EU Sustainable Finance Disclosure Regulation

This summary sets out the policies of LBC Credit Management, L.P., CIFC Asset Management LLC and CIFC Asset Management Europe Ltd (together, “CIFC” or the “Firm”), on the integration of sustainability in our investment decision-making process.

The Firm has implemented a Sustainability Risks Policy (the “Policy”), which sets out the Firm’s policies in respect of the integration of sustainability risks in its investment decision-making process, as required by the Sustainable Finance Disclosure Regulation (“SFDR”). This summary provides a summary description of the key features of the Policy, for the purposes of disclosure on CIFC’s website and/or in the pre-contractual disclosures for financial products, where applicable.

Under SFDR, “sustainability risk” means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment. The Policy therefore approaches sustainability risk from the perspective of the risk that ESG events might cause a material negative impact on the value of its clients’ investments.

CIFC is a signatory and advocate of the United Nations Supported Principles for Responsible Investment (“PRI”). For reference, the Firm maintains other policies and documentation related to sustainability, including the CIFC Asset Management Corporate Social Responsibility Policy available at www.cifc.com. Also, for additional information on PRI please see: http://www.unpri.org/pri/about.

With respect to sustainability risks, the Policy explains that, as part of CIFC’s broader risk management processes, certain procedures are intended to be implemented to identify, measure, manage, and monitor sustainability risks. These processes include, but are not limited to: (i) the review of sustainability risks that are potentially likely to cause a material negative impact on the value of our clients’ investments, should such risks occur; (ii) the measurement of such risks by considering the likelihood of events contemplated by certain risks occurring and the potential severity of impact to the value of the Firm’s clients’ investments should events contemplated by such risks occur; (iii) the holistic integration of sustainability risks into overall risk management processes and the recognition that sustainability risks are, as a group, one of many potential risks that may, depending on the specific investment opportunity, be relevant to a determination of risk; and (iv) the periodic monitoring of existing client portfolios and taking corrective action where necessary and appropriate.

This summary is provided for information purposes only. In the event of any inconsistency between this summary and either (i) the Policy, or (ii) the terms of any agreement between the Firm and any of its clients, such other document shall prevail. No person should take (or refrain from taking) any action as a result of this summary. To the maximum extent permitted by law, no liability is accepted by the Firm in respect of this summary.

No consideration of sustainability adverse impacts. The Firm has carefully evaluated the requirements of the PAI regime in Article 4 SFDR, and in the draft Regulatory Technical Standards which were published in February 2021 (the “PAI regime”).

The Firm is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market, as to how financial market participants integrate consideration of the adverse impacts of their investment decisions on sustainability factors. However, taking account of the Firm’s size, the nature and scale of our activities and the types of products we make available, we consider that it would be disproportionate to comply with the specific regime in the SFDR. In addition, the Firm notes certain of our products involve portfolio management strategies where it is not possible to conduct detailed diligence on the PAIs of our investments on sustainability factors.

Finally, the Firm is also concerned about the lack of reasonably priced / readily available data to comply with many of the technical reporting requirements of the PAI regime, as we believe that issuers and market data providers are not yet ready to make available all necessary data for the PAI regime.

The Firm will keep its decision not to comply with the PAI regime under regular review, and will formally re-evaluate the decision periodically.