We hold a fundamental belief that no employee should compromise integrity, even if they perceive short-term benefits for the firm. This commitment is evident in our dedication to building client trust and conducting business with ethical values and the highest standards of honesty and integrity. Our reputation hinges on our ability to discern right from wrong.

To guide our actions, we maintain an internal code of conduct encompassing rules and principles. This framework assists employees in making decisions aligned with the AIFM business. Every individual within the organization is accountable for conducting business ethically and in compliance with the law across all operational regions.

The internal policy undergoes annual evaluation and re-approval by the board of directors, ensuring its continued relevance and effectiveness in upholding ethical standards.

To report a complaint or possible violations related to ethical issues or other inappropriate activities, your initial step should be to contact the employee at AIFM with whom you have discussed the matter in question. If dissatisfaction persists, you can escalate the issue by reaching out to AIFM's Complaint Manager in writing. When submitting a written complaint, please include copies of relevant documents for thorough investigation.

Emerald Management Luxembourg aims to provide a high standard of services to its clients, but on occasions, we may fall short of this goal and this may result in a complaint.

We aim to treat all complaints fairly and objectively. Below are details of our complaints handling arrangements:

• Complaints can be made by letter, e-mail,
• A written acknowledgement will be send within 10 business days after receipt of the complaint,
• Complaints will be referred to our Compliance department and the Conducting Officers,
• Impartial investigation will be carried out within a reasonable time frame after receipt of a complaint,
• Complaints will be responded one month after receipt of the complaint,
• If this timeline will not be respected, an information about the causes of a delay will be provided as well as the likely resolution date.

You can send us your complaint (in English or French) by writing directly to the Director in charge of Clients complaints, whether by post, or through the following email address complaint@emeraldaifm.com.

In order to investigate and resolve a complaint in the shortest time-frames possible, investors are kindly requested to include the following information when sending a complaint:

• Client personal data: Name;
• Address;
• Contact details.
• Description of the complaint with relevant data of the transaction involved:
• Date;
• the sub-fund concerned;
• Number of shares;
• Amount;
• Copies of any relevant documents

Upon receipt of Emerald’s final response, should you remain dissatisfied, you may, if so wished, refer the matter to the Luxembourg Regulator, the Commission de Surveillance du Secteur Financier (CSSF) as follows:

​By mail to:
Commission de Surveillance du Secteur Financier, Département Juridique CC
283, Route d’Arlon
L-2991 Luxembourg

By fax: (+352) 26 25 1-2601;

By e-mail:
reclamation@cssf.lu

Or by filling in the online complaint form
https://reclamations.apps.cssf.lu/index.html?language=en

The CSSF circular on the out of court complaint handling can be found on its website, indicated hereunder:
https://www.cssf.lu/wp-content/uploads/files/Lois_reglements/Legislation/RG_CSSF/RCSSF_No16-07eng.pdf

To adhere to regulations and uphold public confidence in the financial market and Emerald Managements Luxembourg S.à.r.l, the AIFM has instituted, implemented, and enforced an internal policy aimed at preventing, identifying, managing, and monitoring conflicts of interest. This internal policy undergoes assessment and re-approval by the board of directors at least once annually.

The AIFM keeps a description of the potential conflicts of interest that may arise, and is open to be requested by investors to the firm at info@emeraldaifm.com.

"Ensuring financial integrity is a core principle of Emerald Managements Luxembourg S.à r.l to prevent the misuse of the financial system. In accordance with Luxembourg's regulatory requirements, specifically referencing Circular CSSF 12/552 and other applicable laws, the AIFM has established, implemented, and applied a comprehensive internal Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) policy. This policy is meticulously designed to detect and deter activities related to money laundering and the financing of terrorism within the organization.

The AML/CFT policy includes robust procedures and measures to verify the identity of clients, assess and monitor transactions, and report any suspicious activities to the relevant authorities. Regular training and updates on AML/CFT regulations, including those outlined in Luxembourg's legal framework, are provided to employees to ensure a strong and vigilant approach in maintaining financial integrity.

The effectiveness of this policy is regularly assessed, and necessary adjustments are made to align with evolving regulatory requirements and emerging risks in the financial landscape, ensuring continued compliance with Luxembourg's legal standards for anti-money laundering and combating the financing of terrorism."

Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector, as amended (the “SFDR”) intends to provide harmonised disclosure requirements for investment products. The SFDR lays down harmonised rules for ‘financial market participants’ on transparency with regard to the integration of Sustainability Risks.

Emerald Managements Luxembourg S.à.r.l (the AIFM)AIFM considers sustainability as a critical driver of business of the Company and the Sub- funds and has been working towards greater transparency and accountability on environmental, governance and social matters. The AIFM recognises that those companies that are capable of generating a more inclusive and sustainable economic growth to their stakeholders are the ones that tend to produce more value in the long term.

Hence, the AIFM believes that the integration of Sustainability Risks into the investment decision-making process may help to enhance long term risk-adjusted returns for investors, in accordance with the investment objectives and policies of the Sub-funds. The AIFM identifies and integrates Sustainability Risks as part of its investment management process and as part of its risk management process. The AIFM integrates the Sustainability Risks assessment together with other material factors in the context of the specific investment opportunities and positions and of the investment objective and policy of the Company (and the Sub-funds) in accordance with the provisions of Article 6 (1) §1 of SFDR. Unless otherwise provided for a specific Sub-Fund in the relevant Sub-Fund Appendix, the Sub-Funds do not promote environmental or social characteristics, nor do they have sustainable investment as investment objectives within the meaning of Articles 8 and 9 of SFDR, respectively.

