SFDR data collection exercise applicable to investment fund managers (IFMs) and institutions for occupational retirement provision (IORPs) on precontr

(3)of the Law of 12 July 2013 (the 2013 Law), based in Luxembourg or in another Member State of the European Union, in relation to all Luxembourg-domiciled regulated AIFs they manage; (e) IORPs, subject to the Law of 13 July 2005 to participate to this data collection exercise, by providing a set of information relating to precontractual product disclosures for each of the financial products mentioned above, in accordance with the details set out below. FMPs subject to Articles 2

(2)or 3

(1)of the 2013 Law can participate to this data collection exercise on a voluntary basis in relation to any Luxembourg-domiciled regulated AIF they manage. A user guide providing clarifications on the content and the format of the information to be reported as well as technical details on the data collection process is available. The current reporting of SFDR data is mandatory for all sub-funds of a UCITS/AIF/IORP subject to the scope as defined above. The data is to be completed and provided to the CSSF for each fund/sub-fund, regardless of the regime applicable to those under SFDR (i.e. SFDR Article 6, Article 8 or Article 9). Additional details regarding the scope are available in the user guide. After the initial declaration, IFMs and IORPs remain responsible to ensure that the information provided is being kept up-to-date; in case of changes to the precontractual documents/templates, IFMs and IORPs must update the data reported under the SFDR data collection by transmitting subsequent declarations. The deadline for submission of the initial report is 15 June

