Disclosures on sustainability

Integration of sustainability risks into the investment process

This section refers to the requirements of art. 3 of Regulation (EU) 2019/2088 for financial market participants and financial advisors to disclose the entity's guidelines for integration of sustainability risks into the investment process.

Consideration of principal adverse impacts on sustainability factors

This section refers to the requirements of art. 4 of Regulation (EU) 2019/2088 for financial market participants and financial advisors to disclose whether principal adverse impacts of investment decisions or advice on sustainability factors are considered as part of the investment decision or advice.

In accordance with the EU regulation on sustainable finance disclosure ("SFDR"), Cubera Private Equity ("Cubera") is to disclose to what extent, if any, principal adverse impacts of investment decisions on sustainability factors are considered as part of the investment process. A "principal adverse impact" as understood by the Regulation is a consequence of an investment decision which negatively affects one or more sustainability factors. This disclosure requirement can be met on a “comply or explain” basis.

Cubera does not currently intend to publish a statement on its website regarding its consideration of the adverse impacts of its investment decisions on sustainability factors as specified in article 4 of the SFDR. Cubera will however keep this position under close review by reference to market practice and whether sufficient information is available to change this position.

Cubera places great weight on ESG in daily operations and in investment analysis and advice. Cubera will not recommend investments where there is a risk of serious misalignment with Cubera's ESG principles.

As funds advised by Cubera are themselves investors in private equity funds and thereby do not make decisions on which assets will be acquired and ultimately form part of their portfolio, it must take appropriate measures to contribute to that the negative impact of the Portfolio Funds' investments on the environment and society is mitigated or eliminated. As part of its investment recommendation, Cubera will consider ESG criteria including but not limited to:

• The track record of the prospective Portfolio Fund manager with respect to ESG and responsible investment

• The ESG track record of the portfolio companies to be acquired, if applicable, including screening of material ESG incidents and the resolution of such incidents by the company and by the fund manager

• The prospective Portfolio Fund manager's internal ESG capabilities, policies and structures

• Exclusion and other criteria for the fund advised by Cubera

Cubera will make use of side letter agreements where possible, including excuse rights, with the Portfolio Fund managers in order to enforce its requirements with respect to ESG, including the minimization or elimination of negative impacts of investments in Portfolio Companies.

The funds advised by Cubera may make investments by subscriptions to new private equity funds, in which case the asset portfolio is unknown at the time of making the subscription, or they may acquire portfolios of LP interests in the secondary market, usually consisting both of existing Portfolio Companies and undrawn commitments which will be used to acquire companies. Due to the private nature of the portfolio, Cubera cannot meaningfully measure or evaluate which specific principal adverse impacts, if any, can be attributed to the investment opportunity being evaluated by Cubera. For this reason, Cubera has implemented measures as described above to secure the mitigation of negative impacts of the investment recommendations, with respect to responsible investment, throughout the investment value chain.

The private equity industry, and in particular the fund-of-funds segment, is not currently at a point where measuring and reporting adverse impacts in a consistent manner across the industry is possible. Where the public investment space already has benefitted from services from well-established data and insight providers, the private investment space has not yet seen the same development. Cubera engages in dialogue with several market players, including buyout managers, fund-of-funds managers and insight and data providers, to share practices, views and needs and contribute to developing the industry's sustainability monitoring and reporting capabilities.

Cubera is thereby making efforts to expand the organization's sustainability monitoring and reporting capabilities, to be able to provide an even more complete understanding of the sustainability aspects of our investment advice to our clients. As the Regulatory Technical Standards supplementing the SFDR are finalized and more clarity on the Regulation is gained, Cubera will assess its ability to comply with applicable requirements by developing processes to gather information on the sustainability impact of underlying investments and by making assessments of principal adverse impacts based on this reporting.