EU Sustainable Finance Disclosure Regulation (SFDR)

Newscape Funds plc (the Company) is authorised by the Central Bank of Ireland as an undertaking for collective investment in transferable securities pursuant to the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011, as amended and as an open-ended umbrella fund with segregated liability between sub-funds.

Under Article 3 of Regulation (EU) 2019/2088 (the SFDR), the Company must publish information about its policies on the integration of sustainability risks in the investment decision-making process.

The impact of sustainability risks on the returns of each of the Company’s Funds has been assessed by the Company’s investment manager, Newscape Capital Group Limited (the Investment Manager) and, taking due account of the Investment Objective, Policies and Strategy of each Fund, the Investment Manager has determined that the impact of sustainability risks are not materially relevant to the returns of the Funds. For that reason, sustainability risks are not integrated into investment decisions for the Funds. The Investment Manager will continue to pursue a relatively fixed investment strategy, as set out in the supplement for each Fund.

Under Article 4 of the SFDR, the Company must publish information about its consideration of the principle adverse impacts of investment decisions on sustainability factors.

Taking due account of the nature and scale of each of the Funds, the Funds do not consider (in the manner specifically contemplated by Article 4(1)(a) of the SFDR) the principal adverse impacts of investment decisions on Sustainability Factors. The Company and the Investment Manager will keep this under review.