This disclosure is made in accordance with the Regulation (EU) 2019/2088 of the European Parliament and Council on sustainability-related disclosures in the financial services sector (the “SFDR”).

For the purposes of these disclosures, “sustainability risk” refers to an environmental, social, or governance event or condition that could materially negatively impact the value of an investment.

Material business or legal risks, including sustainability risks, may cause Berkshire Capitals to decline an investment opportunity unless there is an actionable plan for mitigating such risks during ownership. As part of our due diligence process, we evaluate factors including the company’s industry, size, and geographic presence to determine the materiality of risk factors related to responsible investing.

During late-stage investment diligence, we utilize a proprietary scorecard to assess potentially material sustainability risks. Any significant findings requiring further discussion will be included in the final investment memorandum for evaluation by our investment staff. If we identify potential material risks, our internal teams or external legal counsel may conduct further inquiries or engage specialized third-party resources if necessary.

While we do not anticipate that sustainability risks will materially impact returns, there is no guarantee that our processes will successfully identify and mitigate all material risks.

Currently, Berkshire Capitals does not consider the adverse impacts of investment decisions on sustainability factors as outlined in the SFDR. We have chosen this approach as we believe our existing responsible investing strategy is appropriate, proportional, and tailored to the investment objectives of our funds.

We remain committed to transparency and are continually evaluating our policies to ensure they align with evolving regulations and best practices in responsible investing.