1. Sustainability Risk Policy (Article 3 SFDR)

AQ1443 Lux Sàrl (the “AIFM”) is authorised by the Commission de Surveillance du Secteur Financier (the “CSSF”) as an alternative investment fund manager within the meaning of the Luxembourg law of 12 July 2013, as amended. As a financial market participant within the meaning of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”), the AIFM is required to publish information on the manner in which sustainability risks are integrated into its investment decision-making process.

For the purposes of SFDR, a sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

Integration of sustainability risks

The AIFM has adopted a Sustainability Risk Policy that forms part of its broader risk management framework. The policy applies to all investment decisions taken by the AIFM in respect of each alternative investment fund it manages and is reviewed at least annually.

Sustainability risk assessment is carried out on a fund-by-fund basis. The AIFM determines, in respect of each fund it manages, whether sustainability risks are likely to be relevant to the returns of that fund having regard to:

• the investment strategy, asset class and target geographies of the fund;
• the sectors and types of underlying issuers in which the fund invests;
• the typical holding period and liquidity profile of investments;
• the AIFM’s overall risk appetite and the risk profile agreed with the fund’s investors.

Where sustainability risks are determined to be relevant, they are integrated into pre-investment due diligence, investment committee deliberations and ongoing portfolio monitoring. Findings are documented in the investment memorandum prepared in respect of each transaction. Where, in the AIFM’s reasonable assessment, sustainability risks are not likely to have a material impact on the returns of a particular fund, the reasons for that determination are recorded and disclosed in the relevant fund’s pre-contractual information.

Governance

Responsibility for the Sustainability Risk Policy sits with the AIFM’s Conducting Officers. The Risk Management function is responsible for monitoring sustainability risk exposure and for escalating material findings to the Conducting Officers and, where appropriate, to the AIFM’s board of managers. Where the AIFM has appointed an investment adviser in respect of a particular fund, the AIFM remains solely responsible for sustainability risk integration and retains final decision-making authority over all investment and divestment decisions.

Review

The Sustainability Risk Policy is reviewed at least annually and on an ad hoc basis where there is a material change in the AIFM’s activities, the regulatory framework or the funds under management. Material updates to this disclosure will be reflected on this webpage and prior versions will be archived.

Last reviewed: 8th May 2026

2. Statement on Principal Adverse Impacts (Article 4 SFDR)

AQ1443 Lux Sàrl does not consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors within the meaning of Article 4(1)(b) of SFDR.

Reasons

The AIFM is not required to consider principal adverse impacts at entity level under Article 4(3) or Article 4(4) SFDR. Those provisions apply only to financial market participants which, as at their balance sheet date, exceed the criterion of an average of 500 employees during the financial year (including, where relevant, on a consolidated group basis). The AIFM does not exceed that threshold and is not part of a group that exceeds that threshold. Accordingly, the AIFM falls within the “comply or explain” regime in Article 4(1)(b) SFDR and has determined, on the basis set out below, not to consider principal adverse impacts at entity level.

First, the size and resourcing of the AIFM are not such as to make entity-level PAI reporting proportionate. The AIFM is a specialist alternative investment fund manager with a small headcount that is well below the 500-employee threshold referred to in Article 4(3) and Article 4(4) SFDR. Article 4 SFDR is calibrated so that the obligation to consider PAIs at entity level applies on a mandatory basis only to financial market participants above that threshold. The AIFM considers that the operational and cost burden of producing, monitoring and assuring a complete entity-level PAI statement, including all mandatory and applicable additional indicators set out in Annex I to Commission Delegated Regulation (EU) 2022/1288 (the “SFDR RTS”), is disproportionate to the benefits that such a statement would provide to investors at this stage.

Second, the funds under management invest predominantly in unlisted companies and other non-listed assets in respect of which the mandatory PAI indicators set out in Annex I to the SFDR RTS are, in the AIFM’s reasonable assessment, not currently available to a level of quality, completeness, comparability and verifiability sufficient to support meaningful entity-level reporting. The AIFM does not regard estimated, modelled or proxy data as a satisfactory substitute for primary issuer-reported data for the purposes of an entity-level PAI statement.

Third, the AIFM’s investor base is composed exclusively of professional investors who, in the AIFM’s experience, conduct their own sustainability due diligence at the level of the individual fund and the underlying portfolio rather than relying on aggregated entity-level statistics.

Future review

The AIFM will keep this position under review. In particular, if the AIFM (or any group of which it forms part for the purposes of Article 4(3) or Article 4(4) SFDR) at any time exceeds the 500-employee threshold, the AIFM will be required to, and will, consider principal adverse impacts at entity level and publish a statement in the form prescribed by the SFDR RTS. Independently of that threshold, the AIFM will reconsider its current position if there is a material change in the size or scope of the AIFM’s activities, in the availability or quality of PAI data, or in the regulatory framework applicable to the AIFM. Any change in position will be reflected in an updated statement published on this webpage.

Product-level information

This statement is made at the level of the AIFM. Information on whether PAIs are considered at the level of an individual fund is set out in the pre-contractual information of that fund and, where applicable, on the dedicated sustainability-related disclosures page of that fund.

Last reviewed: 8th May 2026

3. Remuneration Policy and Sustainability Risks (Article 5 SFDR)

Article 5 of SFDR requires financial market participants to publish information on how their remuneration policy is consistent with the integration of sustainability risks.

AQ1443 Lux Sàrl has adopted a Remuneration Policy in accordance with the requirements of the Luxembourg law of 12 July 2013, as amended, and the AIFMD remuneration guidelines issued by ESMA. The Remuneration Policy applies to all staff of the AIFM whose professional activities have a material impact on the risk profile of the AIFM or the funds it manages, including its Conducting Officers and members of senior management.

Consistency with sustainability risk integration

The Remuneration Policy is designed to be consistent with the integration of sustainability risks in the following respects:

• Variable remuneration is not awarded in a manner that incentivises excessive risk-taking, including excessive sustainability risk-taking. The award of variable remuneration takes account of the AIFM’s overall risk profile, including, where relevant, the AIFM’s exposure to sustainability risks.
• Compliance with the AIFM’s policies and procedures, including its Sustainability Risk Policy, is a condition of the award and payment of variable remuneration to relevant staff. Material breaches may result in a reduction or forfeiture of variable remuneration in accordance with the malus and clawback provisions of the Remuneration Policy.
• Performance assessment of relevant staff includes both quantitative and qualitative criteria. Qualitative criteria include adherence to the AIFM’s risk management framework as a whole, of which sustainability risk integration forms part.
• The Remuneration Policy is structured to ensure an appropriate balance between fixed and variable remuneration so that staff are not financially dependent on the award of variable remuneration to such an extent that prudent risk-taking — including in respect of sustainability risks — could be compromised.

Governance and review

The Remuneration Policy is approved by the AIFM’s board of managers and is reviewed at least annually. The implementation of the Remuneration Policy is subject to an independent internal review at least annually. Any material amendment to the Remuneration Policy is approved by the board of managers.

Last reviewed: 8th May 2026