SFDR
Disclosures

Furthermore, under the Alternative Investment Fund Managers Law L.56(I)/2013 (as amended), we have received authorization from the Cyprus Securities and Exchange Commission (CySEC) to operate as an Alternative Investment Fund Manager (AIFM). Our authorization extends to managing alternative investment funds (AIFs) which are classified as financial products under the SFDR. This designation qualifies us as a financial market participant within the scope of SFDR.

This section outlines our Sustainability framework in a structured and

reader-friendly manner.

In accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council, known as the Sustainable Finance Disclosures Regulation (SFDR), Argus Management Ltd (referred to as Argus Management, we or us) is obligated to adhere to specific sustainability disclosure requirements.

Our approach

Our approach begins within our own organization, where we encourage our team to make thoughtful and responsible decisions in their daily work.

Where appropriate, we take environmental, social and governance (ESG) considerations into account as part of our investment and risk-management processes. This approach helps us identify and assess potential ESG-related risks alongside financial considerations.

Our objective is to support long-term value creation for our investors while acting in a responsible and considered manner. We continue to evaluate ways to balance economic growth with responsible investment practices, with the aim of delivering sustainable outcomes for our investors and other stakeholders.

At Argus Management, we have taken a strong stance against investments in industries and businesses that do not align with our ethical principles. We firmly prohibit investments in:

Unethical Industries - alcohol, tobacco, gambling, weapons manufacturing, and sex-related industries.
Human Rights Violations - businesses complicit in human rights abuses are not part of our investment portfolio.
Labor Rights Violations - we support businesses that uphold freedom of association, recognize the right to collective bargaining, do not employ forced, compulsory, or child labor, and ensure a discrimination-free working environment.
Corporate Corruption - we refrain from investing in businesses with confirmed practices of corruption, extortion, and bribery.

In accordance with the SFDR, we acknowledge our role as a financial market participant, with the AIFs we manage being categorized as financial products under SFDR definitions. As part of SFDR requirements, we categorize our AIFs based on their sustainability objectives. We employ the following categorization framework:

Article 9 (Dark Green Products): Financial products that have sustainable investments as their objective:
o Article 9(1) - financial products that have sustainable investments as their objective and an index has been designated as a reference benchmark;
o Article 9(2) - financial products that have sustainable investments as their objective and no index has been designated as a reference benchmark;
o Article 9(3) - financial products that have a reduction in carbon emissions as their objective.
Article 8 (Green Products): Financial products that promote environmental or social characteristics, or a combination thereof, provided that the companies in which investments are made follow good governance practices.
Article 6 (Neutral Products): Financial products that do not fall under Article 8 or Article 9 categories but are part of our investment offerings.

We wish to disclose that all the products we currently offer are categorized as "Article 6" products.

The assigned Risk Manager continuously monitors investments within AIF portfolios to identify developments that could affect their exposure to sustainability risks. We acknowledge that due to the nature of our investment mandates, we currently face limitations in using measurement tools such as ESG scores. However, we remain committed to adopting these tools as they become widely adopted and data becomes available.

Where relevant, we integrate sustainability risks into our strategies to ensure that we make informed and responsible investment choices. Our sustainability risk considerations focus on potential financial impacts on our investments, aligning with SFDR's definition of sustainability risk. We assess the short, medium, and long-term material sustainability risks, primarily related to environmental, social, and governance (ESG) issues:

Environmental Risks - physical risks (e.g., water contamination), transition risks (e.g., regulatory changes), and susceptibility to market conditions.
Social Risks - workforce working conditions, health and safety, and compliance with anti-slavery, child labor, and workplace equality regulations.
Governance Risks - stemming from a lack of appropriate policies, controls, and diversity and inclusion efforts, along with non-compliance with anti-corruption provisions.

Depending on the investment strategy of the AIF, we may establish and implement limits to mitigate sustainability risks that could impact performance, as part of our overall risk mitigation process. Where deemed relevant, any one of the following indicative limits may be established and monitored:

Set quantitative limits to prevent or reduce exposure in investments with high carbon emissions.
Set quantitative limits to reduce exposure in companies or projects with a history of environmental violations.
Prohibit exposure in companies or projects associated with controversial social practices, such as human rights violations or labor issues.
Restrict investments in assets or transactions with counterparties that have low ESG scorings.
Prohibit investments in industries or activities considered harmful to the environment, society or ethical standards.
Avoid financing projects that are harmful to the environment.

Fostering the Well-Being of our Employees

At Argus Management, we take pride in being regarded by our shareholders as a firm of excellence that makes a meaningful difference in the professional lives of our employees. Acknowledging that work is a significant part of daily life, we are committed to fostering a workplace where individuals feel valued, supported, and empowered to grow. We have established a set of policies, principles, and core values designed to create a respectful, inclusive, and motivating environment. Through dedicated well-being initiatives, we aim to support our team both personally and professionally. Our commitment is reflected in the values we uphold, including integrity, respect, diversity, continuous development, and excellence. These values form the foundation of our corporate culture. We are equally committed to the principle of equal treatment, ensuring that all employees are treated fairly and free from any form of discrimination.

