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Marketing restrictions
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Risks
The information in this website (which may contain forward-looking statements, projections, valuations, benchmarks and/or investment performance calculations) has not been audited or independently verified. Any past performance information is not indicative of future performance, and any forward-looking statements, forecasts or projections in this document are dependent on future events, uncertainties and factors beyond the Adviser’s control such that actual results, performance or achievements may be materially different from such statements, forecasts, projections and past performance information. 
Neither the Adviser nor any of its affiliates, officers, employees and agents (the “Salica Group”) make any express or implied representation or warranty, and no responsibility or liability is accepted by any of them, with respect to the adequacy, accuracy, completeness, reasonableness or likelihood of any information contained in this website. The Adviser expressly disclaims any obligation to update or revise the information under any circumstances. No part of the website should be regarded as advice or recommendation and any potential investors in any securities should make their own enquires and take their own advice before making any investment in securities. 

United Kingdom
[The content of this website has not been approved by an authorised person within the meaning of the Financial Services and Markets Act 2000. Reliance on this website for the purpose of engaging in any investment activity may expose an individual to a significant risk of losing all of the property or other assets invested.]
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Sustainable Finance Disclosure Regulation 
Salica Growth Debt Fund I GP S.à r.l., Salica Access Fund IV GP S.à r.l. and Salica Leaders Fund II GP S.à r.l.  (each a “Lux Company” and together, the “Lux Companies”) are each private limited companies incorporated under the laws of the Grand Duchy of Luxembourg. Each of the Lux Companies are required to comply with EU regulations that directly apply to all EU member states, including the Sustainable Finance Disclosure Regulation (2019/2088) (the “SFDR”).

1. Article 3(1) – Transparency of sustainability risk policies
None of the Lux Companies has a specific policy on the integration of sustainability risks in its investment decision-making process. A sustainability risk is 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 an investment.
However, the Lux Companies’ appointed investment adviser, the Adviser, has an ESG internal policy, which must be factored into any recommendation that is made by the Adviser to any of the Lux Companies. The Adviser’s ESG policy requires various sustainability risks to be considered and factored into its recommendation process.
For further information, please email [email protected].

2. Article 4(1) – Transparency of adverse sustainability impacts at entity level
As per Article 4(1)(b), the Lux Companies are required to publish information on whether they consider the “adverse impacts of investment decisions on sustainability factors” (the “Principal Adverse Impacts”) under the SFDR. The Lux Companies do not expressly or specifically consider the Principal Adverse Impacts of investment decisions on sustainability factors in connection with all of their respective products and services, as defined under and in accordance with the SFDR. This is because none of the Lux Companies are, in their view, currently in a position to obtain and/or measure all the data which they would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all its investment strategies to clients and investors. This is in part because underlying investments are not widely required to, and may not currently, report by reference to the same data. In addition, the investment objectives and likely portfolios of the products and services provided by the Lux Companies are not specifically ESG focused, and they are unlikely to be able to require underlying investee companies to provide all the data that they would be required by the SFDR to report.
The Lux Companies may report to investors in the future on some or all of the Principal Adverse Impacts of investment decisions on sustainability factors in relation to certain strategies on a voluntary basis, applying the same or similar standards as in the SFDR.
In practice, the Lux Companies intends to consider some or all of the “sustainability factors” listed in the SFDR, including environmental, social and employee matters, respect for human rights, anti-corruption and/or anti-bribery matters by means of its global policy on integration of environmental, social and governance risks and value creation opportunities as part of its investment process and decision making. Further, as noted above, the Lux Companies’ appointed investment adviser, the Adviser, has an ESG policy which requires consideration of certain sustainability factors.  
For further information, please email [email protected].

3. Article 5(1) – Consistency of remuneration policy with integration of sustainability risks
None of the Lux Companies has a standalone remuneration policy in place on the basis that none of the companies directly employs any staff.  However, the persons involved in advising the Lux Companies are subject to a group-level remuneration policy (the “Group Remuneration Policy”).  The Group Remuneration Policy is monitored and administered by a specifically formed remuneration committee, chaired by an independent non-executive director.  
The Group Remuneration Policy does not have any specific quantitative sustainability-focused performance targets.  However, notwithstanding this, the Group Remuneration Policy is consistent with the integration of sustainability risks by virtue of the fact that:
a. the total amount of variable remuneration is based on a holistic assessment of the performance of the employee. An individual’s demonstration of compliance with the Adviser’s ESG policy forms part of their overall assessment of performance; and
b. decisions relating to salary and bonuses are focused on ensuring alignment with clients’ interests and the Salica Group’s investment philosophies and processes, which include the integration of sustainability risks.