Article 3: Sustainability Risk Policy

Overview

Oak Ridge Partners S.à r.l. (hereinafter "we" or "the firm") is a professional fund manager subject to the Sustainable Finance Disclosure Regulation (SFDR). In accordance with Article 3 requirements, we hereby disclose that environmental, social, and governance (ESG) factors and sustainability risks are not systematically factored into our investment decision-making processes at this time.

Definition of Sustainability Risk

Under SFDR, a sustainability risk is defined as an environmental, social, or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. Examples include:

• Climate change and transition risks (carbon emissions, energy efficiency)
• Environmental damage and resource depletion (water stress, biodiversity loss)
• Labor practices and human rights violations
• Board diversity and executive compensation misalignment
• Supply chain vulnerabilities and regulatory compliance issues
• Reputational and operational risks related to misconduct

Our Approach to Sustainability Risks

Oak Ridge Partners does not systematically factor environmental, social, and governance (ESG) risks into its investment decision-making process. Our investment strategy focuses on specific criteria and financial analysis rather than sustainability considerations.

Rationale

This approach reflects our view that:

• Our fund strategy focuses on specific investment opportunities within the Special Credit Senior Preferred (SCSP) segment
• Sustainability risk factors are generally not material drivers of investment performance in our target asset class
• Financial analysis and traditional risk metrics remain the primary basis for investment decisions
• Our portfolio composition and holding periods limit the applicability of ESG frameworks

Standard Risk Management

While ESG factors are not formally integrated into our decision-making, we maintain standard operational risk controls and regulatory compliance monitoring to protect our investments and ensure adherence to applicable laws and regulations.

Future Assessment

We acknowledge that regulatory requirements and market practices regarding sustainability risk disclosure continue to evolve. Oak Ridge Partners will periodically reassess whether the integration of ESG factors becomes necessary or appropriate for our fund strategy and will update this disclosure accordingly should circumstances change.

Contact Information

For questions regarding our Sustainability Risk Policy or ESG practices, please contact: