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SFDR Disclosures

Sustainable Finance Disclosure Regulation – Art. 3 – Sustainability risks

VCUK Global Expansion GP acknowledges that ESG-related events or conditions could potentially have a negative impact on the value of our investments. VCUK Global Expansion GP does not formally integrate an assessment of sustainability risks in our decision-making process in accordance with article 3 of the SFDR. That being said, VCUK Global Expansion GP could consider sustainability risks as part of its investment decision-making process. In particular, Claret considers sustainability risks as part of its due diligence process prior to any investment. Through the application of negative screens, due diligence (including ESG) questionnaires and/or documentation of ESG risks and opportunities, however, it remains free in its decision to refrain from investing or to invest, despite sustainability risks.

Sustainable Finance Disclosure Regulation – Art. 4 – Principal adverse impact

Sustainable Finance Disclosure Regulation requires VCUK Global Expansion GP to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”). In general, sustainability risks could adversely impact VCUK Global Expansion GP investments funds and related investments. VCUK Global Expansion GP does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR Regulation. Indeed, VCUK Global Expansion GP considers that an alignment with Article 4 of the SFDR regulation is difficult due to the overall interpretation of the set principal adverse impact rules, maturity level of ESG available data and KPI and diverse ESG source of information. However, VCUK Global Expansion GP will continuously seek to obtain relevant information on potential sustainability risks and evaluate to which extent this information can fulfill the PAI requirements and VCUK Global Expansion GP may review its position on the PAI approach in the future.
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