SFDR Article 8 Website Disclosure

EPM Private Opportunities ELTIF

Summary

EPM Private Opportunities ELTIF (the "Feeder Fund") is classified as an Article 8 financial product under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector ("SFDR"). This means the Feeder Fund promotes environmental and social characteristics. The Feeder Fund is a feeder ELTIF (as such term is construed under the ELTIF Regulation).

The Feeder Fund pursues its investment objective by investing substantially all of its assets (target: 99%) into LBPAM Private Opportunities (the "Master Fund"), managed by LBP AM. The Master Fund, in turn, invests in other investment funds, whether managed by its own management company or by third-party managers, which promote environmental and/or social characteristics or which have a sustainable investment objective, and whose ESG methodologies are assessed as sufficiently robust by LBP AM.

No Sustainable Investment Objective

The Feeder Fund does not have a sustainable investment objective but does promote environmental and social characteristics and is therefore classified as an Article 8 financial product under SFDR, not an Article 9 product.

Although sustainable investment is not its objective, the Feeder Fund has made a voluntary commitment to indirectly invest a minimum of 25% of its net assets in investments that qualify as sustainable investments. This commitment is binding and forms part of the Feeder Fund's asset allocation obligations, as further described in the "Proportion of Investments" section below.

Sustainable investments are not made directly at the level of the Feeder Fund or the Master Fund. Given the Feeder Fund's feeder fund structure, sustainable investments are made at the level of the underlying investment funds in which the Master Fund invests. Each underlying investment fund manager is responsible for determining whether its investments qualify as sustainable investments, and may apply its own definitions and methodologies for this purpose. These may differ between funds.

Details of the sustainable investment objectives and definitions applied by underlying investment funds are set out in the relevant pre-contractual disclosures of those funds.

Environmental or Social Characteristics of the Financial Product

The Feeder Fund promotes environmental and social characteristics indirectly by investing substantially all of its assets (target: 99%) into the Master Fund.

The Master Fund, in turn, invests in underlying investment funds which:

- Promote environmental and/or social characteristics; and/or

- Have a sustainable investment objective within the meaning of SFDR,

and whose ESG methodologies are assessed as sufficiently robust by the Master Fund management company.

No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the Feeder Fund.

Investment Strategy

The Feeder Fund achieves the environmental and social characteristics it promotes through the investment strategy applied by the Master Fund.

Investments in investment funds managed by third-party management companies

For such investments, the Master Fund management company relies on ESG rating methodologies applied at management company level, which assess in particular:

- Whether the management company is a signatory to the UN Principles for Responsible Investment (UN PRI);

- The integration of ESG criteria into investment decision-making and monitoring;

- Governance practices at the level of the management company and underlying portfolio companies; and

- ESG engagement practices implemented by the management company.

Investments in investment funds managed by the Master Fund management company

Where the Master Fund invests in funds managed by its own management company, those funds apply a proprietary socially responsible investment (SRI) approach aimed at identifying issuers that:

- Provide solutions to long-term environmental and social challenges; and

- Anticipate sustainability risks through responsible conduct.

This approach is structured around four pillars:

- Responsible governance;

- Sustainable resource management;

- Energy transition; and

- Development of territories.

Binding Elements of the Investment Strategy

The following elements are binding on an ongoing basis:

- For investments in investment funds managed by third-party management companies (excluding money market funds): the ESG rating of the management company must be at least "B".

- Furthermore, for investments in investment funds managed by the Master Fund management company: the application of an exclusion policy, which excludes investments relating to:

  - Cluster munitions;
  - Tobacco production;
  - Prostitution and exploitation of prostitution;
  - Gambling;
  - Severe, systematic and unremedied human rights violations; and
  - Coal, oil and gas activities, in accordance with the applicable exclusion policy.

No committed minimum reduction rate is applied prior to the application of the investment strategy.

Good Governance Practices

Good governance practices are assessed as follows:

- For investment funds managed by the Master Fund management company, governance is a core component of ESG analysis and covers matters such as balance of power, executive remuneration and business ethics.

- For investment funds managed by third-party management companies, governance assessments are carried out by the respective management companies of the underlying investment funds.

The Master Fund management company ensures that the methodologies applied by underlying investment funds appropriately assess good governance practices.

