The European Commission’s Sustainable Action Plan has three objectives: (1) To reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth; (2) To manage financial risks stemming from climate change, environmental degradation, and social issues; and (3) To foster transparency and long-termism in financial and economic activity. It is a response to recommendations from the high-level expert group on sustainable finance, which were submitted to the Commission in January 2018.

Already, the European Parliament has adopted an amendment to Regulation 2016/1011 to introduce a framework for EU climate transition and EU Paris-aligned benchmarks, an amendment to the Delegated Regulation 2017/565 to integrate environmental, social, and governance (ESG) considerations into investment advice and portfolio management, and an amendment to Delegated Regulation (EU) 2017/2359 to integrate ESG considerations and preferences into the investment advice for insurance-based investment products. It has also prepared a series of related reports, including an EU Taxonomy Regulation, benchmarks, EU green bond standard, and climate-related disclosures.

SFDR which is part of a broader legislative package under the European Commission’s Sustainable Action Plan, came into effect on 10 March 2021. To meet the SFDR disclosure requirements, PREMIUM CAPITAL MANAGEMENT Sàrl identifies, assesses and, where possible and appropriate, seeks to manage sustainability risks for the Partnership as part of its risk management process. PREMIUM CAPITAL MANAGEMENT Sàrl believes that the integration of this risk analysis could help to enhance the long-term value of the portfolio for Investors, in accordance with the investment objective and Investment Policy of the Partnership. However, due to the nature of the investment objective, sustainability risks are not integrated in the investment decisions.

For the avoidance of doubt, the Partnership is not promoting environmental or social characteristics within the meaning of article 8 of SFDR nor has sustainable investment as its objective within the meaning of article 9 of SFDR. For the purposes of Article 6 of the EU Taxonomy Regulation, PREMIUM CAPITAL MANAGEMENT Sàrl confirms that the investments underlying this financial product (i.e. the Partnership) do not take into account the EU criteria for environmentally sustainable economic activities.

As regards disclosures obligations under article 4(1) of SFDR it is confirmed that PREMIUM CAPITAL MANAGEMENT Sàrl does not take into account the negative impacts due to investments - Article 4 (1) (b).