At Argus Management, we believe that investing in our people is essential to building a resilient and high-performing organization.

Our Core Principles for Robust Governance

At Argus Management, we maintain a corporate governance framework designed to support effective oversight and responsible management. Our Board has adopted governance principles that guide the organization's structure and decision-making processes. These principles aim to maintain Board independence and ensure appropriate oversight. Our governance framework supports transparency and clear accountability in the management of the Company. We maintain governance measures that encourage effective supervision and independent judgement at the Board level. The composition of the Board includes independent Non-Executive Directors in order to support balanced and objective decision-making. Argus Management is also committed to collective suitability and integrity at the Board level. The members of the Board of Directors bring a range of professional expertise and meet the applicable requirements regarding competence, availability, and independence. Board members are supported through induction processes and ongoing professional development. The Company operates in accordance with applicable regulatory requirements. Members of the Board and senior management meet the Cyprus Securities and Exchange Commission (CySEC) criteria for good repute and professional standing.

Remuneration Policy Framework

We comply with both Cyprus national and EU laws by establishing a comprehensive Remuneration Policy that governs our staff's compensation practices. This policy serves as a safeguard to ensure that our remuneration practices do not provide incentives for excessive risk-taking in relation to sustainability risks.

Our Remuneration Policy champions several fundamental practices that are perfectly aligned with our sustainability risk policies:

We evaluate the suitability of personnel and job applicants solely based on their merits and qualifications, eliminating any form of bias related to ethnicity, religion, or disability.
Our fee structure is intentionally designed to foster sound risk management, avoiding any encouragement of risk-taking that could be inconsistent with the objectives of the funds we manage.
The remuneration we offer does no includes a well-balanced blend of fixed and - in exceptional cases - variable performance components, with emphasis on the fixed component.
We incorporate a comprehensive adjustment mechanism in our performance assessments, accounting for various types of risks, whether current or future.
We maintain stringent controls to prevent excessive risk-taking, ensuring that variable remuneration, when offered, is tied to individual performance and adjusted for risk.

Implementation Oversight

The effective implementation of our remuneration policy is vigilantly overseen by the members of our Remuneration Committee. While the ESMA Remuneration Guidelines, also adopted by CySEC, mandate the establishment of a remuneration committee only for companies deemed "significant" based on size, internal organization, and the nature of their activities, we have chosen to establish a Remuneration Committee, voluntarily absorbing the associated costs and resources.

The establishment of the Remuneration Committee is vital in the diligent oversight of our remuneration system, emphasizing our steadfast commitment to transparency, fairness, and sustainability in the way we reward our employees.

We remain actively engaged in monitoring market trends and regulatory developments, ensuring that we stay at the forefront of industry best practices. Our dedication to adaptability means that we are open to making necessary adjustments to our remuneration policies in alignment with evolving industry consensus and regulatory guidance, ensuring that we continue to meet the highest standards of governance and sustainability.

Disapplication

While we acknowledge the principles outlined in Article 4 of the SFDR, we understand that our current approach does not precisely mirror the requirements of this regulation. This divergence is primarily attributed to the several considerations, including:

Complexity and Data Challenges - the process requires extensive collection and analysis or reliable data, which can be complex, resource-intensive, and challenging, especially given the diverse holdings in our portfolios and the fact that many of the companies and projects in which we invest do not have clear obligations to disclose the necessary information.
Global Diversification - our portfolios consist of diverse assets spanning various sectors, industries, and geographic regions. Assessing principal adverse impacts across this diversity presents intricacies, and the lack of standardized data across jurisdictions adds to the complexity.
Materiality and Relevance - adverse impacts may not always be material or relevant for all investments within our portfolio. Our approach may prioritize other well-established metrics that align more closely with our investment strategy and our investors' objectives.

Other Investment Criteria

Future Consideration

It is essential to underscore that Argus Management maintains stringent investment criteria that, in some occassions, are in alignment with sustainability principles. We are resolute in our commitment to ethical investing and refrain from allocating capital to industries that raise ethical concerns or are associated with questionable practices. This includes sectors such as alcohol, tobacco, gambling, weapons manufacturing, and sex-related industries. Additionally, we actively avoid companies and projects linked to human rights abuses, labor rights violations, or corporate corruption.

We are dedicated to continually enhancing our practices to align with evolving regulations and improvements in data availability. We remain open to re-evaluating our approach in the future, particularly if circumstances change, with the goal of ensuring that we address the principal adverse impacts on sustainability factors comprehensively.

When feasible, these assessments will adhere to the indicators specified in Table 1 of Annex I of the Commission Delegated Regulation (EU) 2022/1288, commonly referred to as the SFDR Regulatory Technical Standards (SFDR RTS). These assessments encompass a wide array of factors, including but not limited to greenhouse gas emissions, biodiversity, water management, and various social and employee-related matters.

SFDR Disclosures

Our approach

Our Core Principles for Robust Governance

SFDR
Disclosures