Proportion of Investments

The Feeder Fund commits to:

- At least 65% of its portfolio being invested in investments aligned with the environmental and social characteristics promoted; and

- At least 25% of its net assets being invested in sustainable investments.

The remaining portion of the portfolio may be used for hedging, liquidity management, diversification or return-seeking purposes, and no minimum environmental or social safeguards apply to those investments.

Monitoring of Environmental or Social Characteristics

The monitoring of the environmental and social characteristics promoted by the Feeder Fund operates at two levels: at the level of the Master Fund, by its management company, LBP AM; and at the level of the Feeder Fund, by Titanbay Ireland Limited (the "AIFM").

Monitoring by LBP AM (Master Fund level)

LBP AM is responsible for monitoring compliance with the sustainability constraints applicable to the Master Fund as set out in the Master Fund's own prospectus. This includes ongoing monitoring of the sustainability indicators described in the "Methodologies" section of this disclosure, in particular the ESG ratings of the third-party management companies whose investment funds the Master Fund invests in.

LBP AM's monitoring is conducted by its investment and risk management functions, and compliance with the extra-financial management process is subject to periodic review by LBP AM's Compliance and Internal Control function.

Information on LBP AM's responsible investment practices is published in LBP AM's annual Responsible Investment report, available on the LBP AM website.

Oversight by the AIFM (Feeder Fund level)

Titanbay Ireland Limited, as AIFM to the Feeder Fund, monitors on an ongoing basis the continued alignment of the Master Fund with the environmental and social characteristics promoted by the Feeder Fund.

This monitoring forms part of the AIFM's broader due diligence and oversight of the Master Fund and its management company, and includes the review of:

- Periodic sustainability reporting and responsible investment disclosures produced by LBP AM;

- The Master Fund's pre-contractual and periodic SFDR disclosures;

- Information provided by LBP AM on an ongoing basis pursuant to the Master-Feeder Agreement; and

- Any material changes to the Master Fund's ESG framework, exclusion policies, or investment strategy notified by LBP AM.

Where the AIFM identifies any concern regarding the Master Fund's continued alignment with the Feeder Fund's environmental and social characteristics, it will engage with LBP AM to seek clarification or, where necessary, appropriate remedial action.

Methodologies

Binding sustainability indicator

The ESG rating of third-party management companies whose investment funds are invested in by the Master Fund.

The sustainability indicator used is the number of third-party management companies with an ESG rating below "B".

The ESG rating scale is assigned by the Master Fund Management Company's proprietary rating methodology comprising eight scores: A+, A, A-, B+, B, B-, C and D (with A+ being the highest and D the lowest).

Do No Significant Harm (DNSH)

The assessment of whether sustainable investments do not cause significant harm to environmental or social objectives is carried out by the management companies of the underlying investment funds.

The Master Fund management company ensures that the methodologies applied by underlying investment funds appropriately integrate controls for potential significant harm to other environmental or social objectives.

Principal Adverse Impacts on Sustainability Factors

The Feeder Fund considers principal adverse impacts on sustainability factors within the meaning of SFDR.

- For investments in investment funds managed by the Master Fund management company, principal adverse impacts are considered through:

  - The application of ESG-based exclusions; and
  - ESG analysis applied during investment selection and portfolio monitoring.

- For investments in investment funds managed by third-party management companies, preference is given to investment funds that implement a responsible or sustainable investment approach compatible with the ESG philosophy of the Master Fund management company.

The Feeder Fund does not itself calculate principal adverse impact indicators. The consideration of principal adverse impacts is carried out at the level of the underlying investment funds in accordance with their respective methodologies.

Further information on the consideration of principal adverse impacts is available in:

- The Master Fund management company's responsible investment reports; and

- The Feeder Fund's annual report.

Data Sources and Processing

1. Data sources used to achieve each of the environmental or social characteristics promoted by the Financial Product:

The Master Fund Management Company applies a multi-source approach to ensure better coverage as well as a diversity of analytical perspectives. The selected suppliers are mainly the following: Bloomberg, CDC Biodiversité, CDP, Ethifinance, ISS ESG, LSEG, Moody's ESG and MSCI.

2. Measures taken to guarantee data quality:

The Master Fund Management Company systematically carries out qualitative and quantitative due diligence when adding a new supplier.

This due diligence is supplemented by statistical studies carried out periodically to identify inconsistencies between the indicators of different suppliers on the same subject. In particular, these analyses may lead to the disqualification of an indicator deemed irrelevant, or to the correction of biases arising from methodological differences.

