The below disclosures are applicable to Oakley Capital GmbH (“OCG”), a German-based investment firm operating under the MiFID II framework. It is our understanding, that both Oakley Capital Limited (“OCL”) as a non-EU investment firm and Oakley Capital Manager Limited (“OCML”) as a non-EU alternative investment fund manager, are not subject to the entity level regulatory requirements of the EU Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088) (“SFDR”). Although our organisation is spread geographically, we operate as one ‘Oakley’, where sustainability is an important factor in our decision-making process. We have therefore chosen to include entity level disclosures for OCL and OCML on a voluntary basis.

Article 3(1) – Entity Level Sustainability Risk Disclosure

Oakley considers sustainability risks and factors during the investment process, as outlined in our Responsible Investment Policy (“Policy”). The Policy outlines Oakley’s approach to the assessment and management of environmental, social and governance (ESG) issues during the investment process. The Policy is applicable across OCL, OCG and OCML, including future managers and successor funds, all staff and all investments made since 2010. The Policy outlines the approach we take to investing responsibly across the Oakley funds and at Oakley as a firm.

The Policy sets out the principals to assess and manage sustainability risks when making an investment decision, and for ongoing management of the portfolio. Oakley will always assess a target company’s ESG risks and opportunities during the due diligence process. In situations where ESG risks or opportunities require further scrutiny, external specialists will be instructed to undertake detailed ESG, or specific topic, assessments. Should material findings be identified, they will be analysed and presented by the deal team to the Investment Committee in the specific ESG section of the Investment Memorandums. If the risks identified during the due diligence process are too great and cannot be appropriately mitigated, Oakley will not pursue the investment.

Oakley has an ESG Committee comprising four Partners and the Head of Sustainability. The Committee meets monthly to monitor progress and members are responsible for the implementation of the Policy.

All Investment Professionals are required to follow the Policy and to consider relevant ESG factors as part of their pre-investment and portfolio monitoring responsibilities. Investment Professionals receive regular training on the Policy, accompanying ESG tools and relevant ESG topics.

Article 4(1)(a) – Principal Adverse Impacts (PAI) Disclosure

Oakley engages with portfolio companies to understand and monitor sustainability factors on a regular basis. Such factors are not currently assessed as prescribed by the draft Regulatory Technical Standards (RTS) of the SFDR. Instead, Oakley uses sustainability factors which are appropriate and material to the sectors we invest in and the companies within our portfolio. However, we will continue to closely monitor the development and finalisation of the RTS and are committed to reviewing our position once the RTS are finalised.

Article 5(1) – Entity Level Remuneration Policy Disclosure

Oakley considers sustainability risks in its remuneration policies to ensure sound and effective risk management.