Sustainability-related Disclosures ((EU) 2019/2088) (‘SFDR’) Website Disclosures

Article 3 Disclosure

The systematic inclusion of Environmental, Social and Governance (ESG) issues in the investment decision process requires, among other things, that sufficient ESG information on the sub-funds’ investments is available. Since Prism Fund’s sub-funds’ investments are funds themselves, which are still in the process of integrating ESG information in their own documents and processes, such information is not yet sufficiently available. In addition, Prism Fund wishes to get more guidance from the EU in the form of delegated acts defining technical screening criteria for the environmental objectives in accordance with article 3(d) Taxonomy Regulation before giving more consideration to the ESG matters. Whilst aiming at assessing the ESG considerations of its sub-funds in the future, Prism Fund intends to do so gradually so as not to undermine its investors’ interests and expected return on their investments.

Article 4 Disclosure

Since the regulatory technical standards (“RTS”) supplementing SFDR which will set out the content, methodology and information required in the principal adverse sustainability impact statement remain in draft form and have been delayed, Prism Fund is not able to confirm that it considers all principal adverse sustainability impacts of investment decisions. Prism Fund’s investment manager does currently not apply an ESG policy and deems sustainability risks not to be relevant as Prism Fund’s fund of funds structure does not support their integration at this time. Pending the Level 2 measures, and as an interim disclosure, the reader is referred to the disclosure made under Article 3 above.

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