1. The SFDR data concerning UCIs must be submitted by the IFM (or the UCITS/AIF for internally managed UCIs). The SFDR data concerning IORPs must be submitted directly by the IORP. Any question should be addressed to ucisfdr@cssf.lu. The SFDR data can be submitted to the CSSF via the following channels: a. A solution based on the submission of a structured file through S3 (“simple storage service”) protocol, which is already available. This solution allows for an automation by financial market participants and if needed, a testing of the reporting file submission before going into production. Please refer to the user guide for further details. b. An online solution via eDesk for manual input by IFMs/IORPs for each fund/sub-fund they manage. This solution will be made available as of 2 May
2. Further guidance on this solution will be provided in due course. Additional information The current data collection exercise will be extended in the near future to collect information contained in the PAI statements and in the periodic disclosure templates. Further details on timing and practical proceeding of this extended data collection will be communicated at a later stage. 1 February 2023 SFDR data collection exercise for investment fund managers (IFMs) on regulatory requirements in relation to Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR) Communiqué Page 24 March 2023 - Updated on 7 June 2024 SFDR UCI precontractual data collection – practical and technical guidance Related publications : SFDR data collection exercise for investment fund managers (IFMs) on regulatory requirements in relation to Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR) SFDR data collection exercise applicable to investment fund managers (IFMs)… Technical document PDF (1.47Mb) 4 May 2023 Extension of the initial submission deadline for the SFDR data collection exercise on precontractual disclosures Communiqué Page Main topic: Sustainable finance Relevant for Alternative investment fund managers Management companies - Chapter 15 Pension fund Specialised investment funds (SIFs) Undertakings for collective investment in transferable securities (UCITS) Undertakings for collective investment subject to Part II of the Law of 17 December 2010 (Part II UCIs) SFDR UCI precontractual data collection Practical and technical guidance SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 1/81 SFDR UCI precontractual data collection - Practical and technical guidance Contents
8. Glossary and objectives 5 1.1 Glossary 5 1.2 Objectives 6 Scope 6 2.1 Who must submit the report? 6 2.2 Which UCITS/AIF/IORP are covered by this reporting? 7 2.3 When does an IFM/IORP have to report? 7 2.4 Identification of a sub-fund subject to a data collection report 8 2.5 Constituents and purpose of the SFDR data collection 8 Practical guidance 9 3.1 Information to be collected for sub-funds not disclosing under SFDR Article 8 or SFDR Article 9 9 3.2 Information to be collected for sub-funds disclosing under SFDR Article 8 9 3.3 Information to be collected for sub-funds disclosing under SFDR Article 9 9 Technical guidance 9 4.1 S3 system reporting technical specifications 9 4.2 eDesk online form 20 4.3 Reporting entities obligations 24 4.4 Testing with CSSF 24 Contact information 25 Questions & Answers 26 6.1 Is a LuxTrust certificate mandatory for using eDesk? 26 6.2 Who can grant the "IT Expert" role to a user within my entity? 26 6.3 What is the role of the "IT Expert"? 26 6.4 Is it possible to share S3 credentials externally? 27 6.5 How might we parameter the S3 protocol? 27 6.6 Is S3 similar to a SFTP solution? 27 6.7 What is the “ECHO” service? 27 6.8 Can you please explain how to set up an S3 compatible transfer client? 27 6.9 My entity did choose to configure an S3 transfer client. However, I am not seeing any "submission" folder in my S3 bucket. What should I do? 27 6.10 Which file format is expected by the CSSF? 28 SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 2/81 6.11 Is the S3 protocol linked to a commercial cloud provider? 28 6.12 What is the retention period for files in the bucket? 28 Annex I – Synopsis on information to be collected for sub-funds not disclosing under SFDR Article 8 or SFDR Article 9 29 Annex II – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 8 31 CSSF guidance: Please refer to annex IV for the code to be used in the report for closed questions (Yes/No answers, or answers referring to a predefined list) 31 Annex III – Synopsis on information to be collected for subfunds disclosing under SFDR Article 9 54 Annex IV – Codes required in the report for closed questions 79 SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 3/81 Update information Date Version Changes 24/03/2023 1.0 Publication of the document 06/04/2023 1.1 Modification of Annex II and Annex III 12/05/2023 1.2 Extension of initial submission deadline Correction of typographical errors 08/06/2023 1.3 Addition of information concerning the eDesk online form (see point 4.2) Explanations concerning the obligations to provide the precontractual template for a sub-fund (see point 4.1.2.2.4 (iii)) 03/07/2023 1.4 New version of Precontractual JSON schema document (see chapter 4.1.2.2 for details) Additional information concerning the correction or the modification of the last accepted pre-contractual data of a sub-fund (see point 4.2.6) Addition of information concerning the possibility to view the last accepted data (see point 4.2.7)Modification of the Questions & Answers (see point 6.12) 05/06/2024 1.5 Addition of declarations to submit (see point 4.2.8) SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 4/81
9. Glossary and objectives 1.1 Glossary Notion Definition A bucket is a container for objects. S3 stores data as objects Bucket within buckets. An object is a file and any metadata that describes the file. Each entity manages its own separate buckets to be used for each report type. CDR SFDR-RTS ESMA SB ESMA Supervisory briefing – Sustainability risks and disclosures in the area of investment management (31 May 2022, ESMA34-45-1427) The “IT Expert” is an eDesk specific role that is granted by IT Expert the "Advanced User" of the entity to the person managing access to the S3 API. A person with this role is responsible for creating, viewing and revoking access keys. S3 – or “simple storage service” – is the object storage protocol (through a web service interface) used by the CSSF S3 for the file exchange. In this context, S3 simply refers to the protocol for managing object storage and does not rely on any services provided by commercial cloud providers. SFDR Sustainable Finance Disclosure Regulation Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector, as amended SFDR precontractual Precontractual templates set out in Annex II respectively templates Annex III of the SFDR-RTS Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022 supplementing Regulation (EU) 2019/2088 of the European Parliament and of the Council with regard to regulatory technical standards specifying the details of the content and presentation of the information in relation to the principle of ‘do no significant harm’, specifying the content, SFDR-RTS methodologies and presentation of information in relation to sustainability indicators and adverse sustainability impacts, and the content and presentation of the information in relation to the promotion of environmental or social characteristics and sustainable investment objectives in precontractual documents, on websites and in periodic reports (published on 25/07/2022), as amended SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 5/81 TR Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 UCI 1.2 Generic term referring to UCITS and AIFs Objectives The general objective of this document is to provide practical and technical information on the SFDR Data collection exercise. The first part of the document aims at providing information to financial market participants on the scope of the data collection and outlines the CSSF expectations on the manner in which the data fields need to be completed before being submitted to the CSSF. The second part of the document aims at providing technical details to financial market participants on the data collection exercise as follows:
10. • Technical overview of the reporting system; • Data and file format of the reports; • Data validation and feedbacks. Scope 2.1 Who must submit the report? The CSSF is requiring the following financial market participants (“FMPs”): (a) UCITS management companies, based in Luxembourg or in another Member State of the European Union, in relation to all Luxembourg-domiciled UCITS they manage; (b) authorised AIFMs, based in Luxembourg, in relation to all Luxembourgdomiciled regulated and unregulated AIFs (including ELTIFs) they manage; (c) authorised AIFMs, based in another Member State of the European Union, in relation to all Luxembourg-domiciled regulated AIFs, as well as Luxembourg-domiciled unregulated AIFs qualifying as ELTIFs they manage; SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 6/81 (d) registered AIFMs, subject to Article 3

