DISCLOSURE ON THE SYNTAXIS GROUP WEBSITE FOR SFDR

Overview

Walking the walk, not just talking the talk. First and foremost, responsibility begins with us. Only if we have respect for our own employees, our investors, and our companies, can we expect the same from them. By embracing certain key principles, such as equality, openness, and transparency, and an appropriate frugality on our part, we reinforce our commitment to being responsible investors.

At Syntaxis we have always been responsible investors - we want to do not merely the right things, but to do them in the right way. To us it is self-evident that companies with strong environmental controls, a healthy and contented workforce, and effective systems of governance, are likely to be more profitable, and more valuable than companies lacking them.

We are signatories to the ILPA principles and operate in line with the PRI principles. We are also required to provide certain disclosures in compliance with the EU’s Sustainable Finance Disclosure Regulation (SFDR) and these are set out below.

Integration of sustainability risks

A sustainability risk is any ESG event that, if it occurs, could or will have a material negative impact on the value of investments we make for our clients (“Sustainability Risks”). Sustainability or ESG factors include environmental, social and employee matters, respect for human rights, and anti-corruption and anti-bribery matters (“Sustainability Factors”). SFDR requires us to explain how we integrate Sustainability Risks in our decision making process.

What we do now:

ESG considerations are integrated into the way we approach, think about, and analyse potential investments A comprehensive ESG screening is typically performed on Portfolio Companies at the time of investment. This screening is currently primarily qualitative, but it is the objective to develop a meaningful and supplementing quantitative approach, presumably based on an ESG scoring. We may also work with ESG service providers depending on the business operations of the Portfolio Company and its industry. Once a quantitative approach has been developed, an internal rating system for the ESG scoring will be implemented to rate and evaluate the progress of Portfolio Companies over time. Analysis of the ESG profile of an investment is also monitored on an ongoing basis during the life cycle of the investment and reported to investors at least annually.

Syntaxis’ internal policy requires that during the internal due diligence process, the deal team shall assess the Portfolio Companies’ information based on audited annual accounts (if available), internal management information, site visits and several meetings with key management & shareholders. We also pass Portfolio Companies through an exhaustive “know your customer “process etc. Occasionally, external due diligence by an independent and reputable third party might also be required. Additionally, post - investment, Portfolio Companies provide monthly financial information and to audit their accounts with reputable firms agreed in advanced.

Minimise business travel by maximising the use of less wasteful methods of communication (we are big users of Skype for instance).

Internally we have a relatively flat structure - both in terms of hierarchy and remuneration - which promotes genuine teamwork.

What we will strive to do:

Seek to improve our approach, by adding more quantitative information to the current qualitative analysis and improve related reporting to investors.

Expand the ways in which Syntaxis contributes to society in a broader sense.

Principal adverse impacts

We do not at present consider principal adverse impacts of investment decisions on Sustainability Factors as prescribed in Article 4 of SFDR. Although Syntaxis considers Sustainability Risks in its decision making process, as outlined above, we use our own policies, procedures and measures to assess the adverse impacts of investment decisions on Sustainability Factors, rather than those prescribed under SFDR. This is because, at present, they are more tailored to our investors and investments. Further, as an Article 6 fund, we do not consider that the detailed consideration of PAIs is proportionate to the Fund’s sustainability approach.

Whilst we do not currently intend to consider the prescribed adverse impacts of our investment decisions on Sustainability Factors within the meaning of Article 4 of SFDR, we do keep this position under review annually.

Remuneration Policy

Our remuneration practices are designed to promote sound and effective risk management and not to encourage risk-taking which is inconsistent with their risk appetites or the risk profiles of the portfolios which they manage. Our approach to remuneration includes fixed and variable remuneration. Variable remuneration may be adjusted for performance, including with respect to the integration of and compliance with Syntaxis’ policies and procedures, including those relating to the impact of sustainability risks on the investment decision making process.