Lux Aeterna Capital Limited

Climate-related Risks Disclosure

Introduction

Lux Aeterna Capital Limited (“Lux Aeterna” or the “Firm”) provides investment management services to institutional and individual investors worldwide. Lux Aeterna owes its clients a fiduciary duty to act, at all times, in their best interests and treat clients fairly and honestly; as a result of the SFC’s revision of the Fund Manager’s Code of Conduct (“FMCC”) in August 2022, the Firm also needs to consider the importance of climate-related risk factors which may impact the Firm’s investment and risk management processes, depending on Lux Aeterna’s internal assessments of its climate-risk exposure.

Consistent with regulatory and investor trends of focusing on climate-risk related considerations, Lux Aeterna has prepared this specific disclosure to its investors to provide greater insight into the Firm’s approach to climate-risk in accordance with the SFC’s regulations.

Governance Structure

The Firm’s Board of Directors (the “Board”), oversees the incorporation and implementation of the firm’s climate-related risk considerations and strategies.

The Firm has assigned the management team the primary responsibility of managing climate-related risks obligations per the SFC’s FMCC. The management team reports to the Board and its current role in respect of managing climate-related risks is to periodically review the Firm’s climate-risk exposure and its material impact on the Firm’s portfolios on an annual basis.

Investment and Risk Management

Lux Aeterna’s approach to considering climate-related risk implications for its funds is determined by the Firm’s assessment as to the relevancy of fund’s investment strategy in relation to climate-related risks and the level of materiality that said risks may pose on the performance of the fund.

Lux Aeterna has considered that as a result of its investment strategy, that climate-related risks are deemed relevant but are not material to the performance of Lux Aeterna’s portfolio performance and operations. The materiality assessment is based both on a qualitative approach, using SASB industry standards, and a quantitative approach, weighting the portfolio’s exposure to climate-related risk per sector.

As a result of Lux Aeterna’s assessment of its climate risk relevancy and materiality, the Firm is not obliged to formally implement climate-related risk procedures, as stipulated in the SFC Fund Manager Code of Conduct, in its investment management and risk management processes. Lux Aeterna’s management team will re-evaluate this assessment on an annual basis which will be reviewed and ratified by the Board.