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AMI Capital Partners S.A.

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector, as amended (SFDR)

AMI Capital Partners S.A., a public limited liability company (société anonyme) incorporated under the laws of the Grand Duchy of Luxembourg, having its registered office at 16, rue Eugène Ruppert, L-2453 Luxembourg, Grand Duchy of Luxembourg and registered with the Register of Trade and Companies of Luxembourg (Registre de Commerce et des Sociétés de Luxembourg), under number B308173, as a financial market participant under SFDR (the FMP), makes the following disclosures in accordance with and pursuant to, article 3, article 4 and article 5 of SFDR.

Pursuant to the SFDR, the FMP is required to publish information about its policies on the integration of Sustainability Risks in their investment decision-making process. A “Sustainability Risk” is an environmental, social or governance event or condition that, if it occurred, could cause an actual or a potential material negative impact on the value of the investments concerned by the FMP’s investment decision. Sustainability Risks are principally linked to climate-related events resulting from climate change or to the society's response to climate change, which may result in unanticipated losses that could affect investments and financial position. Social events (e.g. inequality, inclusiveness, labour relations, investment in human capital, accident prevention, changing customer behaviour, etc.) or governance shortcomings (e.g. recurrent significant breach of international agreements, bribery issues, products quality and safety, selling practices, etc.) may also translate into Sustainability Risks. Such Sustainability Risks are only integrated into the investment decision making of the FMP from a risk monitoring perspective to the extent that they represent a potential or actual material risks and/or opportunities to maximizing the long-term risk-adjusted returns. The impacts following the occurrence of a Sustainability Risk may be numerous and vary depending on the specific risk, region and asset class and other features of the financial product(s) managed by the FMP. In general, where a Sustainability Risk occurs in respect of an asset, there could be a negative impact on, or entire loss of, its value. It is expected that the financial product(s) managed by the FMP will be exposed to a broad range of Sustainability Risks which will differ from an investment to another and a financial product to another. For example. some markets and sectors will have greater exposure to Sustainability Risks than others will.

The FMP does not consider the principal adverse impacts of its investment decisions on sustainability factors (as defined under SFDR) (the PAI), as the FMP considers that such PAI cannot be clearly and correctly quantified and duly taken into account both in consideration of a proportionality criteria (size, nature and scale of the activities of the FMP) and the general lack of readily available data within the investment universe of the financial product(s) managed by the FMP to consider many of the technical reporting requirements of the PAI. For the avoidance of doubt, the FMP keeps this position under review.

The FMP pays its staff in accordance with remuneration policies which take into account compliance with its internal risk management framework and internal policies, including those relating to the integration of Sustainability Risks. In this regard, the FMP’s remuneration policies do not encourage risk-taking which is inconsistent with its internal risk limits or with the risk profile of the financial product(s) managed by the FMP, including regarding Sustainability Risks stemming in particular from climate-related events or from the society’s response to climate change.