Sustainability risk policy
The EU SFDR requires financial market participants to disclose information to investors and ensure public transparency through website disclosures regarding the integration of sustainability risks, the consideration of principal adverse impacts (PAI), and remuneration policies related to sustainability risks. Quadrum Capital complies with these requirements, and the relevant EU SFDR disclosures are provided below.

Quadrum Capital adopts the definition of sustainability risk as set out in Article 2(22) of the EU SFDR: “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 accordance with Article 3(1) of the EU SFDR, Quadrum Capital takes sustainability risks into account when making investment decisions for its funds.

No consideration of adverse impacts of investment decisions on sustainability factors
Quadrum Capital does not consider the principal adverse impacts of its investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the EU SFDR. In accordance with Article 4(1)(b) of the EU SFDR, this is based on three considerations:

• First, Quadrum Capital had on average fewer than 500 employees during the last financial year and, given its size, considers it disproportionate, in terms of time, cost, operational capacity and associated complexity, to prepare the detailed statement in the prescribed format under Article 4(2) of the EU SFDR (the "Principal Adverse Impact Statement"), which involves numerous requirements that are largely not relevant to the type of investments Quadrum Capital makes. 
• Second, Quadrum Capital does not promote environmental or social characteristics, or a combination thereof, with its funds, nor does it have the objective of making sustainable investments, and it therefore does not consider it meaningful to measure the potential impacts of its investment decisions in these areas. 
• Third, Quadrum Capital considers that the preparation of an annual statement in the prescribed format is particularly relevant where a fund manager promotes environmental or social characteristics or has sustainable investment objectives, as such a statement enables investors to assess the extent to which the fund manager's related sustainability commitments are being met. As Quadrum Capital does not pursue such objectives, it does not consider the preparation of such a statement to be appropriate or proportionate at this time.

Quadrum Capital will periodically reconsider this decision and the reasons behind it. There may be reasons why Quadrum Capital decides to issue a principal adverse impact statement in the future, for example following requests from investors, as a result of changes in applicable laws and regulations, or if the investment policy is adjusted with regard to sustainability considerations. 

Remuneration policy in relation to the integration of sustainability risks
Compliance with Quadrum Capital’s Responsible Investment Policy, particularly regarding the integration of sustainability risks into the investment decision-making process, may be assessed as part of the performance evaluation for Quadrum Capital’s management and employees, as outlined in Article 5 of the EU SFDR. Quadrum Capital ensures that, through its remuneration structure and Remuneration Policy, no excessive risk-taking is encouraged, including with respect to sustainability risks. In the performance review of Quadrum Capital’s employees and the decision to award bonuses, one of the non-financial criteria considered is whether the employee has complied with internal policies and procedures, including those related to addressing sustainability risks in the investment decision-making process.