formally consider adverse impacts of investment decisions on sustainability factors (and the Company does not directly link the remuneration of its staff with sustainability factors), although it will continue reviewing and considering SFDR adherence for one (1) or more of its clients.