Expeditions II S.à. r.l. SFDR disclosures

This statement outlines how Expeditions II S.à. r.l. (the "AIFM" or “Expeditions”) integrates sustainability risks into its investment decision-making process, as required under the Sustainable Finance Disclosure Regulation (SFDR).

1. Integration of Sustainability Risks (SFDR Article 3)

A Sustainability Risk is defined as an environmental, social, or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

Expeditions is committed to integrating sustainability risks into its internal procedures and ongoing risk monitoring for the Fund.

Risk Assessment Process

Expeditions generally considers all materially relevant sustainability risks alongside other factors within the investment process. The assessment process is designed to maximize long-term risk-adjusted returns by:

• Identification: Prior to making an investment decision, Expeditions identifies material risks, including sustainability risks, associated with the proposed investment.
• Evaluation: The relevance of the ESG data and the likely impact on the financial return are evaluated in the context of the Fund’s specific investment strategy.
• Decision: Identified risks are submitted as part of the overall investment proposal to the board of managers. The final investment decision is made having regard to the Fund’s investment policy, with the identification, assessment, and mitigation (where possible) of sustainability risks embedded into this process.

The occurrence of a sustainability risk may materially negatively affect the Fund’s performance and returns. Due to the difficulty in assessing the precise probability and impact of these risks, investors should note this inherent uncertainty.

2. No Consideration of Principal Adverse Impacts (SFDR Article 4(1)(b))

Expeditions does not currently consider the Principal Adverse Impacts (PAIs) of investment decisions on sustainability factors (environmental, social, employee, human rights, anti-corruption, and anti-bribery matters) in the manner prescribed by Article 4(1) of the SFDR.

This position is adopted primarily because:

1. Data Unavailability: Reliable, consistent, and sufficiently accessible data required for the mandatory regulatory reporting on PAIs is not consistently available from underlying investments.
2. Investment Focus: The Fund's investment strategy and objectives are not ESG-focused, and the overall portfolio is not deemed likely to have a material impact on sustainability factors.
3. Reporting Burden: The underlying investments are not generally required to, and may not currently, report on the necessary factors.

This approach remains subject to ongoing review in line with future regulatory and market data developments.

3.Remuneration Policy Transparency (SFDR Article 5(1))

Expeditions qualifies as a registered Alternative Investment Fund Manager and is therefore not subject to the specific remuneration policy requirements under the AIFMD. Accordingly, the AIFM has not put in place a separate remuneration policy with respect to the integration of sustainability risks for the purposes of SFDR Article 5(1).

4. Taxonomy Regulation Disclosure (Article 7)

The assets of the Fund under management do not currently take into account the EU criteria for environmentally sustainable economic activities set out in the EU Taxonomy Regulation.

‍