Sustainability Risk Disclosures (SFDR)

1. Sustainability Risk Integration Policy (Article 3 “SFDR”)

The Company integrates sustainability risks into its overall risk management framework in accordance with applicable sustainability-related disclosure rules. A sustainability risk is an ESG event or condition that could cause a material negative impact on the value of an investment.

As the Company does not offer financial instruments that pursue sustainable investment objectives or promote ESG characteristics, sustainability risks are considered at governance level and are not a primary product feature.

2. Target Market & Clients Seeking Sustainable Investments

The Company does not currently offer financial instruments that qualify as sustainable investments or that promote ESG characteristics. Clients who seek sustainable or ESG-focused investments fall outside the Company’s identified target market.

3. Remuneration Policy & Sustainability Risks (Article 5 “SFDR”)

The Company ensures that remuneration policies and practices are consistent with the integration of sustainability risks and do not encourage excessive sustainability risk-taking.