REGULATORY CONTEXT

Article 173 of the Energy Transition for Green Growth Act No. 2015-992 of 17 August 2015 amends Article L. 533-22-1 of the Monetary and Financial Code, which now provides that: "management companies make available to the subscribers of each of the UCIs that they manage information on how to take into account in their investment policy criteria relating to the respect of social, environmental and governance quality objectives. They specify the nature of these criteria and the way in which they are applied according to a standard form prescribed by decree. They indicate how they exercise the voting rights attached to the financial instruments resulting from these choices"

1. General approach for taking ESG criteria into account
HTL Capital Management does not currently take into account the social, environmental and quality of governance (ESG) criteria in the fund management process. HTL Capital Management reserves the right to modify this position and opt for a commitment to meet these criteria.

2. Content, frequency and means used to inform clients
HTL Capital Management communicates on its website (Regulatory Information) and "ESG Investor Information".

3. UCIs concerned by the consideration of ESG criteria
Funds managed by HTL Capital Management are not affected by the inclusion of ESG criteria.

4. Membership of the entity in initiatives, codes and labels
HTL Capital Management is not a signatory to the United Nations Principles for Responsible Investment (PRI) (more information on www.unpri.org).