3. Data processing methods:

Supplier data is integrated into a data processing tool developed by the Master Fund Management Company. This tool gathers and aggregates the data to provide a single set of data used to monitor the environmental or social characteristics of the Financial Product.

4. Proportion of data estimated:

The Master Fund Management Company is not currently in a position to assess precisely the proportion of data that is estimated. The latter is likely to be fairly substantial, given the broad spectrum of themes covered by the extra-financial analysis and the fact that a significant proportion of the data transmitted by suppliers is based on qualitative analyses or proxies, and that the data processing tool developed by the Master Fund Management Company performs a statistical reprocessing of the integrated data.

The proportion of measured data will increase with the gradual implementation of European regulations governing the publication of non-financial data by issuers.

Limitation to Methodologies and Data

The diversity of investments made by the Master Fund means that they are unable to provide full coverage of the environmental and social characteristics of all the stocks in their portfolios, especially as some markets are not themselves covered by data providers, which means that they are unable to take full account of the contribution of each stock in their portfolio to the sustainability indicators used to measure achievement of environmental and social objectives. This is particularly the case for small caps and non-European issuers, which are not subject to the same regulatory transparency constraints.

The Master Fund Management Company responds to these difficulties by diversifying data suppliers ("multi-source" approach).

The quantity of data handled does not allow for quality control on a case-by-case basis. The Master Fund Management Company therefore favours two approaches: (i) control of the rating methodology applied by data suppliers, and (ii) statistical control of the data as a whole. In addition, the "multi-source" approach applied by the Master Fund Management Company tends to smooth out potential individual assessment errors by data providers.

In addition, the absence of data on certain indicators used to verify that the environmental or social characteristics promoted are indeed achieved is compensated for by the use of other indicators on similar themes, as well as by a control of controversies affecting the issuer in question.

Due Diligence

The consideration of environmental and social characteristics and principal adverse impacts is based on the due diligence carried out by the management companies of the underlying investment funds in which the Master Fund invests. This due diligence includes the assessment of ESG policies, governance frameworks, exclusion policies, and the integration of sustainability risks and principal adverse impact indicators by the underlying investment fund managers. The Master Fund Management Company ensures that the methodologies applied by the underlying investment funds are sufficiently robust and consistent with the environmental and/or social characteristics promoted by the Feeder Fund.

In addition, prior to and on an ongoing basis, the AIFM carries out due diligence on the Master Fund and its management company in relation to the integration of environmental and social characteristics.

This due diligence includes an assessment of the Master Fund's investment strategy, ESG framework, exclusion policies, sustainability risk integration, SFDR classification and disclosures, as well as the governance and organisational arrangements supporting the promotion of environmental and/or social characteristics.

The AIFM also monitors, on an ongoing basis, the continued alignment of the Master Fund with the environmental and/or social characteristics promoted by the Feeder Fund, including through the review of periodic reporting, responsible investment disclosures and other information provided by the Master Fund Management Company.

Engagement Policies

The Feeder Fund does not engage directly with investee companies. Engagement activities, where applicable, are carried out by the management companies of the underlying investment funds in which the Master Fund invests. The Master Fund Management Company assesses the existence and effectiveness of engagement practices applied by the underlying investment fund managers as part of its ESG due diligence.

Designated Reference Benchmark

No index has been designated as a reference benchmark to determine whether the Feeder Fund is aligned with the environmental or social characteristics it promotes.

EU Taxonomy Alignment

The Feeder Fund promotes environmental and/or social characteristics and is committed to partially making sustainable investments with an environmental or social objective.

However, the Feeder Fund does not commit to making a minimum proportion of sustainable investments with an environmental objective aligned with the EU Taxonomy.

The methodology applied by the Management Company does not allow the contribution of investments to be measured according to the definition of the European Taxonomy.

Under these conditions, the minimum proportion of sustainable investments with an environmental objective aligned with the EU Taxonomy is 0% of total investments.

The Feeder Fund does not invest in fossil gas and/or nuclear energy related activities that comply with the EU Taxonomy.

The Feeder Fund does not commit to a minimum proportion of investments in transitional and enabling activities.

Further Information

Additional product-specific sustainability information is available in the Feeder Fund's prospectus and annual reports.
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