SFDR – Sustainability-Related Disclosures

Leucadia Asset Management LLC (“we” and “LAM”) is a U.S. investment adviser, registered with the SEC,  and serves as adviser or sub-adviser   for various alternative investment funds ( each, a “Fund”) some of which are marketed within the EU.

The disclosures below explain the details of how LAM complies with the disclosure requirements in accordance with the European Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”).

Policies on the Integration of Sustainability Risks

LAM has adopted an ESG policy which sets forth two levels of ESG engagement: (i) participation in broader ESG initiatives that are driven by how LAM manages the operations of its business and strives to integrate ESG considerations as a fundamental component of its business operations; and (ii) certain Fund strategies advised by LAM specifically incorporate ESG considerations as part of their investment strategy. The manner and extent in which LAM takes sustainability risks into consideration in its investment advice therefore varies from Fund to Fund.

Adverse Sustainability Impacts Statement

Investment decisions made for the Funds may take into account the adverse impacts on sustainability factors as defined in the SFDR.

Where a Fund does not promote environmental or social characteristics or have sustainable investment as an objective, we consider that the best interests of the Fund’s investors are served by following the investment objectives and policies of the Fund.

Where a Fund promotes environmental characteristics, promotes social characteristics, or has sustainable investment as an objective, we will ensure that sustainability risks in relation to the Fund are considered.

LAM takes into account the adverse impacts of sustainability risks to the extent that such risks form an intrinsic part of other risks, such as market risk and operational risk. However, LAM does not consider this to amount to considering the adverse impacts on sustainability factors of investment decisions as set out under the SFDR.

Integration of Sustainability Risks in Remuneration Policies

Our remuneration policy is consistent with, and promotes, sound and effective risk management. It does not promote risk taking which is inconsistent with the risk profile of the Funds. Our remuneration policy does not explicitly take into account sustainability risks.