Memphis fund

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

(SFDR)

NI Capital GP (NI Capital GP) and NI Capital Holding (NI Capital H) as a financial market participants under SFDR (the FMPs), make the following disclosures in accordance with and pursuant to, article 3, article 4 and article 5 of SFDR.

Transparency of sustainability risk policies

Article 3 SFDR

Pursuant to the SFDR, the FMPs are required to publish information about its policies on the integration of Sustainability Risks in their investment decision-making process. A “Sustainability Risk” is an environmental, social or governance event or condition that, if it occurred, could cause an actual or a potential material negative impact on the value of the investments concerned NI Capital’s investment decision. Sustainability Risks are principally linked to climate-related events resulting from climate change or to the society’s response to climate change, which may result in unanticipated losses that could affect investments and financial position. Social events (e.g. inequality, inclusiveness, labour relations, investment in human capital, accident prevention, changing customer behaviour, etc.) or governance shortcomings (e.g. recurrent significant breach of international agreements, bribery issues, products quality and safety, selling practices, etc.) may also translate into Sustainability Risks. Such Sustainability Risks are only integrated into the investment decision making of the FMPs from a risk monitoring perspective to the extent that they represent a potential or actual material risks and/or opportunities to maximizing the long-term risk-adjusted returns. The impacts following the occurrence of a Sustainability Risk may be numerous and vary depending on the specific risk, region and asset class and other features of the financial product(s) managed by the FMPs. In general, where a sustainability risk occurs in respect of an asset, there could be a negative impact on, or entire loss of, its value. It is expected that the financial product(s) managed by the FMPs will be exposed to a broad range of Sustainability Risks which will differ from an investment to another and a financial product to another. For example. some markets and sectors will have greater exposure to Sustainability Risks than others will.

Transparency of adverse sustainability impacts at entity level

Article 4 SFDR

The FMPs do not consider the principal adverse impacts of their investment decisions on Sustainability Factors (the PAI), as the FMPs consider that such PAI cannot be clearly and correctly quantified and duly taken into account both in consideration of a proportionality criteria (size, nature and scale of the activities of the FMPs) and the general lack of readily available data within the investment universe of the financial product(s) managed by the FMPs to consider many of the technical reporting requirements of the PAI. For the avoidance of doubt, the FMPs currently do not intend to consider such PAI in the future.

Transparency of remuneration policies in relation to the integration of sustainability risks

Article 5 SFDR

The FMPs pay their staff in accordance with remuneration policies which takes into account compliance with their internal risk management framework and internal policies, including those relating to the integration of Sustainability Risks. In this regard, the FMP’s remuneration policies do not encourage risk-taking which is inconsistent with its internal risk limits or with the risk profile of the financial product(s) managed by the FMPs, including regarding Sustainability Risks stemming in particular from climate-related events or from the society’s response to climate change.