SFDR Disclosure

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Mandatory disclosures pursuant to Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability‑related disclosure requirements in the financial services sector ("Disclosure Regulation"):

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1. Strategies for integrating sustainability risks into investment decision-making processes (Article 3 of the Disclosure Regulation). Sustainability risks are currently not a separate component of the investment decision-making processes of Elvaston Capital Management GmbH.

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2. Mandatory disclosures on the consideration of principal adverse impacts on sustainability factors at the level of Elvaston Capital Management GmbH (Article 4 of the Disclosure Regulation)

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Article 4 of the Disclosure Regulation provides a framework for creating transparency with regard to any adverse impacts of investment decisions on sustainability factors within the meaning of the Disclosure Regulation. To this end, financial market participants such as Elvaston Capital Management GmbH are required to disclose certain information (taking into account the so-called Regulatory Technical Standards (RTS)). Elvaston Capital Management GmbH is of the view that the information made available to it by its portfolio companiesin relation to its investments – particularly with regard to the comprehensive requirements of the RTS – is not yet sufficient to enable such disclosure. Elvaston Capital Management GmbH does not currently take into account any principal adverse impacts of investment decisions on sustainability factors within the meaning of Article 4 of the Disclosure Regulation. However, Elvaston Capital Management GmbH will monitor developments with regard to the availability of relevant information and assess the extent to which it will be meaningfully possible in the future to disclose the information required under Article 4 of the Disclosure Regulation (including the RTS).

3. Mandatory disclosures on remuneration policies in relation to the integration of sustainability risks (Article 5 of the Disclosure Regulation).

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As sustainability risks do not form part of the investment decisions of Elvaston Capital Management GmbH, no information can be provided on the consistency of the remuneration policy with the integration of sustainability risks. Accordingly, the remuneration policy of Elvaston Capital Management GmbH does not currently take sustainability risks into account.

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Version History:

V 2.0 – Secondversion, published 23 March 2026

V 1.0 – Firstversion, published 10 March 2021

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