(3)of the Law of 12 July 2013 (the “2013 Law”), based in Luxembourg or in another Member State of the European Union, in relation to all Luxembourg-domiciled regulated AIFs they manage; (e) Institutions for occupational retirement provision (“IORPs”), subject to the Law of 13 July 2005; to participate to this data collection exercise. FMPs subject to Articles 2

(2)or 3

(1)of the 2013 Law can participate to this data collection exercise on a voluntary basis in relation to any Luxembourg-domiciled regulated AIF they manage. UCITS management companies and AIFMs ("IFMs”) are responsible for submitting the SFDR data to the CSSF for the UCITS and AIFs in scope and under their management. IORPs are responsible for submitting the SFDR data to the CSSF for the IORPS in scope. 2.2 Which UCITS/AIF/IORP are covered by this reporting? The reporting of SFDR data collection is mandatory for all sub-funds of a UCITS/AIF/IORP in scope as defined under 2.1 above. The data is to be completed and provided to the CSSF for each sub-fund disclosing under SFDR Article 8, Article 9 or not disclosing under SFDR Article 8 or SFDR Article 9. Sub-funds that are not active anymore (i.e. have entered into liquidation) or AIF subfunds that are not being distributed anymore since the entry into force of SFDR RTS (i.e. 1 January 2023) and, as a consequence, do not update their prospectus/issuing document anymore, are excluded from the present reporting obligation. To eliminate any doubt, an AIF prospectus/issuing document that is updated on a voluntary basis shall include the SFDR RTS Template applicable at the date of the visa-stamped prospectus/issuing document. For clarity’s sake, sub-funds that have not been launched and sub-funds awaiting reactivation as described in Circular CSSF 12/540 are covered by the reporting obligation as long as the prospectus/issuing document of the UCITS/AIF still provides for disclosure for those sub-funds. 2.3 When does an IFM/IORP have to report? 2.3.1 Initial data collection SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 7/81 IFMs, respectively IORPS, must submit an initial report to the CSSF on a best effort basis by 15 June 2023, and in any event by 31 October 2023 at the latest for all UCIs, respectively IORPs in scope and under their management. The reporting must be done at sub-fund level and be consistent where applicable, with the information contained in the precontractual document/template. 2.3.2 Subsequent data collection A subsequent report must be submitted by the IFM, respectively the IORP, each time the relevant information contained in the SFDR precontractual document/template and reflected in the previous report is modified. 2.4 Identification of a sub-fund subject to a data collection report The sub-funds must be identified based on the CSSF identification number, which can be obtained via the following links: (

