Sustainable Finance Disclosure Regulation

SFDR Disclosure

The following disclosures are made by AIP, LLC (“AIP”) in accordance with Articles 3(1), 4(1)(b) and 5(1) of 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 (“SFDR”).

Information about Policies on Integration of Sustainability Risks

“Sustainability Risk” is defined in SFDR as “an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.” In relation to AIP, Sustainability Risks are risks which, if they occur, would cause a material negative impact on the value of the portfolios of the alternative investment funds managed or advised by AIP (“AIFs”).

AIP recognizes that material sustainability factors can have an impact on an investment’s ability to create, preserve or erode economic value. However, the AIFs do not pursue a sustainability-based investment strategy or limit their investments to those that meet certain sustainability criteria or standards, other than as may be described in the pre-contractual disclosures of a particular AIF. Nevertheless, and where consistent with its fiduciary and other duties and as otherwise commercially practicable, AIP will endeavor to consider financially material sustainability factors, including Sustainability Risks, alongside other factors in its investment decision-making process.

As part of its due diligence process for prospective investments, AIP will seek to identify, assess, monitor and, where necessary, mitigate risks, including Sustainability Risks, on an investment-by-investment basis with a view to preserving the value of the AIFs’ investments, taking account of the relevance and materiality of such risks. In addition, for equity investments in portfolio companies, Sustainability Risks may be integrated into post-investment monitoring and engagement processes. Notwithstanding the above, Sustainability Risks may not be relevant to certain non-core investment activities of the AIFs, such as derivatives for hedging or financial management purposes and cash and cash equivalent positions held for the purposes of liquidity management.

Investors should be aware that integrating Sustainability Risks into the investment decision-making process for the AIFs’ investments does not mean that sustainability integration is the sole or primary consideration for such investment, and any reference to sustainability considerations is not intended to qualify the investment objective of any AIF to seek to maximize risk-adjusted returns on investments. Sustainability factors are, where material, part of a broad mix of factors that AIP may consider within the investment decision-making process, and, depending on the nature of the investment, except to the extent required by law, sustainability factors will not be considered for certain investments or assets. AIP will evaluate and weigh a variety of financial factors, which may include sustainability considerations (where deemed material), within its investment decisions.

No Consideration of Principal Adverse Impacts

AIP does not consider the adverse impacts of its investment decisions on sustainability factors within the meaning of Article 4(1)(b) of SFDR, as the current sustainability impact profile of an investment is not determinative of the investment decisions made by AIP for the AIFs. While AIP may engage with portfolio companies on sustainability-related matters, the AIFs do not seek

specifically to reduce negative externalities related to adverse impacts that may be associated with portfolio companies. AIP will keep this position under review.

Remuneration Policy

AIP’s remuneration policies are consistent with its approach to the integration of Sustainability Risks into the investment decision-making process to ensure sound and effective risk management.

Investment professionals are compensated through a combination of fixed and variable remuneration, and the structure of remuneration is designed to align the long-term interests of investment professionals with the AIFs they manage.

As Sustainability Risks are a type of financial risk, AIP acknowledges that failure to consider such risks, like other financial risks, could have an adverse impact on the performance of investments and the performance of the AIFs managed or advised by it.

AIP’s remuneration structure does not encourage excessive risk-taking, including with respect to Sustainability Risks, and variable remuneration is assessed on a risk-adjusted basis consistent with AIP’s risk management framework.