SFDR Disclosures

Article 4: Consideration of Principal Adverse Impacts (PAIs) at the entity level

Freshstream takes sustainability and ESG very seriously, including through consideration of adverse impacts of an investment as part of its investment process; however, Freshstream does not consider the principal adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR. Freshstream is not currently in a position to obtain and/or measure all the data that it would be required by the SFDR to report on this basis, or to do so systematically, consistently, and at a reasonable cost. Freshstream does, however, monitor the SFDR’s principal adverse impacts indicators within the portfolio companies of its funds as part of the firm’s integrated approach to ESG. Freshstream believes that our existing due diligence processes and Responsible Investment Policy are appropriate for the investment strategies of our funds. We do and will continue to monitor regulatory developments, including with respect to the SFDR, and where required will make changes to our existing policies and procedures if appropriate.

Article 5: Integration of sustainability factors in the remuneration policy at the entity level

Freshstream pays its staff a combination of fixed remuneration, which takes into consideration a variety of qualitative and quantitative factors, including sustainability, as described above.