1. Integration of Sustainability Risks

Sustainability Risks are integrated into the investment decision-making process and risk monitoring of the Fund to the extent that they represent potential or actual material risks and/or opportunities to maximising the long-term risk-adjusted returns of the Fund.

Such risks are principally linked to climate-rela ted events resulting from climate change (so-called “physical risks”) or to society’s response to climate change (so-called “transition risks”), which may result in unanticipated losses that could affect the Funds’ investments and financial condition. Societal events (such as inequality, lack of inclusiveness, poor or deteriorating labour relations, insufficient investment in human capital, lack of accident prevention measures, changing customer behaviour, etc.) or governance shortcomings (such as democratic instability, poor sovereign or political party leadership or reputation, recurrent significant breaches of international agreements, bribery issues, insufficient products quality and safety, sales of negative goods, etc.) may also translate into Sustainability Risks.

The Investment Manager’s portfolio managers assess information relevant to Sustainability Risks and take such information into account when forming an investment thesis and making an investment decision. The Investment Manager employs a number of key inputs to assess the impact and relevance of Sustainability Risks with respect to the Funds’ investments, which are incorporated into the Investment Manager’s determination of an “ESG-score” for the sovereigns, sectors and issuers in which the Fund may invest.

The Investment Manager adopts a range of integration approaches many of which aim to evolve over time and in response to further regulatory requirements and market developments, including the following:

• use of external data sources to assess material impacts of sustainability factors, where data is available (primarily Bloomberg ESG Data Service, and in the unlikely event that no data is available, the Investment Manager’s ESG team will make a best efforts estimate);
• development of proprietary overlays and scoring methodologies;
• investment in tools to equip our portfolio managers with access to ESG information for risk management, research and portfolio construction; and
• use of guideline control processes to assist with the monitoring of investment decisions and portfolio composition with respect to ESG considerations, where both possible and applicable.

While Sustainability Risk would not by itself prevent the Investment Manager from making any investment, Sustainability Risk forms part of the Investment Manager’s overall assessment of a potential investment’s relative value. By taking Sustainability Risks into consideration during its investment decision making process, the intention of the Investment Manager is to manage such Sustainability Risks in a way that Sustainability Risks do not have a material negative impact on the value or performance of the Fund over other risks in relation to the investments. While the expectation is that the potential impact of Sustainability Risks on the returns of the Fund is limited there can be no guarantee that losses will not arise.

2. Consideration of principal adverse impacts

For the purposes of Article 7 of the SFDR, the Investment Manager does not currently consider the adverse impacts of investment decisions being made in respect of the Fund on sustainability factors due to the size and scale of the Fund’s activities at this time. The Fund is not currently aligned specifically with indicators for principal adverse impacts on sustainability factors, although its underlying investments may reflect these considerations to an extent via the Investment Manager’s proprietary ESG assessment methodology. The Investment Manager will keep this determination under review.

Additionally, at the present time the Investment Manager does not, when making investment decisions, consider the adverse impacts of decisions on sustainability factors and does not, in its investment advice, consider adverse impacts of investment decisions on sustainability within the meaning of Article 4(1)(a) of the SFDR as it considers the lack of relevant data, regulatory uncertainty and lack of clear methodology do not enable it to do so. The Investment Manager will keep its position in this respect under review as reporting practices develop and may adopt the Article 4 framework in the future if it considers that to be practical and appropriate to do so, including being able to meet the requirements of the Regulatory Technical Standards.

3. Remuneration policy in relation to the integration of sustainability risk

The Investment Manager has adopted a remuneration policy on remuneration practices in relation to its staff whose professional activities have a material impact on the risk profile of the Funds, which seeks to promote sound and effective risk management and discourage excessive risk-taking. This also applies with respect to sustainability risks.

4. Description of the promotion of environmental and social characteristics

1. Summary

The RV Capital Asia Opportunity UCITS Fund (the “Fund”) promotes environmental and social characteristics in accordance with Article 8 of Regulation (EU) 2019/2088 (“SFDR”).

While it does not have sustainable investment as its objective, the Fund promotes ESG characteristics by applying RV Capital’s ESG policy, proprietary assessment methodology, and exclusion list across its investment activities in Asian credit, interest rate and foreign exchange markets.

