Sustainable Finance Disclosure Regulation

Last updated: May 2025  |  Grand Duchy of Luxembourg

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Fundequate Management S.a r.l. ("the Manager") acts as registered alternative investment fund manager pursuant to Article 3(2) of the Luxembourg Law of 12 July 2013 on alternative investment fund managers, providing fund management services to alternative investment fund vehicles accessible through the AlterLegacy platform. AlterLegacy Sarl operates the technology platform and does not itself constitute a financial market participant within the meaning of Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector ("SFDR"). The following disclosures are made by and on behalf of the Manager in its capacity as financial market participant under SFDR. Unless information is explicitly provided in relation to a specific fund vehicle managed by the Manager, the following statements refer to the management and investment decision-making processes of the Manager in general

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1. Regulatory Basis

These disclosures are made pursuant toRegulation (EU) 2019/2088 on sustainability-related disclosures in thefinancial services sector ("SFDR"), as supplemented by CommissionDelegated Regulation (EU) 2022/1288 of 6 April 2022 (the "RegulatoryTechnical Standards" or "RTS"), and as implemented in Luxembourgby the Luxembourg Law of 25 February 2020 on undertakings for collectiveinvestment. SFDR imposes transparency obligations on financial marketparticipants and financial advisers in relation to the integration ofsustainability risks and the consideration of adverse sustainability impacts intheir investment decision-making and advisory processes.

2. Integration Of Sustainability Risks In Investment Decision-Making

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2.1 Sustainability Risk Policy

The Manager reviews and evaluatessustainability risks as part of its investment management process.Sustainability risks are environmental, social or governance ("ESG")events or conditions, the occurrence of which could have an actual or potentialmaterial adverse effect on the value of an investment. Prior to any investmentdecision, the Manager conducts due diligence on prospective investments. Partof this due diligence process includes an assessment of whether materialsustainability risks are present in relation to the relevant investment.

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Where sustainability risks are identifiedand there is a reasonable likelihood that such risks may adversely affect thereturns of a fund vehicle, those risks are taken into account in the investmentdecision-making process. However, there is no dedicated ESG policy in place atthe Manager, and the Manager retains discretion to make or recommendinvestments in relation to which certain sustainability risks have beenidentified, provided that those risks are considered in the context of theoverall risk-return profile of the relevant fund vehicle.

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2.2 Likely Impact Of Sustainability Risks On Returns

The Manager considers that sustainabilityrisks, where material, may have an adverse impact on the financial returns offund vehicles. However, given the nature of the fund vehicles managed by theManager — which are typically blind-pooled alternative investment fundsinvesting in private equity or venture capital — the specific impact of anysustainability risk on returns will depend on the underlying investments madeby each fund vehicle and cannot be assessed in general terms at the level ofthe Manager or the platform. Fund-level sustainability risk disclosures, whereapplicable, are set out in the pre-contractual documentation for each fundvehicle.

3. Principal Adverse Impacts On Sustainability Factors

For the avoidance of doubt, the Managerdoes not currently consider principal adverse impacts ("PAI") onsustainability factors in its investment decision-making process, within themeaning of Article 4 of SFDR and the indicators set out in Table 1 of Annex Ito the RTS.

The Manager does not consider PAI for thefollowing reasons:

(a)  Fund vehiclesmanaged by the Manager are blind-pooled alternative investment funds. At thetime the Manager makes its investment decisions, the underlying portfoliocompanies or assets in which a fund vehicle will invest are typically not yetidentified or committed. The Manager therefore does not have access to the datanecessary to assess PAI at portfolio company level at the point of investmentdecision.

(b)  Even in theexceptional circumstance that a fund vehicle has made an investment at the timethe Manager takes an investment decision, the Manager does not have directaccess to the underlying portfolio companies by reason of its role as managerof the fund vehicle rather than as direct investor in those companies.

(c)  The Manager doesnot rank, select, or screen fund vehicles on the basis of PAI indicators setout in Table 1 of Annex I to the RTS.

The Manager may revisit itsapproach to PAI consideration as its assets under management grow, asregulatory guidance evolves, and as data availability at portfolio companylevel improves. Any change to this position will be reflected in an updatedversion of this statement.

4. Sustainability-Related Fund Classifications Under SFDR

Fund vehicles managed by the Manager areclassified in accordance with SFDR as follows:

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Article 6 SFDR — Funds Not Promoting Environmental Or SocialCharacteristics

Unless otherwise stated in thepre-contractual documentation for a specific fund vehicle, fund vehiclesmanaged by the Manager are classified as Article 6 funds under SFDR. This meansthat such fund vehicles do not promote environmental or social characteristics(within the meaning of Article 8 SFDR) and do not have sustainable investmentas their objective (within the meaning of Article 9 SFDR). Sustainability risksare integrated into the investment decision-making process to the extentdescribed in Section 2 above, but no binding ESG criteria are applied in theselection or management of investments.

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For the avoidance of doubt, classificationas an Article 6 fund does not imply that the relevant fund vehicle ignoressustainability risks entirely. It means that the fund vehicle does not make anyspecific sustainability-related commitments or pursue sustainability-relatedobjectives as part of its investment strategy.

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Article 8 And Article 9 SFDR — Future Fund Vehicles

The Manager may in the future manage fundvehicles that promote environmental or social characteristics (Article 8 SFDR)or that have sustainable investment as their objective (Article 9 SFDR). Anysuch fund vehicle will be clearly identified as such in its pre-contractualdocumentation, together with the applicable SFDR pre-contractual disclosuresand, where applicable, the disclosure templates prescribed under the RTS. Suchdisclosures will also be made available on the AlterLegacy platform in accordancewith Article 10 of SFDR.

5. Remuneration Policy And Sustainability Risks

In accordance with Article 5 of SFDR,information on the consistency of the Manager's remuneration policy with theintegration of sustainability risks is set out below.

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The Manager's remuneration arrangements aredesigned to be consistent with the integration of sustainability risks in itsinvestment decision-making process. In particular, the Manager does notmaintain remuneration structures that would incentivise the taking ofsustainability risks inconsistent with the risk profiles or investmentobjectives of the fund vehicles it manages. Given the Manager's current scaleand structure, remuneration decisions are made by senior management withreference to overall performance and risk management considerations, includingsustainability risk where material.

6. Website Disclosure

In accordance with Article 10 of SFDR,pre-contractual sustainability-related disclosures for each fund vehiclemanaged by the Manager, together with periodic sustainability-relatedinformation, are made available on the AlterLegacy platform at https://alterlegacy.comin the documentation section for the relevant fund vehicle. These disclosuresinclude, where applicable, information on:

(a)  Theenvironmental or social characteristics promoted by the fund vehicle, or thesustainable investment objective of the fund vehicle;

(b)  The investmentstrategies and methodologies used to attain those characteristics orobjectives;

(c)  The data sourcesand screening criteria used;

(d)  The assetallocation of the fund vehicle; and

(e)  Any benchmarkused and an explanation of how it is aligned with the environmental or socialcharacteristics or sustainable investment objective.

7. Updates To This Statement

This statement will be reviewed and updatedby the Manager on at least an annual basis, or more frequently if required bychanges in applicable law, regulatory guidance, or the Manager's investmentprocesses. The current version of this statement, together with the date oflast update, is available on the AlterLegacy platform at https://alterlegacy.com/sfdr-statement.

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For any queries relating to this statement,please contact the Manager via AlterLegacy Sarl at legal@alterlegacy.com.

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