The integration of Sustainability Risks in the investment decisions of the AIFM is a multi-step processfrom pre-investment to post-investment, monitoring and exit. The process starts with the identificationof Sustainability Risk indicators and factors considered to be material to a given investment, in thecontext of the relevant investment objective. The AIFM includes in its decision-making process theconsideration that a prospective investment has a sustainable competitive advantage for the relevantSub-Fund. The AIFM ensures that the operational counterparties are fully aware of and commit tocomply with the investment philosophy, approach and expectations of the Company (and the Sub-Funds) and the AIFM in respect of sustainability. Once selected and appointed, the AIFM monitors therelevant Sustainability Risks for each investment. The AIFM will regularly monitor the investmentuniverse and implement necessary measures to ensure that Sustainability Risks are sufficientlyconsidered. Where the AIFM deems that an existing investment in the portfolio of the Company (andthe Sub-Funds) or an investment opportunity reaches a certain level of exposure in relation toSustainability Risks as defined by the AIFM from time to time that impact or are likely to impact thefinancial returns of the Company (and the Sub- Funds), the AIFM will take the appropriate measuresup to the divestment or rejection of an investment opportunity. Nonetheless, the AIFM does not useESG factors as decisive or reductive factors but only as additional factors in its decision-makingprocess.

The AIFM requires the Investment Adviser(s) to consider and assess Sustainability Risks for each investment opportunity they introduce to the AIFM.

For further information on the integration of Sustainability Risks in respect of the Company and the Sub-Funds please refer to the website of the AIFM.

As at the date of this Issuing Document, the AIFM does not intend to consider principal adverse impactsof investment decisions related to the Company and the Sub-Funds on Sustainability Factors as thesize of investments and structure of the Company do not seem to be of sufficient relevance on thesefactors and there is no sufficient data available for measuring these principal adverse impacts withinthe meaning of Article 7 (1) of SFDR.

A loan-to-value (LTV) ratio is a metric that measures the amount of debt used to buy a home and compares that amount to the value of the home being purchased. LTV is important because lenders use it when considering whether to approve a loan and/or what terms to offer a borrower.

Raising funds provide investors with a document containing questions that are common among investors when considering an investment fund. The key issues contained in the document include general information about the general partner (GP) and the fund, the investment strategy and process, the market environment, the terms and conditions of the fund and its past performance.

The general partner in a limited partnership that is responsible for all partnership management decisions. The general partner is responsible to act for the benefit of the limited partners and is fully responsible for the fund’s activities.

The internal rate of return (IRR) is a metric used in financial analysis to estimate the profitability of potential investments. IRR is a discount rate that makes the net present value (NPV) of all cash flows equal to zero in a discounted cash flow analysis.

IRR calculations rely on the same formula as NPV does. Keep in mind that IRR is not the actual dollar value of the project. It is the annual return that makes the NPV equal to zero.

This term is relevant to open-ended funds where the fund establishes a mechanism that allows the investor to redeem participation units. It is generally acceptable that, after the Lock-Up Period defined in the fund’s policy, the investor may redeem his investments at the end of each quarter, with the number of days stated in the specific OM of each such fund as prior notice days prior notice. Where many investors seek to withdraw their investments, some funds may defer the redemption if the total redemption requests exceed a certain percentage of the asset value. In such a case, the fund may decide to suspend the redemptions for a fixed period of time, a partial repayment which will be divided pro rata among the applicants or a spread of the redemption for a certain period of time.

An annual fee charged to investors by the fund manager for as long as they are invested in the fund, with the amount of the fee varying according to the nature of the fund. Management fees are generally paid from the investor’s capital contribution to the fund. Some funds collect management fees only from the actual investments.

A fund with no finite or limited lifespan that allows the continuous entry and exit of investors, except during the Lock-Up Period, following which monies can be redeemed. The fund calls the investors to make their capital contributions on one occasion and executes the investments accordingly. Generally, investments in this type of funds are relatively liquid, to allow the fund to make its investments based on the value of the capital contribution made to the fund.

A legal document furnished to prospective investors when raising capital. The document reveals all information that the investor should be aware of to make a reasoned investment decision prior to making an investment. The PPM sets out, inter alia, the investment opportunity as well as legal obligations, and explains the risk of losses. The disclosures included in the PPM vary depending on the complexity of the offering and its terms and conditions.

Currently English is the only language we support online. If you need assistance in Spanish, please call us.

Certainly. If you are submitting a request through the online form, you have the option to select more than one product. This allows you to include multiple products in a single request for your convenience.

Upon processing your request, we will send you a confirmation message via email or in the originally received format, indicating the status and completion details. Please remember to take note of your login information and request ID after submission. Should you require further assistance before receiving this message, feel free to reach out to us by phone. We are here to help.

We are able to fulfill your request, your information will be made available to you either via secure electronic means or through regular mail. If this method is not convenient for you or if you require additional assistance, please feel free to call us. We are here to assist you further.

You can request access to and/or deletion of your data by calling us at: +352 621 887 085 or by mail at: info@emeraldaifm.com

Your security is our top priority, and we are committed to providing you with any information within the limits defined by applicable law. However, please note that we may refrain from disclosing personal data if doing so would adversely affect the rights and freedoms of others. This cautious approach is in adherence to privacy considerations and legal constraints.

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We requires enough information to accurately and securely authenticate your identity. Your personal data will be used for the sole purpose of complying with your data access or deletion request. We will delete the personal data you provide to us in making this request when it is no longer needed for that purpose. Our intention is not to create a new record of personal information, but to fulfill your request through an efficient search.We maintain physical, electronic and procedural safeguards to protect your personal information.