The Fund does not commit to make any sustainable investments under Article 2(17) of SFDR or Article 3 of the Taxonomy Regulation.

2. No Sustainable Investment Objective

The Fund does not have a sustainable investment objective within the meaning of SFDR. It promotes environmental and/or social characteristics, but does not commit to sustainable investments either aligned or non-aligned with the EU Taxonomy.

3. Environmental or Social Characteristics of the Fund

The Fund promotes the following ESG characteristics:

• Preference for issuers, sovereigns, and sectors with acceptable ESG scores.
• Exclusion of entities involved in:
  • Coal, gambling, or controversial weapons (≥15% revenue threshold for group companies).
  • Violations of UN Global Compact or OECD Guidelines.
  • Activities such as child labour, environmental damage, or pornography.
• Consideration of ESG scores at country, industry, and issuer level to evaluate sustainability performance.

These characteristics are integrated into the Fund’s investment process alongside traditional financial analysis.

4. Investment Strategy

The Fund aims to achieve absolute returns over the medium to long term through long and short positions in Asian bonds, foreign exchange, and interest rate markets.
ESG factors are integrated at four stages:

1. ESG Analysis – Assigning proprietary ESG scores based on quantitative data and qualitative research.
2. Exclusion Screening – Filtering issuers that breach ESG norms.
3. Ongoing Monitoring – Periodic ESG reviews by the Investment Manager’s ESG team.
4. Portfolio Oversight – Maintaining a minimum ESG score threshold across the portfolio.

The Fund’s binding ESG elements include adherence to exclusion criteria and maintaining a minimum weighted-average ESG score for credit positions.

5. Proportion of Investments

6. Monitoring of Environmental or Social Characteristics

The Investment Manager monitors ESG indicators and maintains oversight through:

• Regular review of ESG scores and controversies.
• Exclusion screening updates.
• Portfolio-level ESG scoring tracked via internal tools.
• Quarterly reviews by the Investment Manager’s ESG Committee.

These controls ensure that ESG characteristics are consistently applied throughout the investment lifecycle.

7. Methodologies

The Fund’s ESG scoring combines:

• External ESG data from third-party providers.
• Internal overlays based on proprietary research.
• Sustainability indicators, including:
  • Democracy and rule of law for sovereign issuers.
  • Environmental data (emissions, energy use).
  • Social metrics (labour standards, human rights).
  • Governance factors (ethics, management, anti-corruption).

8. Data Sources and Processing

The Fund uses:

• Third-party ESG data providers, public disclosures, and third-party ESG ratings.
• Proprietary research and qualitative assessments to fill data gaps.
• Data is validated through internal reviews and monitored for consistency.

Limitations include data unavailability or lag in updates for certain issuers, which are mitigated through internal analysis.

9. Limitations to Methodologies and Data

• ESG data in emerging markets may be incomplete or inconsistent.
• The proprietary ESG scoring relies partly on subjective inputs.
• ESG controversies or updates may occur with reporting delays.

The Fund mitigates these through diversified data sources, qualitative overlay analysis, and continuous monitoring by the Investment Manager’s ESG team.

10. Due Diligence

The Investment Manager conducts ESG due diligence during both pre-investment and monitoring stages:

• Screening against exclusion criteria.
• ESG score evaluation at multiple levels.
• Ongoing issuer and sector reviews.
• Review of potential ESG-related controversies.

11. Engagement Policies

The Investment Manager is a signatory to the UN Principles for Responsible Investment (PRI) and to the Singapore Stewardship Principles for Responsible Investors (SSP).

While the Fund does not actively engage as a shareholder in issuers, where possible the Investment Manager:

• Encourages ESG disclosure from counterparties and issuers.
• Incorporates ESG dialogue into counterparty assessment.
• Collaborates with other PRI and SSP signatories to promote responsible investment practices.

12. Designated Reference Benchmark

The Fund does not designate a reference benchmark to measure the attainment of environmental or social characteristics.

13. Taxonomy Alignment

The Fund currently does not invest in environmentally sustainable activities under the EU Taxonomy Regulation.

• 0% aligned with EU Taxonomy.
• 0% in transitional or enabling activities.
• The Fund may reassess this in future updates.

5. Review of disclosures

The Investment Manager, in consultation with the manager, will update relevant disclosures for SFDR at least on an annual basis.

Date of review: 18 November 2025