SFDR Policy

Pursuant to EU 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, which is also known as the “Sustainable Finance Disclosure Regulation” or (the “SFDR”), Alt Investments is required to disclose the manner in which Sustainability Risks (as defined below) are integrated into the investment decision making process and the results of the assessment of the likely impacts of Sustainability Risks on the returns of the Funds it manages.

“Sustainability Risks” means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investments.

“Sustainability Factors” means environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. Environmental factors may include, but are not limited to, the impact of emissions, energy efficiency, the exploitation of natural resources or waste treatment. Social factors may include human rights, treatment of workers and workers’ rights or diversity issues. Governance factors may include shareholder rights, remuneration of senior management, conflicts of interest or board independence.

Alt Investments does not promote, among other characteristics, environmental or social characteristics, or a combination of those characteristics according to Article 8 of SFDR and does not have sustainable investment as their objective according to Article 9 of SFDR.

For the purposes of Article 6 of SFDR, sustainability risks are not explicitly taken into account for the investment decisions and Alt Investments does not use a formal sustainability framework.

Alt Investments’ investment decisions are based on thorough analysis of business models, competitive environment, company financials and management incentives. In these areas Alt Investments can occasionally formulate a superior risk/return analysis compared to other market participants. Contrary, Alt Investments does not believe the assessment of “Sustainability Risks” is an area where it can add significant value compared to market consensus.

If Alt Investments considers it appropriate to integrate sustainability risks into the investment decisions going forward, this disclosure will be updated in accordance with the SFDR to reflect such decision.

Compensation Policy

Alt Investments’ compensation policy does not take into account any sustainability metrics.