SFDR Disclosure

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Hilmar Capital GP S.à r.l., a private limited liability company (société à responsabilité

limitée) incorporated and existing under the laws of the Grand Duchy of Luxembourg,

registered with the Luxembourg Trade and Companies Register (Registre de

Commerce et des Sociétés) under the number B290579 (the “AIFM”), which

manages an alternative investment fund registered in Luxembourg: HILMAR

CAPITAL DIRECTIONAL FUND SCSp, a Luxembourg special limited partnership

(société en commandite spéciale), formed under the laws of the Grand Duchy of

Luxembourg, registered with the Luxembourg Trade and Companies Register under

the number B291223 (the “AIF”), makes the following sustainability-related

disclosures pursuant to Regulation (EU) 2019/2088 of the European Parliament and

of the Council of 27 November 2019 on sustainability‐related disclosures in the

financial services sector (the “SFDR”).

The AIFM does not actively incorporate sustainability risks into its investment

decision-making process. This means that it does not base its investment choices on

potential sustainability risks, nor does it assess the negative impacts that these risks

may have on the investments. These considerations are not part of the AIFM's

standard due diligence procedures when evaluating investment opportunities.

The AIFM acknowledges the importance of incorporating sustainability principles into

its core processes throughout the investment phase. However, after considering the

size, nature, and scale of its activities, and given that the primary objective of the AIF

is to deliver high returns to its partners across the market cycle, the AIFM believes

that it would not currently be proportionate to comply with the detailed technical

standards under the SFDR regarding the principal adverse impacts of its investment decisions on sustainability factors. Therefore, at this stage, the AIFM does not take

into account the principal adverse impacts of its investment decisions on

sustainability factors, as specified in the SFDR. Nevertheless, the AIFM intends to

monitor industry developments closely and update its approach as the situation

evolves.

As de-minimis / sub-threshold alternative investment fund manager under registration

with the Commission de Surveillance du Secteur Financier (the “CSSF”) in

Luxembourg, in accordance with the requirements of the CSSF, the AIFM does not

have and does not need to have a remuneration guideline or policy.