Amended: September 2026 | Version: 2026.1

PROSPERGATE CAPITAL LTD, is a company registered under the laws of the Republic of Cyprus, with registration number C369583. It is a regulated Cyprus Investment Firm (“CIF“) authorised and regulated by the Cyprus Securities and Exchange Commission (“CySEC“) under license number 361/18. The Company also acts as the External Manager of PROSPERGATE FUND AIFLNP V.C.I.C LTD.

The registered office of the Company is situated at 2 Filiou Zannetou street, 3021 Limassol, Cyprus.

For the purposes of, inter alia, this Sustainability Risk Policy, the Company operates under:

• Regulation (EU) 2019/2088 (the “Sustainable Finance Disclosure Regulation” or “SFDR“), effective from 10 March 2021, introduced by the European Commission as part of the EU Action Plan on Sustainable Finance. Under SFDR, Cypriot firms and fund managers, as other financial market participants in the European Union, are required to disclose specified information on sustainability risks and impacts, with the aim of increasing market transparency and encouraging sustainable investment practices;
• Directive 2014/65/EU (“MiFID II“), as implemented in Cyprus by the Investment Services and Activities and Regulated Markets Law of 2017 (Law 87(I)/2017), as amended, together with Delegated Regulation (EU) 2017/565, as amended by Delegated Regulation (EU) 2021/1253 in respect of the integration of sustainability factors, risks and preferences;
• Directive 2011/61/EU on Alternative Investment Fund Managers, the Alternative Investment Funds Law of 2018 (L.124(I)/2018), and, in respect of the Company’s role as External Manager, the Small AIFM Law.

The purpose of this document is to address SFDR Article 3 on transparency of sustainability risk policies, which provides that “financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process.”

This Policy describes the Company’s approach to handling and monitoring sustainability risks that may arise during the investment decision-making process in relation to (i) the discretionary portfolio management services provided to clients in the Company’s capacity as a CIF, and (ii) the alternative investment fund(s) managed in its capacity as a Small AIFM (together, the “Products“). The Company is a financial market participant under Article 2(1) SFDR in both capacities. All Products are classified under Article 6 SFDR: they neither promote environmental or social characteristics (Article 8 SFDR) nor have sustainable investment as their objective (Article 9 SFDR).

Within this Policy, the Company aims to:

1. set the framework for the manner in which sustainability risks are integrated into its investment decisions; and
2. describe the approach taken to manage and monitor sustainability risks that may have a material influence on the Products.

At Prospergate Capital Ltd, we do not offer portfolios or funds that seek to promote one or more environmental or social characteristics, nor do we have sustainable investment as an objective. However, as a financial market participant, we comply with SFDR to ensure that we transparently disclose our sustainability risk policies and how they are applied across the Products.

The Company integrates sustainability risks from a financial-materiality perspective, i.e. it assesses whether an ESG event or condition could cause an actual or potential material negative impact on the value of an investment.

Sustainability risks form part of the Company’s investment risk management framework and are considered alongside other risk factors as part of the wider investment decision-making process. In accordance with Article 6(1)(b) SFDR, the Company’s current assessment is that the likely impact of sustainability risks on the returns of the Products is not material, given the risk-mitigation and due diligence measures it applies. Should sustainability risks identified in future have a material negative impact on the returns of any Product, the Company will put in place relevant risk-mitigation strategies and update its disclosures accordingly.

Under Article 2(22) SFDR, sustainability risks refer to environmental, social and governance (“ESG“) factors that could have a material impact on the financial performance of an investment. These risks include:

• Environmental risks: such as climate change, natural resource depletion, water scarcity, pollution, and biodiversity loss.
• Social risks: including labour practices, human rights violations, product safety, community relations, and supply chain ethics.
• Governance risks: relating to corporate governance practices, executive compensation, board composition, and shareholder rights.

Sustainability risks can have both short- and long-term effects on the value of investments and, as such, are considered as part of the Company’s investment decisions, even where the Products do not have a specific ESG focus.

At Prospergate Capital Ltd, sustainability risks are integrated into investment decision-making through the following processes:

• Identification of sustainability risks: the Company identifies and assesses sustainability risks that may arise when making investment decisions.
• Due diligence and risk management: ESG factors are incorporated into the Company’s overall risk management framework; each investment is analysed for potential exposure to environmental, social and governance risks that may affect its long-term financial performance.
• Continuous monitoring: the Company continuously monitors the sustainability risks associated with its investments, ensuring that changes in the regulatory landscape are reflected in its risk assessment models.
• Client sustainability preferences (CIF): as part of the suitability assessment for portfolio management clients, the Company obtains information on clients’ sustainability preferences. As the Products are classified under Article 6 SFDR, they are not presented as meeting any such preferences; where a client expresses sustainability preferences that the Products cannot meet, this is explained to the client and any adaptation of those preferences is documented.

