SFDR Disclosures

Article 3 – Sustainability Risk Policy

As a “financial market participant” in terms of Regulation (EU) 2019/2088 (the Sustainable Finance Disclosure Regulation or “SFDR”), the Company is subject to certain requirements relating to sustainability-related disclosures in the financial services sector.
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The Company performs a sustainability risk assessment to firstly determine the relevance of sustainability risks in respect of its Funds, and secondly disclose the relevance or otherwise of sustainability risks in the Offering Supplement of the respective Fund. Investors are urged to read the Offering Supplement to determine whether sustainability risks are integrated in the investment decision-making process in respect of the relevant Fund.

Article 4 – Principal Adverse Impacts (PAI) Statement
Challenger Impact High Income Fund I

The Company has performed a sustainability risk assessment to determine the relevance of sustainability risks in respect of the Sub-Fund. Whilst it is the Company’s policy to invest in legitimate and recognized assets within reputable jurisdictions, the Company’s objectives are not limited towards investing in assets which promote environmental or social characteristics, and it does not adopt any ad hoc approach to the analysis of sustainability issues.
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The Company is strongly committed to the promotion of environmental, social and governance (ESG) factors, however following an assessment on the sustainability risks the Company has decided not to consider the adverse impacts of its investment decisions on sustainability factors.
This decision is the consequence of a cost-benefit analysis, where, due to its small size and the nature and scale of its activities, the Company finds that the full application of the Regulation may damage its profitability with a negative impact to its investors. The Company has also considered that the adverse impact of its investment decisions on sustainability factors is limited, and that non-financial data is not available in satisfactory quality and quantity to allow adequate assessment. Measuring the principal adverse impacts of investment decisions is considered a complex exercise requiring methodologies and significant resources dedicated solely to data analysis and reporting. Accordingly, the Company shall disclose on its website that it does not undertake an assessment of the PAIs of its investment decisions on ESG factors.

Endeavour Real Assets Fund II

As a Notified Alternative Investment Fund, the Company is subject to Regulation (EU) 2019/2088, the SFDR. As a “financial market participant,” the Company has performed a sustainability risk assessment to determine the relevance of sustainability risks in respect of the Sub-Fund.
Whilst it is the Company’s policy to invest in legitimate and recognized assets within reputable jurisdictions, the Company’s objectives are not limited towards investing in assets which promote environmental or social characteristics, and the Company does not adopt any ad hoc approach to the analysis of sustainability issues.
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The Company is strongly committed to the promotion of environmental, social and governance factors, however following an assessment of sustainability risks the Company has decided not to consider the adverse impacts of its investment decisions on sustainability factors.
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This decision is the consequence of a cost-benefit analysis, where, due to its small size and the nature and scale of its activities, the Company finds that the full application of this Regulation may damage its profitability with a negative impact to its investors. The Company also considers that non-financial data is still not available in satisfactory quality and quantity to allow adequate assessment. Moreover, measuring the principal adverse impacts of the activities and investments of the Company is considered a complex exercise requiring methodologies and significant resources dedicated solely to data analysis and reporting.

Article 5 – Remuneration Policy Disclosure

The Company’s remuneration policies and practices are designed to be consistent with sound and effective risk management. They do not encourage risk-taking that is inconsistent with the risk profiles, rules or instruments of incorporation of the Funds it manages, including risks arising from sustainability considerations. The Company ensures that its remuneration structures are aligned with the integration of sustainability risks, thereby avoiding conflicts of interest that could result in excessive risk-taking in relation to sustainability matters.

Article 6 – Product-Level Disclosures
Challenger Impact High Income Fund I

The Fund is not limited to investing in assets that promote environmental or social characteristics, and it does not adopt a specific ESG approach.The sustainable investments of the Fund are aligned with the OECD Guidelines for Multinational Enterprises and the International Labour Organisation’s Fundamental Principles and Rights at Work.The Fund may use sustainability indicators, such as avoided emissions, to measure the attainment of sustainable investment objectives.The Fund does not consider itself subject to the EU Taxonomy Regulation objectives.The Fund does not aim to achieve long-term capital growth by integrating an ESG approach. This may change in future depending on regulatory developments and investor demand.

Endeavour Real Assets Fund II

The investment objectives and policies of the Sub-Fund are not limited towards investing in assets which promote environmental or social characteristics. To this end, the Company does not consider that an ad hoc approach to the analysis of sustainability issues should be adopted, and the Manager shall accordingly not integrate the consideration of sustainability risks in the investment management process in respect of the Fund.
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The Company is strongly committed to ESG promotion, however following its assessment of sustainability risks, it has decided not to consider the adverse impacts of its investment decisions on sustainability factors, for the reasons outlined under Article 4 above. Accordingly, the Fund is managed without specific ESG objectives and does not fall under Articles 8 or 9 of the SFDR.