1Sustainability Disclosures

Piper makes the following disclosures in accordance with Article 6(1) and Article 7(2) of the Sustainability-Related Disclosure in the Financial Services Sector Regulation (2019/2088) (the “Disclosure Regulation”) and Article 7 of the Taxonomy Regulation (2020/852) (the “Taxonomy Regulation”).

2Integration of Sustainability Risks

Before any investment decisions are made on behalf of the Fund, Piper will identify the material risks associated with the proposed investment. These risks identified form part of the overall investment proposal submitted to the Investment Committee for debate and decision making. The Investment Committee assesses the identified risks alongside other relevant factors set out in the proposal. Following its assessment, the Investment Committee makes relevant investment decisions having regard to the Fund’s investment policy and objectives. During this process, sustainability risks are identified and assessed using the same process as is applied to other relevant risks affecting the Fund.

The specific investment decision-making on behalf of the Fund as outlined above is part of Piper’s wider policies and procedures on the integration of sustainability risks in its decision-making process in relation to its funds generally. Further information on this will be provided upon request.

Sustainability risks will be integrated into the investment decision making and risk monitoring of the Fund to the extent that they represent potential or actual material risks to the Fund’s investments. As part of that process, Piper has determined that sustainability risks are potentially relevant to the Fund having regard to the types of investments that may be made in accordance with the Fund’s investment policy and objectives. Identification and assessments of risks, including sustainability risks, will take place on an investment-by-investment basis in accordance with the above policy.

Piper will follow its procedures to identify and mitigate sustainability risks, although there can be no guarantee that Piper will successfully identify and mitigate all material risks.

3Transparency of adverse sustainability impacts

Article 4 of the Disclosure Regulation requires fund managers to make a clear statement as to whether or not they consider the “principal adverse impacts” of investment decisions on sustainability factors. Piper does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the Disclosure Regulation.

Although Piper takes sustainability and ESG very seriously, Piper uses its own procedures, policies and metrics to assess the principal adverse impacts of investment decisions on sustainability factors which do not align with those prescribed under Article 4 of the Disclosure Regulation, as Piper considers that its own procedures, policies and metrics are more appropriate and tailored to Piper and investments that Piper makes on behalf of the funds it manages, and therefore assist in Piper’s objective to deliver long-term risk adjusted returns to investors.

Accordingly, Piper does not currently intend to consider the prescribed adverse impacts of their investment decisions on sustainability factors within the meaning of Article 4 of the Disclosure Regulation; however, Piper keeps this situation under ongoing review.

4Taxonomy Regulation Disclosure

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.