EU Sustainable Finance Disclosure Regulation (SFDR)
This paragraph sets out certain disclosures by Contingency Capital LLC, as a non-EU Alternative Investment Fund Manager, for the purposes of compliance with Articles 3 and 4 of the EU Sustainable Finance Disclosure Regulation, or SFRD, in relation to certain fund(s) it manages which are registered or notified under Alternative Investment Fund Managers Directive national private placement regimes in certain EU and EEA jurisdictions. This disclosure is subject to any disclosures that may be made in the offering documents and other documents issued by such funds managed by Contingency Capital. The SFDR requires Contingency Capital to disclose whether, and if so how, it considers the principal adverse impacts of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR. Contingency Capital does not consider the principal adverse impacts of its investment decisions on sustainability factors (either generally or in relation to its funds), as the investment objective and approach of each fund in respect of which Contingency Capital has been appointed as investment manager does not provide that principal adverse impacts be taken into account. Contingency Capital will keep its decision not to comply with the principal adverse impacts regime under regular review. The SFDR requires Contingency Capital to disclose information on its policy on the integration of “sustainability risks” in its investment decision making process. Contingency Capital believes that ESG considerations could influence the risk-return profile of its investments; however, sustainability risk is not the only consideration in Contingency Capital’s investment decision making, and is one of many risks which may, depending on the specific investment opportunity, be deemed relevant by Contingency Capital on a case by case basis.