Policy regarding sustainability risks

A “sustainability risk” (as defined in SFDR) 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 the investment. These risks include, but are not limited to, climate change transition and physical risks, natural resources depletion, waste intensity, labour retention, turnover and unrest, supply chain disruption, corruption and fraud and human rights violations. A sustainability risk trend may arise and impact a specific investment or may have a broader impact on an economic sector, geography or political region or country. The impacts following the occurrence of a sustainability risk may be numerous and vary depending on the specific risk, region and asset class.

Centillion’s risk framework, as it relates to evaluation individual business, considers the following parameters and integrates the following risks in its investment decisions:

• Environmental – A business’s effort to proactively reduce and improve its environmental exposure, thereby also improving its long-term sustainable competitive positioning. Examples of environmental risks to be considered by Centillion are:

  • Increased taxation on environmentally damaging activities

  • Reputational risk as a consequence of harming the environment

  • Increasing input costs as a result of scarcity of materials and availability of supply

• Social – Businesses whose activities are beneficial to all stakeholders including employees, customers, society and shareholders. Examples of social risks to be considered by Centillion are:

  • Reputational risk as a consequence of poorly managing customer or employee relations

  • Excessive employee turnover or difficulty to attract new talent as a result of a non-inclusive workplace

  • Loss of pricing power or ability to attract new customers due to declining customer satisfaction

  • Increasing regulatory burden as a result of resistance to certain business practices by society

• Governance – Businesses with a clear alignment of interest between management, employees and shareholders, including regular and transparent reporting. Examples of governance risks to be considered by Centillion are:

  • Declining employee morale due to a mismatch between management compensation and that of other employees

  • Misrepresentation of underlying earnings power due to opaque reporting

  • Unfair and unbalanced communication to stakeholders

  • Misalignment between management and/or other large shareholders and minority shareholders

• Exclusion – Centillion will exclude certain sectors from its investment universe due to significant negative externalities and related risks.

Not all sustainability risks may have a material negative effect on the value of an investment. Also, the relevancy of each sustainability risk may differ based on the economic sector the investment is active in. Therefore, Centillion will assess available information and (physically) visit the company (and speak to representatives of the company) to determine which sustainability risks are material to consider in the investment decision-making process.

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Sustainability risks and remuneration policy

Under the AIFMD registration regime, Centillion is not required to adopt a remuneration policy. Given the limited size of the organization, it has not been decided to draw up a specific (voluntary) remuneration policy. Due to the absence of (an obligation to draw up) a remuneration policy, Centillion Capital will not integrate sustainability risks in such policy.

Dated 1-Oct-2025