REGULATORY DISCLOSURES

---

Sustainability Risk Policy - Article 3 SFDR

ASTATE S.à r.l. is registered as an Alternative Investment Fund Manager (AIFM) under Article 3(2)(a) of the Luxembourg law of 12 July 2013 on alternative investment fund managers.

In accordance with Article 3 of Regulation (EU) 2019/2088 (SFDR), ASTATE S.à r.l. has adopted a policy on the integration of sustainability risks in its investment decision-making process.

Given the nature of the investment strategy pursued by the funds managed by ASTATE S.à r.l. - systematic quantitative trading in financial futures contracts (commodities, equity indices and forex pairs) using proprietary algorithms - sustainability risks as defined under SFDR are not considered to be materially relevant to investment decisions. The strategy does not involve direct investment in equity or debt securities of individual issuers, and therefore exposure to sustainability risks specific to individual companies or sectors is not applicable. ASTATE S.à r.l. will review this assessment periodically and update its policy as appropriate.

Principal Adverse Impacts Statement - Article 4 SFDR

In accordance with Article 4 of Regulation (EU) 2019/2088 (SFDR), ASTATE S.à r.l. does not currently consider the principal adverse impacts (PAI) of its investment decisions on sustainability factors.

This position is justified for the following reasons: (i) ASTATE S.à r.l. is a sub-threshold AIFM registered under Article 3(2)(a) of the AIFM Law and is not subject to mandatory PAI reporting obligations; (ii) the investment strategy focuses exclusively on exchange-traded futures contracts and does not involve direct holdings in corporate securities, making standard PAI indicators inapplicable; and (iii) the aggregate assets under management remain below the thresholds triggering mandatory PAI consideration.

ASTATE S.à r.l. will review this position as its activities develop and will update this statement accordingly.

Last updated: April 2026