Under the Regulation (EU) 2019/2088 of the European Parliament on sustainability‐related disclosures in the financial services sector (“SFDR”), and the Taxonomy Regulation (EU) 2020/852 (“TR”), CPAG Fund Management Ltd (“CPAG”, “the Company”, or “we”) qualifies as a financial market participant and therefore is required to comply with certain sustainability disclosure requirements. This Disclosure Policy is reviewed annually and updated where any amendments are need to be made to comply with Regulations.

“Sustainability risk” as defined in the SFDR, is 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. CPAG addresses the required disclosures under SFDR and TR below:

• Integration of sustainability risks in the investment decision-making process

Sustainability has three main pillars which relate to environmental, social, and governance (“ESG”) matters, including human rights, anti-corruption and anti-bribery. As at time, CPAG, does not consider specific ESG principles in its strategy or objectives including for the funds under management. Nevertheless, CPAG considers ESG principles to be of high importance and intends to gradually integrate sustainability considerations and their implications within its business environment as well as integrating them within its core values, the investment assessment, decision making process and risk profile of its funds under management.

• Transparency of adverse sustainability impacts at entity (AIFMJ) level

At CPAG, for the time being, except as may be otherwise disclosed at a later stage on our website, we do not consider any adverse impacts of our investment decisions on sustainability factors in the manner prescribed in Article 4 of the SFDR, due to the fact that, currently, such considerations are deemed irrelevant to the Company’s business decisions taking into account the size and scale of the Company’s business activities.

The Company may reassess its consideration in the future in regard to adverse impacts, should circumstances change, in order to reflect the way these principal adverse impacts on sustainability factors will be taken into account.

• Transparency of remuneration policies in relation to the integration of sustainability risks

CPAG integrates sustainability risks into its remuneration policies as a financial market participant. The Company’s remuneration practice does not encourage risk-taking nor triggers any risks regarding sustainability risks.

• Taxonomy Regulation Disclosure

The investments underlying our financial products in our funds under management do not currently take into account the TR criteria for environmentally sustainable economic activities