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Important information

Sustainable Finance Disclosure Regulation Statement

HP Growth Debt Fund GP S.à r.l (“HP Growth”), a private limited company incorporated under the laws of the Grand Duchy of Luxembourg, is required to comply with EU regulations that directly apply to all EU member states, including the Sustainable Finance Disclosure Regulation (2019/2088) (the “SFDR”).

Article 3(1) - Transparency of sustainability risk policies

HP Growth does not have a specific policy on the integration of sustainability risks in its investment decision-making process. A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.

However, Hambro Perks Advisory LLP (HP Growth’s appointed investment adviser) has an ESG internal policy, which can be found below, and which must be factored into any recommendation that is made by Hambro Perks Advisory LLP to HP Growth. Hambro Perks Advisory LLP’s ESG policy requires various sustainability risks to be considered and factored into its recommendation process.

For further information, please email legalnotices@hambroperks.com.

Article 4(1) - Transparency of adverse sustainability impacts at entity level

As per Article 4(1)(b), HP Growth is required to publish information on whether it considers the “adverse impacts of investment decisions on sustainability factors” (the “Principal Adverse Impacts”) under the SFDR. HP Growth does not expressly or specifically consider the Principal Adverse Impacts of investment decisions on sustainability factors in connection with all its products and services, as defined under and in accordance with the SFDR. This is because HP Growth is not, in its view, currently in a position to obtain and/or measure all the data which they would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all its investment strategies to clients and investors. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. In addition, the investment objectives and likely portfolios of the products and services provided by HP Growth are not specifically ESG focused, and HP Growth is unlikely to be able to require underlying investee companies to provide all the data that HP Growth would be required by the SFDR to report.

HP Growth may report to investors in the future on some or all of the Principal Adverse Impacts of investment decisions on sustainability factors in relation to certain strategies on a voluntary basis, applying the same or similar standards as in the SFDR.

In practice, HP Growth intends to consider some or all of the “sustainability factors” listed in the SFDR, including environmental, social and employee matters, respect for human rights, anti-corruption and/or anti-bribery matters by means of its global policy on integration of environmental, social and governance risks and value creation opportunities as part of its investment process and decision making. Further, as noted above, HP Growth’s appointed investment adviser (Hambro Perks Advisory LLP) has an ESG policy which requires consideration of certain sustainability factors. For further information, please email legalnotices@hambroperks.com.

Article 5(1) - Consistency of remuneration policy with integration of sustainability risks

HP Growth does not have in place a standalone remuneration policy on the basis that it does not directly employ any staff. However, the persons involved with advising HP Growth are subject to a group-level remuneration policy (the “Group Remuneration Policy”). The Group Remuneration Policy is monitored and administered by a specifically formed remuneration committee, chaired by an independent non-executive director.

The Group Remuneration Policy does not have any specific quantitative sustainability-focused performance targets. However, notwithstanding this, the Group Remuneration Policy is consistent with the integration of sustainability risks by virtue of the fact that:

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