https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R2088

Sustainable Finance Disclosure Regulation (SFDR)

Solas Capital (the “Investment Advisor”) makes the following disclosures in accordance with 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”).

Transparency is important to us

As an investment advisor specialised in sustainable investments, Solas Capital is highly committed to transparency regarding sustainability-related matters. In accordance with SFDR requirements applicable to financial market participants, we provide the following disclosures:

Sustainability Risk Policy (Article 3 SFDR)

As per SFDR, sustainability risks are defined as environmental, social and governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of an investment.

Solas Capital acknowledges the importance of identifying, assessing, and managing sustainability risks as part of its overall advisory process. We believe that robust consideration of sustainability factors can help identify material risks that might impact investment performance.

Our approach to sustainability risk integration involves:

1. Identifying material sustainability risks relevant to specific investment strategies and assets
2. Assessing the potential financial impact of these risks on investment returns
3. Considering these risks when providing investment advice

Solas Capital considers sustainability risks throughout the advisory process, from initial analysis to ongoing monitoring of investment recommendations.

Principal Adverse Impacts Statement (Article 4 SFDR)

Solas Capital is required to ensure that all Projects do not cause significant environmental or social harm. During the due diligence process, the investment manager checks each investment to ensure full compliance with all EU environmental and local laws and to ensure there are no principal adverse impacts.

The investment objective of all of Solas Capital’s investments is to provide Investors with risk adjusted returns by investing in Energy Efficiency Projects. Energy Efficiency Projects must result in a clear and measurable environmental and social return, typically measured through a quantifiable reduction in GHG emissions in view of achieving the long-term global warming objectives of the Paris Agreement.

Regular review of the portfolio to ensure investments are consistent with decarbonization strategy and financing climate friendly practices in line with our policies and exclusion criteria. The environmental impact of each investment must be measured and reported.

Solas Capital is committed to aligning with the standards prescribed in the SFDR regulatory technical standards for the consideration of principal adverse impacts. We continuously monitor our approach to ensure compliance with these standards and will adapt our processes as necessary to maintain alignment with evolving regulatory requirements.

Remuneration Policy (Article 5 SFDR)

Solas Capital’s remuneration policy is consistent with the integration of sustainability risks. Our remuneration structure does not encourage excessive risk-taking with respect to sustainability risks and is linked to responsible performance.

Components of our remuneration framework that address sustainability risk include:

1. A balanced assessment of performance based on both quantitative and qualitative criteria
2. Consideration of compliance with all policies and procedures, including those related to sustainability
3. A remuneration structure designed to avoid incentivizing excessive risk-taking

Updates and Additional Information

Solas Capital will review these disclosures on a regular basis and update them as necessary to reflect changes in our approach to sustainability risk integration or regulatory requirements.

For additional information on our approach to sustainability and responsible investment, please contact [contact information].

Last updated: March 17, 2025