EU SFDR Disclosures

The European Commission’s Action Plan on financing sustainable growth of March 2018, Regulation (EU) 2019/2088 on Sustainable Finance Disclosure Regulation (SFDR) aims to provide greater transparency on the degree of sustainability of financial products. The SFDR defines “sustainability risks” as environmental, social, or governance (ESG) events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment. GCM Grosvenor has integrated sustainability risks, as a sub-set of risks generally that could cause an actual or potential material negative impact on the value of an investment, as part of its investment decision-making and risk monitoring process. If appropriate for an investment, GCM Grosvenor may conduct sustainability risk-related due diligence and/or take steps to mitigate sustainability risks and preserve the value of the investment.

GCM Grosvenor views ESG factors as key elements of investment return, volatility, and risk mitigation, and believes the consideration of such factors is an important aspect of our fiduciary responsibility to clients. The degree of ESG integration into a given portfolio will depend on the client mandate, investment strategy and portfolio structure. While the general partner may consider ESG factors when making an investment decision, unless otherwise specified in the fund’s investment strategy, the funds do not pursue an ESG-based investment strategy or limit its investments to those that meet specific ESG criteria or standards. Any reference herein to environmental or social considerations is not intended to qualify our duty to maximize risk-adjusted returns. Further information on the manner in which sustainability risks are integrated into investment decisions is available at the offices of GCM Grosvenor.