ILGTSPĒJA

Mandatory disclosures under 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”)

INFORMATION ABOUT POLICIES ON THE INTEGRATION OF SUSTAINABILITY RISK IN INVESTMENT DECISION-MAKING PROCESSES (Article 3 disclosures)

ZGI Capital AIFP, SIA (hereafter “ZGI Capital”) considers environmental, social and corporate governance (hereafter “ESG”) risks in their investment decision-making process. Potential sustainability risks (environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment) are assessed during the investment negotiation and due diligence process. The scope of assessment varies depending on the individual characteristics of particular investment case.

ZGI Capital applies exclusion policy and does not invest into companies which operate in those sectors of economy associated with significant sustainability risks, such as trade of alcoholic beverages, gambling and betting, sale of firearms and ammunition, adult entertainment, manufacturing, processing and marketing of tobacco and tobacco products and others.

ZGI Capital currently does not offer and does not manage any funds which promote, among other characteristics, environmental or social characteristics, or a combination of those characteristics or funds which have sustainable investment as its objective, thus ESG considerations are regarded as inputs in the investment process rather than the objective of our work.

STATEMENT OF NO CONSIDERATION OF ADVERSE IMPACTS OF INVESTMENT DECISIONS ON SUSTAINABILITY FACTORS (Article 4 disclosures)

Taking due account of the size, nature and scale of our activities, as well as the types of financial products we make available, currently ZGI Capital does not consider the adverse impacts ("PAI") of investment decisions as defined by Article 4 of the SFDR on sustainability factors as defined by Article 2 (24) of the SFDR. Investment focus of the funds under our management is small and medium size companies, which, taking into account their inherent characteristics, are currently not required to collect and report the data necessary to reliably assess and monitor PAI of investment decisions. Requirement to collect and report such data would, in most cases, be disproportionate to the size of the operations of these companies and resources available to them. ZGI Capital will reevaluate our policies if and when the conditions described above will change materially.

INFORMATION ON CONSISTENCY OF REMUNERATION POLICIES WITH THE INTEGRATION OF SUSTAINABILITY RISKS (Article 5 disclosures)

The structure of remuneration policies does not encourage excessive risk‐taking with respect to sustainability risks.