Status

Docklands Capital Management B.V. is currently preparing to operate as a registered alternative investment fund manager under the Dutch Alternative Investment Fund Managers Directive (AIFMD) registration regime, subject to registration with the Dutch Authority for the Financial Markets (AFM).

This Sustainability-Related Disclosure has been prepared in anticipation of the commencement of regulated fund management activities and reflects the firm’s intended policies and approach. The disclosure will be reviewed and updated as required following registration and the launch of investment funds.

The first product expected to be managed by Docklands is the MC London Investments Fund, an open-ended Dutch Fund for Joint Account (FGR). This disclosure is intended to apply to that Fund and to any subsequent funds managed by Docklands, unless stated otherwise in the relevant fund documentation.

Sustainable Finance Disclosure Regulation (SFDR)

Docklands recognises the importance of environmental, social and governance (“ESG”) considerations within the investment management industry and supports the objectives of the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”) by promoting transparency regarding the integration of sustainability risks into investment processes.

Intended SFDR Classification

Unless expressly stated otherwise in the relevant fund documentation, any alternative investment funds managed by Docklands following registration — including the MC London Investments Fund — are expected to be classified as Article 6 financial products under SFDR.

Accordingly, the funds are not expected to

• Promote environmental or social characteristics within the meaning of Article 8 SFDR; or
• Have sustainable investment as their investment objective within the meaning of Article 9 SFDR.

Where future investment products adopt a different sustainability classification, the relevant disclosures will be made available in accordance with the applicable regulatory requirements.

Article 6 · MC London Investments Fund

Sustainability Risks

Docklands intends to integrate sustainability risks into its investment decision-making and risk management processes where these risks are considered relevant to the investment strategy and the underlying assets.

Sustainability risks are defined as environmental, social or governance events or conditions that, if they occur, could have an actual or potential material adverse impact on the value of an investment.

Examples include

• Climate change and environmental events
• Resource scarcity and pollution
• Human rights and labour practices
• Corporate governance failures
• Fraud, corruption and regulatory misconduct

The significance of sustainability risks will depend on the nature of each investment strategy, the underlying asset class and the availability of reliable information.

Principal Adverse Impacts

At the commencement of regulated activities, Docklands currently expects not to consider the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors at entity level for the purposes of Article 4 SFDR.

This approach reflects the anticipated size of the organisation, the nature of its investment strategies and the practical availability of relevant sustainability data.

The firm’s position will be reviewed periodically and may change as regulatory requirements, investor expectations and market practices continue to evolve.

Remuneration

Docklands intends to maintain remuneration arrangements that promote sound and effective risk management and do not encourage excessive risk-taking.

Where relevant, sustainability risks will form part of the firm’s overall risk management framework and governance arrangements.

Ongoing Review

This disclosure represents Docklands’ intended approach as part of its regulatory preparation.

Following registration with the AFM and the commencement of regulated activities, this page will be updated to reflect the firm’s final policies, regulatory status and any product-specific sustainability disclosures required under SFDR.