As third-party alternative investment fund manager, Royalton Partners S.A. (“RPSA”) encourages but does not apply specific environmental, social or governance (ESG) principles at the company level. Investment Funds managed by Royalton Partners apply their own specific ESG approach and SFDR classification.

For all funds for which it acts as alternative investment fund manager, RPSA has implemented processes so that at least sustainability risks are integrated into the investment decisions and the risk management framework. The below describes the minimum approach adopted by RPSA with respect to the integration of sustainability risks:

(i)                  when RPSA relies on an investment advisor, RPSA will assess how sustainability risks are integrated in the investment research of such advisers [1]. In addition, RPSA will carefully review any analysis on sustainability risks in the context of an investment recommendation made by an investment advisor;

(ii)                RPSA integrated sustainability risks in its own policies such as for example the portfolio management procedures and the risk management process; and

(iii)               RPSA integrated sustainability risks in its initial and on-going due diligence questionnaires and ongoing oversight.

No consideration of adverse impacts of investment decisions on sustainability factors

Currently, RPSA does not consider the adverse impacts of its investment decisions on sustainability factors. The business of the company is based on review and approval of investment proposals provided by investment advisors for alternative investment funds managed by the Company. Each fund commits to its own environmental objectives tailored to reflect its specific circumstances and the Company’s activity is focused on ensuring compliance of these funds with commitments made under their disclosure frameworks. The Company believes that taking into account variety of strategies and asset classes pursued by the managed Funds, this approach serves best the purpose of promoting sustainable investments and does not foresee changing this approach in the near future.

RPSA will always ensure that its remuneration policy is consistent with the integration of sustainability risks and will notably ensure that when determining the variable remuneration of the identified staff, the board takes into account compliance of the relevant staff member with all procedures and policies of the company, including those relating to the integration of sustainability risks. It shall in this regard be noted that as of today, our remuneration policy already seeks to: (i) align the staff’s incentives with asset owners’ long-term interests and the long-term success of RPSA; and (ii) to promote a sound and effective risk management culture to protect the value of the investment portfolio. Integration of ESG/sustainability risk considerations, where these are relevant and material for investment performance, are already included in these existing requirements as it should be seen and used as an instrument to enhance investment performance, which would equally benefit the funds (and their investors), RPSA and its employees.

ESG disclosures of funds managed by Royalton Partners, which committed to disclosure under Art. 8 or Art. 9 of Regulation (EU) 2019/2088 of the European Parliament and of the Council are presented below.

[1] With respect to AEW Value Investors Asia IV, L.P., AEW Value Investors Asia V, L.P., AEW Asia Pacific Real Estate Fund, L.P. and AEW Core Property (U.S.) Lux Parallel, L.P. please see additional information at https://www.aew.com/socially-responsible-investment

[2] With respect to Lendable S.A. SICAV-RAIF and Lendable Master Impact Fund SCSp SICAV-RAIF please see additional information at Compliance – Lendable

[3] With respect to U-Prime Real Estate SICAV-RAIF, please see additional information at https://www.ubp.com/en/investment-expertise/responsible-investment.

[4] With respect to LCN European Fund IV SCSp, please see additional information at https://www.lcnpartners.com/wp-content/uploads/2024/12/LCN-EU-Fund-IV-PPM-Insert-SFDR-Art-8-2023.pdf

[5] With respect to CONSTELLATION, SCSp, SICAV-FIAR – CONSTELLATION VI , please see additional information at https://constellation.ch/sfdr/

[6] With respect to MIDEUROPA FUND VI SCSp, Please see additional information at https://mideuropa.com/wp-content/uploads/2025/06/Fund-VI-Sustainability-Related-Disclosures.pdf

[7] With respect to Lendable MSME Fintech Credit Fund II SCSp SICAV-RAIF please see additional information at LMFCF 2 – SFDR pre-contractual disclosure

As additional point be advised that the SFDR RTS Pre-Contractual Template and the Fund Documentation are available to the investors upon request to the AIFM and/or the Investment Advisor.

The copy of Complaints Handling Procedures of Royalton Partners SA is available for review in the attached file.

RPSA implemented adequate and effective policies and procedures for implementing:

– conflict of interest policy,

– best execution policy,

– voting rights policy,

– remuneration policy

and

– independent analysis of investment transactions.

These procedures are available for inspection by investors of the funds managed by RPSA at the registered office of the Company or provided upon request by email. The request should be sent to compliance@royalton-partners.com