SFDR

Sustainability Related Disclosures under Regulation (EU) 2019/2088 (“SFDR”)

Accendo Capital Management Limited (the “AIFM”) is an alternative investment fund manager within the meaning of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”). The AIFM manages Accendo Capital (the “Fund”), which is classified as an Article 6 financial product under SFDR.

Article 3 SFDR: Integration of Sustainability Risks

The AIFM has assessed sustainability risks in the context of the Fund's investment strategy and the types of investments made or expected to be made by the Fund.

Following this assessment, the AIFM has concluded that sustainability risks are not currently considered material to the Fund's investment decision-making process and are therefore not specifically integrated into investment decisions relating to the Fund.

The AIFM considers that sustainability risks are not currently expected to have a material adverse impact on the returns of the Fund. This assessment may be reviewed from time to time in light of changes to the Fund's investment strategy, the nature of its investments or applicable regulatory requirements.

Article 4 SFDR: Principal Adverse Impacts on Sustainability Factors

The AIFM does not currently consider principal adverse impacts of investment decisions on sustainability factors within the meaning of Article 4 of SFDR.

In reaching this decision, the AIFM has taken into account its size, the nature and scale of its activities and the investment strategy of the Fund. The Fund follows a concentrated active-ownership strategy, investing primarily in listed small and mid-sized Northern European companies, and does not pursue an environmental or social investment objective or promote environmental or social characteristics.

In light of these factors, the AIFM considers that implementing the detailed framework for the consideration and reporting of principal adverse impacts would not currently be proportionate to the nature and scale of its activities.

The AIFM will keep this position under review and may reconsider whether to take principal adverse impacts into account if the nature or scale of its activities, the Fund's investment strategy or applicable regulatory requirements change.

Article 5 SFDR: Remuneration Policy

The AIFM's remuneration policy is designed to promote sound and effective risk management and not to encourage risk-taking that is inconsistent with the risk profile, investment strategy or governing documents of the Fund.

The Fund is classified as an Article 6 financial product under SFDR. The AIFM assesses sustainability risks in the context of the Fund's investment strategy and investments and has concluded that such risks are not currently material to the Fund's investment decision-making process.

Accordingly, the AIFM does not apply specific sustainability-related remuneration targets or performance indicators. Remuneration is, however, subject to the AIFM's general risk-management framework and takes into account financial and non-financial performance, including compliance with the AIFM's policies and procedures and appropriate risk management.

The AIFM considers its remuneration policy to be consistent with its approach to sustainability risks and reviews the policy and its application on at least an annual basis.

Last updated: September 2026