EU SFDR Disclosure

Firm-level disclosures required under Regulation 2019/2088 on sustainability-related disclosures in the financial services sector dated 27 November 2019, as amended (“SFDR”)

Transparency of sustainability risk policies

Lovell Minnick seeks to integrate environmental, social and governance (“ESG”) factors, including sustainability risks, where relevant, into its investment processes, investment decisions and portfolio monitoring through the application of its ESG Policy and related procedures. Lovell Minnick evaluates material ESG risks, mitigating factors and opportunities applicable for the asset type (and the industry as a whole), which may include corporate governance, data privacy, ethics, anti-bribery and corruption, diversity and employee retention. When evaluating investment opportunities, Lovell Minnick also considers whether there are serious ESG or reputational concerns with regard to prospective portfolio companies or other assets.

Lovell Minnick may engage third party ESG consultants to conduct ESG due diligence on each potential portfolio company, pre-acquisition, to identify any material ESG-related risks and to provide recommendations for how to mitigate those risks during ownership. These recommendations are intended to guide Lovell Minnick’s consideration of material ESG risks when making portfolio investments.

Lovell Minnick supports the American Investment Council (“AIC”) Guidelines for Responsible Investing and strives to align with the principles that it contains.

Find more information on Lovell Minick’s ESG Policy here.

Transparency of Principal Adverse Sustainability Impacts

Lovell Minnick has considered, and continues to consider, environmental, social and governance (“ESG”) factors in its investment process but it does not consider principal adverse impacts of investment decisions on sustainability factors as specifically set out in the SFDR. Lovell Minnick has chosen not to do so for the present time as it considers that its existing ESG Policy and procedures are appropriate, proportional and tailored to the investment strategies of the funds managed by Lovell Minnick. Lovell Minnick continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance, and will, where required or otherwise appropriate, make changes to its existing policies and procedures.