SFDR Disclosures

“The Company is acting as registered alternative investment fund manager under code A00003285 of the Luxembourg Commission de Surveillance du Secteur Financier and as such provide services to alternative investment funds in accordance with article 3 (2) a) of the Luxembourg AIFM Law.

As per Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”), the Company is considered a “financial market participant”.

ICP Global Fund

No consideration of adverse impacts of investment decisions on sustainability factors.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The SFDR lays down harmonised rules for financial market participants on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.

In accordance with these rules, the Fund is required to disclose how sustainability risks are integrated into the investment decision and the results of the assessment of the likely impacts of sustainability risks on the Fund’s returns.

The Fund is considered to fall within the scope of Article 6 of the SFDR. Indeed, it does not promote environmental or social characteristics and does not pursue a specific sustainable investments objective.

Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the Fund may generate.

The AIFM shall continue to review and consider its obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.

Origyn Ecosystem Fund

No consideration of adverse impacts of investment decisions on sustainability factors.

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The SFDR lays down harmonised rules for financial market participants on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.

In accordance with these rules, the Fund is required to disclose how sustainability risks are integrated into the investment decision and the results of the assessment of the likely impacts of sustainability risks on the Fund’s returns.

The Fund is considered to fall within the scope of Article 6 of the SFDR. Indeed, it does not promote environmental or social characteristics and does not pursue a specific sustainable investments objective.

Consequently, sustainability risks are not integrated into the investment decisions or in the risk monitoring and are deemed not to be relevant, as an extra-financial analysis based on sector exclusion and/or the reduction of the investment universe on the basis of an ESG analysis has no impact on the potential reduction of sustainability risks that the investment strategy of the Fund may generate.

The AIFM shall continue to review and consider its obligations with respect to taking into account the main adverse impacts of investment decisions on sustainability factors as defined in Article 4 of the SFDR.”