Under Article 5 SFDR, a financial market participant such as Prospergate must include in its remuneration policy information on the integration of sustainability risks and how its remuneration structure is consistent with that integration.

In its Remuneration Policy, the Company promotes sound and effective risk management consistent with the objectives of its business and risk strategy, corporate culture and values, and risk culture — including with regard to ESG risk factors — the Company’s long-term interests, and the measures used to avoid conflicts of interest and discourage excessive risk-taking. The Company’s Remuneration Policy is designed to support Prospergate’s strategic business objectives and core values in an appropriately risk-controlled manner, providing remuneration mechanisms that allow Prospergate to attract, retain and motivate its staff consistently with applicable remuneration requirements.

Further to the above, the Company’s performance management process — and therefore its remuneration arrangements — integrates non-financial methodologies to promote sound and effective risk management with respect to sustainability risks. This ensures that the Company’s remuneration structure does not encourage excessive risk-taking with respect to sustainability risks, and remains linked to risk-adjusted performance. To this end, all Company employees are expected to support the business in undertaking its activities responsibly, including sustainability considerations in their roles and decision-making.

Under Article 4(1)(b) SFDR, the Company, which does not exceed the 500-employee threshold, does not currently consider the principal adverse impacts (“PAI“) of its investment decisions on sustainability factors, and publishes on its website the reasons for this and, where relevant, whether and when it intends to do so.

The Products are non-ESG-focused, with an emphasis on traditional financial performance factors such as returns, liquidity and risk management; they follow standard market practice and are not designed to incorporate sustainability factors as such. The size of the Company, the nature and scale of its activities and the limited availability of reliable PAI data for the instruments in which it invests mean that such consideration would be disproportionate at present. The Company reassesses this position at least annually and, should sustainability factors become material or the position otherwise change, will consider PAI in accordance with Article 4 SFDR.

The Company is committed to transparent communication regarding sustainability risks. Its approach includes:

• Periodic reporting: as the Products fall under Article 6 SFDR, no product-level periodic sustainability reporting (Article 11 SFDR) applies. Such reporting will be provided if any Product is reclassified in future.
• Pre-contractual disclosures: in accordance with Article 6 SFDR, the Company includes in its pre-contractual documentation (the portfolio management agreement and related client information for CIF clients, and the offering documents of the AIFLNP) a description of how sustainability risks are integrated and the results of its assessment of their likely impact on returns, updated to reflect any material change.

As all Products are classified under Article 6 SFDR, the Company is not required to provide product-specific disclosures on how its products meet environmental or social characteristics (Article 8 SFDR) or sustainable investment objectives (Article 9 SFDR). It will, however, continue to meet the entity-level and Article 6 transparency obligations that do apply.

Where the Company identifies a type of conflict of interest, the existence of which may damage the interests of a client or of a fund under management — including conflicts of interest that may arise as a result of the integration of sustainability risks into the Company’s processes, systems and internal controls, and conflicts that could give rise to mis-selling or misrepresentation of investment strategies — relevant action is taken to manage and prevent such conflicts, in accordance with the Company’s Conflict of Interest Policy. It should be noted that, at present, no conflicts of interest have been identified as arising specifically in connection with sustainability risks.

This Policy may be updated and changed from time to time in order to comply with new legal or regulatory requirements or amendments, including any changes arising from the ongoing review of the SFDR by the European Commission. Any updated version will be published on the Company’s website.

The Company monitors and reviews this Policy on an annual basis, and it is acknowledged by the Board of Directors of the Company after every review and/or material change to its content.

If you would like to contact us with any queries or comments, please send an email to [email protected]

Prospergate Capital Ltd is a Cyprus Investment Firm (“CIF”) authorised by the Cyprus Securities and Exchange Commission (“CySEC”) (licence number 361/18), with a licence to perform portfolio management services, and is also registered with CySEC as a Small AIFM under the Small AIFM Law, acting as External Manager of Prospergate Fund AIFLNP V.C.I.C Ltd. The Company externally manages, on a discretionary basis, client funds held with global financial institutions pursuant to a pre-defined investment strategy. As the risk of investing in certain financial instruments is generally high and the market value of such instruments may be affected by factors such as economic and political conditions, foreign exchange fluctuations, and shifts in market sentiment, the investor bears full responsibility for the risks associated with such investments and acknowledges that investment yield and/or capital preservation are not guaranteed. Investors should ensure they are fully aware of the potential risks connected with portfolio management services and their chosen investment strategy, and should note that some strategies carry a higher degree of risk than others, which may result in the loss of all or part of the initial investment. Past performance does not guarantee, and should not be taken as an indication of, future returns.

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