SFDR Disclosure

Atlan Management GmbH (“Atlan”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).

Art. 3 SFDR - Sustainability risk policies statement

Atlan addresses sustainability risks in its investment decision-making process if and to the extent relevant. ‘Sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment of the Partnership. Considering the Partnership’s investment strategy, Atlan expects sustainability risks not to be relevant in most cases. Where relevant, Atlan will apply reasonable efforts to appropriately assess such risks and their potential impacts. Atlan regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.

Art. 4 SFDR - No consideration of principal adverse impacts

Atlan does not consider principal adverse impacts of investment decisions on sustainability factors. ‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Atlan does not use sustainability indicators. Considering the numerous legal uncertainties currently related to the application of the provisions of the SFDR and the Regulatory Technical Standards (“RTS”) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, Atlan is not in a position to commit to such standard in light of its fiduciary duty to the fund and its investors. Atlan will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to Atlan.

Art. 5 - Renumeration Disclosure

As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB), Atlan does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.