Introduction Eriswell Capital Management LLP (“Eriswell Capital Management” or the “firm”) wants to maximise value for its investors and recognises that corporate decision making and investment strategies are ever increasingly focusing on sustainability and Environmental, Social and Governance (ESG) factors. Eriswell Capital Management believes that by applying ESG factors can actually create more value for investors as more sustainable companies are likely to be more robust and resilient to any necessary changes arising in the future from climate change issues which increases their profits and returns over the long run. This in turn means that it should result in greater and more stable returns for more sustainable companies. Generally, these ESG factors can be described as: • Environmental factors consist of considering how a company’s performance as a steward of nature, the environmental risks they face and how these are managed. • Social factors are used to examine how a company manages relationships and its impact on communities. • Governance factors examine issues such as executive pay, audits and shareholders’ rights. Eriswell Capital Management’s ESG policy is that where possible it should incorporate environmental, social, and governance considerations into our existing investment process and is applied to all existing strategies managed by Eriswell Capital Management. Eriswell Capital Management’s investment teams will consider various sources in order to identify if a target investment’s ESG rating including third party information providers. Sustainable Finance Disclosure Regulation (SFDR) Where relevant, Eriswell Capital Management recognises that it must disclose how it complies with the SFDR or explain why it does not apply and publish a Principal Adverse Impact Statement. ERISWELL CAPITAL MANAGEMENT ’s current size means that it believes it is out of scope of the requirements to publish a Principal Adverse Impact Statement. Eriswell Capital Management will monitor the situation and if it chooses to opt in to the SFDR or its size changes so that it is within scope it will publish its first assessment of its “principal adverse impacts” on its website on or before the deadline of 30th June 2022. Additionally, the UK’s decision, post Brexit, not to directly adopt the SFDR has meant that Eriswell Capital Management are awaiting further guidance as to how sustainability will be measured and reported for investment activity which does not have an EU nexus.