Hilmar Capital GP S.à r.l., a private limited liability company (Société à responsabilité limitée) incorporated and existing under the laws of the Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Register (Registre de Commerce et des Sociétés) under the number B290579 (the “AIFM”), which manages an alternative investment fund registered in Luxembourg: HILMAR CAPITAL DIRECTIONAL FUND SCSp, a Luxembourg special limited partnership (société en commandite spéciale), formed under the laws of the Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies Register under the number B291223 (the “AIF”), makes the following sustainability-related disclosures pursuant to 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 (the “SFDR”). Integration of Sustainability Risks (Article 3 SFDR) The AIFM does not actively incorporate sustainability risks into its investment decision-making process. This means that it does not base its investment choices on potential sustainability risks, nor does it assess the negative impacts that these risks may have on the investments. These considerations are not part of the AIFM'sstandard due diligence procedures when evaluating investment opportunities. Principal adverse sustainability impact statement (Article 4 SFDR) The AIFM acknowledges the importance of incorporating sustainability principles into its core processes throughout the investment phase. However, after considering the size, nature, and scale of its activities, and given that the primary objective of the AIF is to deliver high returns to its partners across the market cycle, the AIFM believes that it would not currently be proportionate to comply with the detailed technical standards under the SFDR regarding the principal adverse impacts of its investment decisions on sustainability factors. Therefore, at this stage, the AIFM does not take into account the principal adverse impacts of its investment decisions on sustainability factors, as specified in the SFDR. Nevertheless, the AIFM intends to monitor industry developments closely and update its approach as the situation evolves.
Remuneration policies (Article 5 SFDR) As de-minimis / sub-threshold alternative investment fund manager under registration with the Commission de Surveillance du Secteur Financier (the “CSSF”) in Luxembourg, in accordance with the requirements of the CSSF, the AIFM does not have and does not need to have a remuneration guideline or policy.