The SFDR mandates that financial market participants disclose supplementary information regarding the integration of sustainability risks and potential adverse sustainability impacts on an entity level. To accomplish this, IC Realty LTD is required to publish:

1. Its sustainability risks policy (Article 3 of the SFDR), 
2. information on adverse sustainability impacts (Article 4 of the SFDR), and
3. Remuneration policy (Article 5 of the SFDR).

The subsequent information is predicated on the current comprehension of the regulatory framework in existence and may, as a result, be subject to change in light of supplementary texts published by the regulators. For the most recent information regarding the approach, please reach out to the Company.

The Company believes that transparency concerning the implementation measures related to those regulations serves the best interests of the Funds under management and the investors in those Funds.

IC Realty Ltd – Company Overview

IC Realty Ltd is a Cyprus-based Alternative Investment Fund Manager (AIFM), authorized and regulated by the Cyprus Securities and Exchange Commission (CySEC) under License Number AIFM24/56/2013.

1. Introduction

At IC Realty Ltd, we are committed to responsible investment by integrating environmental, social, and governance (“ESG”) factors and sustainability risks into our investment decision-making processes. This policy outlines our approach to identifying and managing sustainability risks in accordance with Article 3 of Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDR”).

2. Definition of Sustainability Risk

The term “sustainability risk” is defined in Art. 2 (22) of the SFDR as any environmental, social, or governance (‘ESG’) event or condition that, if it materializes, could have a materially negative impact on the value of the investment, whether it is actual or prospective.

3. Integration of Sustainability Risks in Investment Decisions

The Company’s strategy is not defined to manage specifically those Funds that fall under Article 8 or Article 9 of the SFDR—i.e., those that promote environmental or social characteristics or have sustainable investment as their primary objective.

Instead, the Company addresses sustainability risks by seeking to identify such risks at the earliest opportunity and taking appropriate action to reduce any potential negative impact on individual investments or the overall Fund portfolio.

During the pre-investment phase, the Company applies a mandatory Exclusion List, which outlines sectors and activities that are excluded from direct investment due to inherent sustainability risks. Specifically, the Company will not knowingly invest in businesses that:

Directly manufacture, distribute, or sell:

• Anti-personnel landmines,
• Nuclear, chemical, or biological weapons,
• Cluster bombs or munitions;

Engage in systematic use of exploitative or harmful practices such as forced or child labor;

Derive more than 20% of total revenue from:

• The manufacturing of arms, ammunition, or tobacco,
• Upstream coal and/or oil activities (e.g., exploration, extraction, production);

Generate more than 50% of total revenue from upstream coal and/or oil operations;

Are, at the time of investment, headquartered or primarily active in:

• Jurisdictions identified by the FATF as having significant AML/CFT deficiencies and subject to a FATF call to action;
• High-risk third countries as defined by relevant EU regulations;
• Non-cooperative tax jurisdictions according to EU lists;

• Countries scoring below 30 on the Corruption Perceptions Index.

4. Consistency with Risk Management Framework

Sustainability risks are embedded in the overall risk management process of IC Realty Ltd. Material ESG risks are escalated to the Risk Management and Investment Committee and considered alongside financial, operational, and legal risks.

Where significant sustainability risks are identified, the investment may be declined, adjusted, or subject to enhanced monitoring and mitigation strategies.

5. Alignment with Remuneration Policy

In accordance with Article 5 of the SFDR and the firm’s internal Remuneration Policy:

– IC Realty Ltd establishes and applies remuneration frameworks that promote sound and effective risk management, discourage inappropriate risk-taking, and align with the long-term risk profile and investment strategies of the funds it manages.

– The Remuneration Policy applies to senior management, risk takers, control functions, and other key personnel whose professional activities significantly influence the risk profile of the company or its Sub-Funds.

– Variable remuneration is performance-based and explicitly linked to long-term outcomes and sustainable performance of the fund, which includes the management of sustainability risks.

– The policy incorporates deferral and retention mechanisms, internal oversight, independence of control functions, and alignment with investor interests.

– Staff are prohibited from using personal strategies or structures to undermine risk alignment, and variable remuneration may not be used to circumvent applicable legal or regulatory requirements.

By ensuring that performance incentives are aligned with responsible risk-taking, the remuneration framework reinforces the effective integration of sustainability considerations into investment decisions.

6.  Consideration of PAIs on sustainability factors

The Company does not currently consider the principal adverse impacts (PAIs) of its investment decisions on sustainability factors in accordance with Article 4 of the SFDR for any of its products. This decision is based on the Company’s assessment that it is not presently in a position to obtain or assess all the data required under the SFDR, nor to do so in a systematic, consistent, and cost-effective manner across all investment strategies. This is partly due to the fact that many underlying investments are not subject to uniform reporting obligations and may not currently disclose the necessary data. Nevertheless, the Company remains committed to incorporating sustainability considerations into its investment due diligence process, as outlined in Section 3 above.

7. Review and Updates

This Responsible Investment Policy is reviewed annually and updated as necessary to reflect developments in regulation, industry standards, and IC Realty Ltd.’s investment practices.