Article 4: Principal Adverse Impacts Statement

Definition and Overview

Under the Sustainable Finance Disclosure Regulation (SFDR), Principal Adverse Impacts (PAIs) are defined as the most significant negative effects of investment decisions on sustainability factors related to environmental, social, and human rights issues. These factors include, but are not limited to:

• Greenhouse gas emissions and carbon intensity
• Energy consumption and renewable energy usage
• Water usage and waste management
• Hazardous waste and pollution
• Violations of UN Global Compact or OECD Guidelines
• Controversial weapons and unlawful activities
• Executive pay, board diversity, and labor relations
• Other material social and governance factors

Our Current Position

At this stage, Oak Ridge Partners does not systematically measure, monitor, or implement specific policies to address Principal Adverse Impacts of our investments on sustainability factors. This decision is based on the following considerations:

Fund Strategy and Scope

Our fund strategy focuses on specific, carefully selected investment opportunities within the Special Credit Senior Preferred (SCSP) segment. The limited number and specialized nature of our investments make a standardized PAI framework less applicable to our current portfolio.

Data Availability and Reliability

Comprehensive and reliable PAI data for many investments, particularly in the SCSP asset class, remains limited. We believe it is more prudent to focus on direct engagement and qualitative assessment rather than rely on potentially incomplete or inconsistent data sources.

Operational Materiality

For our specific portfolio companies and investment strategies, a formal PAI monitoring regime may not provide material additional risk insights beyond our existing sustainability risk assessment and engagement processes.

Investment Holding Periods

Given the nature and holding periods of our investments, the measurement and attribution of principal adverse impacts presents practical challenges that may limit the utility of formal PAI metrics.

Our Alternative Approach

Instead of formal PAI measurement, we employ a comprehensive sustainability risk management framework that addresses material sustainability factors through:

Future Considerations

While we do not currently consider PAIs in a formalized manner, we acknowledge that:

• Regulatory requirements for PAI disclosure are evolving
• Data availability and standards for PAI measurement are improving
• Best practices in the industry continue to develop
• The materiality of PAI considerations to our portfolio may change over time

We will continue to assess whether a formalized PAI framework becomes necessary or appropriate for our fund strategy and will update this statement accordingly.

Consistency with Fiduciary Duties

Our decision not to implement a formal PAI framework is consistent with our fiduciary duty to generate appropriate risk-adjusted returns for our investors. We believe our alternative approach to sustainability risk management effectively addresses material negative impacts without creating undue complexity or relying on potentially unreliable data sources.

Review and Update Schedule

This PAI Statement will be reviewed:

• At least annually
• Following any material change in our fund strategy or portfolio composition
• In response to significant regulatory developments or guidance
• When new data sources or methodologies become available

Contact Information

For questions regarding our approach to Principal Adverse Impacts or sustainability practices, please contact: