ESG responsibility

 Cloudbreak Sarls views environmental, social, and governance (“ESG”) factors as important for making sound investment decisions in the funds under management.

Provisions of the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (the “SFDR”)

Cloudbreak makes the following disclosures in accordance with Articles 3(1) and 4(1)(b) of the SFDR

Consideration of sustainability adverse impacts

Adverse sustainability impacts relate to the risk that the investments made via the funds managed by Cloudbreak S.à r.l. (the "Luxembourg AIFM"), in its capacity as an alternative investment fund manager, may have on sustainability factors.

The Luxembourg AIFM believes that considerations concerning sustainability factors play a crucial role in being a responsible alternative investment funds manager and are a key driver in creating long-term value for all stakeholders and for society by making its business and the managed assets “future-proof”.

Nevertheless, pursuant to article 4.1(b) of the SFDR, the Luxembourg AIFM does not consider the adverse impacts of investment decisions on the basis that, in the context of the current investment strategies of the funds under management, it does not integrate in its processes any due diligence on the principal adverse impacts of the investment decisions. However, the Luxembourg AIFM intends to review its position in order to be in accordance with the market expectations during the year.

Approach to sustainability risk

 A sustainability risk means 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 the investment. To the extent that environmental, social and governance factors represent material risks and/or opportunities to maximize long-term risk-adjusted returns, they might be considered as part of the investment decision-making. Nevertheless, the Luxembourg AIFM decides that taking into consideration the sustainability risks on the current returns of the investments is temporarily not relevant for its investment strategy.