Article 5: Remuneration Policy

Overview

Oak Ridge Partners S.à r.l. maintains a remuneration policy designed to attract and retain qualified professionals while aligning compensation with prudent risk management practices. In accordance with SFDR Article 5, we hereby disclose that environmental, social, and governance (ESG) factors are not incorporated into our remuneration policy.

Scope of Application

This policy applies to:

• All members of the Board of Directors
• Senior management and key decision-makers
• Staff responsible for investment decisions
• Staff responsible for risk management and compliance
• Any employees whose actions materially affect risk exposures

Remuneration Components

Fixed Compensation

Fixed compensation is determined based on:

• Role, responsibility, and seniority within the organization
• Market benchmarking for comparable positions
• Individual competence, experience, and qualifications

Fixed compensation provides the primary remuneration component and is sufficient to attract and retain qualified professionals.

Variable Compensation

Where variable compensation is provided to investment professionals and senior management, it is based on:

• Risk-adjusted investment returns relative to benchmarks
• Quality of investment decisions and due diligence processes
• Adherence to risk limits and operational guidelines
• Long-term fund performance and investor satisfaction

Compensation Philosophy

Oak Ridge Partners does not incorporate environmental, social, or governance (ESG) factors into its remuneration policy. This reflects our view that remuneration decisions should be based on financial performance, professional competence, and operational risk management rather than sustainability considerations.

Risk Management Independence

Our remuneration policy ensures that risk management and compliance personnel maintain independence from investment functions. Compensation for these functions is not directly linked to investment performance, allowing for objective risk assessment and reporting.

Governance and Oversight

Remuneration decisions are subject to the following governance:

• Board of Directors: Approves remuneration policy and reviews alignment with firm strategy
• Remuneration Committee: Oversees implementation and ensures compliance with policy
• HR and Compliance: Monitors remuneration decisions for policy adherence
• Annual Review: Comprehensive assessment of remuneration framework effectiveness

Conflict of Interest Prevention

Our remuneration policy is designed to minimize conflicts of interest by:

• Avoiding compensation structures that incentivize excessive risk-taking
• Aligning investment decisions with long-term fund performance
• Ensuring risk management personnel are not penalized for restricting activities
• Prohibiting personal trading or investments that conflict with fund decisions
• Providing clawback provisions for material policy violations

Governance and Oversight

Remuneration decisions are subject to the following governance:

• Board of Directors: Approves remuneration policy and reviews alignment with firm strategy
• Senior Management: Oversees implementation and compliance with policy
• HR and Compliance: Monitors remuneration decisions for policy adherence
• Annual Review: Comprehensive assessment of remuneration framework effectiveness

Policy Review

This Remuneration Policy is reviewed:

• At least annually by the Board
• Whenever there are material changes to fund strategy or organizational structure
• In response to regulatory developments or industry changes

Contact Information

For questions regarding our Remuneration Policy or ESG compensation alignment, please contact: