ESG

• Article 29

• No consideration of the main negative impacts

• Archinvest Exclusion policy

• Sustainability risk policy

• Voting policy and shareholder engagement policy

• Compensation policy

• Archinvest Provision

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DETAILS :

• Article 29

[Extract] Summary presentation of the entity's general approach to taking criteria into account

SG's environmental, social and governance policies and strategies:

Archinvest is an AMF-accredited portfolio management company (GP-21000013) approved in September 2022.

Archinvest's investment strategy is based on the creation of funds of funds. Archinvest has developed a strong belief in the benefits of responsible investment. The management company considers that the integration of environmental, social and governance criteria is important to sustainable management. For this reason, Archinvest now includes an analysis of the management company of the underlying funds, as well as a review of the funds' ESG policies and procedures. Achinvest selects funds that have made ESG a central development focus.

The management company is in the process of building up its capacity to monitor the progress of ESG indicators in the funds.

• No consideration of the main negative impacts

Article 4(1)(b) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on the publication of sustainability-related information in the financial services sector ("SFDR") requires fund managers to publish a statement regarding the consideration of the main negative impacts of investment decisions on sustainability factors as at June 30.

Starting in 2022, Archinvest has put in place processes and measures to assess and monitor ESG issues and sustainability risks (i.e. environmental, social and governance factors) in the investment cycle.

At this stage Archinvest does not consider the main negative impacts prescribed in the EU SFDR regulation, as the Company recognizes the current limitations of the available data to fully comply with the reporting requirements.

The Company's position will be kept under review and closely monitored as the market evolves. To this end, Archinvest will reassess the situation and make any necessary changes in due course, with a view to addressing the main negative impacts in the manner envisaged in article 4(1)a) of SFDR.

• Archinvest Exclusion policy

[Excerpt ] The exclusion policy applies mainly to article 8 and 9 funds within the meaning of SFDR, and may in some cases also apply to article 6 funds.

This exclusion policy is part of Archinvest's Sustainable Investment policy, in line with Archinvest's corporate social responsibility approach. As part of its corporate social responsibility, and as an asset manager, Archinvest has decided to formalize its commitment to the public interest by excluding from its investment perimeter several business sectors with significant negative impacts on the environment and on societal aspects. These exclusions apply to all Archinvest management strategies for Article 8 and 9 funds within the meaning of the SFDR.

The purpose of this policy is to set the general framework for excluding companies engaged in controversial activities with reference to a normative framework that includes:

• The Ottawa and Oslo Conventions and their transposition into French law,

• The FATF's list of high-risk or "non-cooperative" jurisdictions,

• The UN Global Compact.

This normative exclusion policy consists of excluding investment funds that do not comply with our ESG policy, international conventions and internationally recognized frameworks, or national regulatory frameworks.

Archinvest has added sectoral exclusions to its normative exclusions, so as to avoid investing in activities whose ESG impacts are highly criticized.

• Sustainability risk policy

[Extract] Pursuant to Article 3 of Regulation (EU) 2019/2088 ("Disclosures" or "SFDR") and Article L.

533-22-1 of the CMF (resulting from Article 29 of the Energy-Climate Law), financial market players publish information on their websites about their policies for integrating sustainability risks into their investment decision-making processes, including, for French players, risks associated with climate change and biodiversity.

The aim of this policy is to increase transparency on how financial market participants integrate relevant sustainability risks, whether significant or likely to be significant, into their investment decision-making processes.

The policy is based on the principle of double materiality:

Sustainability risk: Impact of external events on product performance (How is the impact of external events on the performance of the financial product integrated into the risk management policy?)

Negative sustainability impacts: Impact of investments made on external sustainability factors (How does the entity ensure that investments made do not cause significant harm to environmental and social objectives?)

• Voting policy and shareholder engagement policy

1. Voting policy

Archinvest markets feeders (a single underlying private equity fund) and multi-funds (several underlying private equity funds). These underlying funds are managed by third-party management companies. In accordance with their regulations, these underlying funds decide whether or not to invest in specific companies. Archinvest does not exercise any decision-making powers in relation to the decision to invest or not in any particular company. Archinvest has no voting rights and cannot make any direct commitments via voting rights.

However, when assessing the funds and the Management Company managing the underlying funds, Archinvest will check that the Management Company's voting policy is consistent with its commitments.

2. Shareholder engagement policy

The shareholder engagement policy will be activated in 2 ways, namely through: 1/ the consistency of the Policy and the conclusions of the Annual Voting Rights Report of the Management Company of the underlying fund in which Archinvest invests and 2/ interviews during due diligence and the study of the Annual Shareholder Engagement Report of third-party Management Companies.

• Compensation policy

Compensation policies linked to the integration of sustainability risks

Sustainability criteria are integrated into the annual appraisal of team members. They are also taken into account in the assessment of the annual bonus.

• Archinvest Provision

Pre-contractual documents, article 10 and periodic reports on the funds are available on request from Archinvest.