Sustainability Policy

SFDR DISCLOSURES – STATEMENT OF NON-CONSIDERATION OF THE NEGATIVE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABILITY FACTORS

Cedrus Atlantica – Sociedade de Capital de Risco, S.A. provides the following information in accordance with 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” or “Regulation”).

Integration of Sustainability Risks in the Investment Decision-Making Process (Article 3 of the SFDR)

As of the date of this disclosure, Cedrus Atlantica – Sociedade de Capital de Risco, S.A. does not market or manage funds that directly promote environmental or social characteristics (Article 8 of the SFDR) or that have sustainable investments as their objective (Article 9 of the SFDR).

The funds managed and marketed by Cedrus Atlantica – Sociedade de Capital de Risco, S.A. at this date may, however, make investments that qualify as sustainable under the Regulation, although without including considerations of sustainability risks, as defined in the Regulation, in their investment policy. This is due to the scope of investments provided for in the Management Regulation of the aforementioned funds and the expected return for such investments (Article 6 of the SFDR).

Statement on the Principal Adverse Impacts of Investment Decisions on Sustainability Factors (Article 4 of the SFDR)

Cedrus Atlantica – Sociedade de Capital de Risco, S.A., although it adopts the required professional diligence in evaluating its investment decisions, as per point b) of paragraph 1 of Article 4 of the SFDR, and intends, at the appropriate time, to incorporate it into its policies, currently does not take into account the negative impacts of investment decisions on sustainability factors.

This position is justified by the following reasons:

• Insufficient Available Information: Given the type of investments made by the funds under management, the level of public information available on ESG, especially the indicators listed in Annex I of Commission Delegated Regulation (EU) 2022/1288, is inadequate to properly consider the adverse impacts on sustainability of investment decisions based on such information. Additionally, the current legal landscape remains fragmented and underdeveloped in this area, with interpretative issues still pending resolution, as well as the absence of similar rules outside the EU, which prevents comparisons and makes it difficult to adequately consider adverse impacts. Cedrus Atlantica – Sociedade de Capital de Risco, S.A. therefore considers that there are not enough public sources of information that include sufficiently broad, rigorous, and comparable elements, nor clear and uniform criteria necessary to properly take into account the adverse impacts on sustainability of its investment decisions.
• Cost Rationality: In the absence of unified, reliable, and comparable public information, access to ESG information requires the use of external sources, which are excessively costly and disproportionate, and do not justify their consideration in the investment decision-making process by Cedrus Atlantica – Sociedade de Capital de Risco, S.A.
• Constitutive Documents: The constitutive documents of the managed funds do not require care or diligence regarding the negative impacts of investment decisions on sustainability factors in their investment decision-making process. Therefore, Cedrus Atlantica – Sociedade de Capital de Risco, S.A. believes that participants do not expect the negative impacts of investment decisions on sustainability factors to be considered in the investment decision-making process.

Cedrus Atlantica – Sociedade de Capital de Risco, S.A. intends to make efforts to incorporate sustainability criteria into its investment policy, although at this time there is no forecast date for such integration, taking into account the current mandates and the aforementioned limiting factors relating to the lack of information and high costs.

Integration of Sustainability Risks in the Remuneration Policy (Article 5 of the SFDR)

Cedrus Atlantica – Sociedade de Capital de Risco, S.A. does not have a formal remuneration policy and is not required under the RGA to have such a remuneration policy.

Final Considerations

As this is a constantly evolving matter, Cedrus Atlantica – Sociedade de Capital de Risco, S.A. intends to review its position in this regard annually, updating its practices and the information provided here whenever possible.

Disclosure date March 2025