SFDR Disclosure

The EU Sustainable Finance Disclosure Regulation (“SFDR”) requires CRC to make a “comply or explain” decision whether to consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR. While CRC does not directly target environmental and social criteria as an investment objective, it has nonetheless implemented positive ESG initiatives and an ESG policy (available on request) and will review its approach to the PAI regime, both at an investment manager and fund level, on an annual basis.