1. a)For regulated entities in scope: Identifiers of UCI/SIF/SICAR; (
2. b)For non-regulated entities in scope: Identifiers of AIF(M)s. (
3. c)The CSSF identification number for a non-regulated entity being an ELTIF managed by an authorised AIFM based in another Member State of the European Union or for an IORP cannot be obtained via a dedicated list available on the CSSF’s website. An IFM or IORP is invited to contact the CSSF directly in case of issues with obtaining this information. 2.5 Constituents and purpose of the SFDR data collection The SFDR data collection consists of a set of quantitative, binary and a certain number of open questions that are derived from the SFDR precontractual documents/templates and vary depending on the SFDR article under which the sub-fund is disclosing. The aim of this exercise is to digitally collect information contained in the precontractual templates and also to obtain confirmation on some more general SFDRrelated questions going beyond the SFDR precontractual templates. The information must be provided for i. Sub-funds disclosing under SFDR Article 8; ii. Sub-funds disclosing under SFDR Article 9; iii. Sub-funds neither disclosing under SFDR Article 8 or SFDR Article 9. Under (
4. i)and (ii), the data collection relates to the environmental and/or social characteristics of the sub-funds. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 8/81 Under (iii), the data collection related to sustainability risk and adverse impact pursuant to SFDR Articles 6 and 7. 3. Practical guidance 3.1 Information to be collected for sub-funds not disclosing under SFDR Article 8 or SFDR Article 9 Please refer to Annex I. IFMs, respectively IORPs, are requested to provide confirmation upon SFDR disclosure obligations under SFDR Article 6 and Article 7. 3.2 Information to be collected for sub-funds disclosing under SFDR Article 8 Please refer to Annex II. 3.3 Information to be collected for sub-funds disclosing under SFDR Article 9 Please refer to Annex III. 4. Technical guidance The SFDR precontractual reporting is possible through two different channels: 4.1 • via S3 system by using a structured exchange file • via an online form available on the eDesk platform S3 system reporting technical specifications 4.1.1 Data collection high-level process The process for submitting a UCI SFDR data reporting via S3 system is the following: SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 9/81 (
5. a)File collection through S3 system; 1 (
6. b)Formal verification of the uploaded reporting file; (
7. c)Feedback sending (positive or negative). 4.1.2 File collection About the S3 solution S3 (“simple storage service”) solution is the object storage through a web service interface used by the CSSF for the file exchange through a S3 compatible transfer client. S3 stores data as objects within buckets. An object is a file and any metadata that describes the file. A bucket is a container for objects. An entity will be linked to one bucket divided into two folders: • “submission”: for the reporting files; • “feedback”: for the feedback files. 4.1.2.1 4.1.2.1.1 Enrolment process Concerned entities The SFDR data concerning UCIs must be submitted by the IFM (management company for UCITS or AIFM for AIFs). In the case of a self-managed fund, if the AIFM is out of scope (Art. 2 AIFM Law) or if the AIFM is exempted from the AIFM Law (Art. 3 AIFM Law), SFDR data must be submitted by the fund itself. The SFDR data concerning IORPs must be submitted by the IORP itself. This means that the enrolment process described below must be done by the entity responsible for the submission of the data. A control checks that the data has been submitted by the expected entity (cf. SFO004 in chapter 4.1.3.2.3). 4.1.2.1.2 Prerequisite To access and use the S3 system, an enrolment process performed through eDesk is required. 1 Note that S3 simply refers to the protocol for managing object storage and not to any service provided by commercial cloud providers. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 10/81 If it has not already been done, the entity must first create an “advanced user” through eDesk (“New advanced user request”) who will accept or reject attachments from other eDesk users for this entity. The advanced user can therefore define an “IT Expert” who will get the credentials to connect through the S3 solution. All key information on the eDesk authentication is available in the eDesk Authentication User Guide on the eDesk home page. 4.1.2.1.3 Defining the “IT Expert” role Once authentication in eDesk is done, the “Advanced user” can access the “Entity management” menu: The “Advanced user” can then attribute the specific role of “IT Expert” to anyone linked to the entity, with IT knowledge and responsibilities within the entity: After reaching the “Specific role within entity” tab, choose a user first by using the magnifying glass. Double-click on the chosen person to get the “IT Expert” role. Select the “IT Expert” role and click on “save” in the top right corner. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 11/81 The “IT Expert” is now identified and can access the IT management console. The IT management console allows managing the accesses of the technical users in the S3 system. 4.1.2.1.4 The “IT Expert” has Collect the S3 credentials to connect on the eDesk IT management console (PRODUCTION link: https://edesk.apps.cssf.lu/edesk-itmgt). 1. Log in to get to the S3 access dashboard. 2. Click on the “Create access” button. 3. Select the option “SFDR – precontractual disclosures” and click on the “Create” button. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 12/81 The access is now granted. 4. Double-click on this new line or click on the “Open” button in the “Actions” column and access the “S3 access” details page to collect the S3 credentials. 5. Save the information provided (bucket, access key, secret key). In order to copy the secret key, press the eye on the right side of the screen. Pay attention to the message: the secret key can only be viewed once, if you lose it, you will need to reset your credentials. If needed, you can also revoke your access by clicking on the button “Revoke”. 4.1.2.1.5 Access the S3 module You can now use the credentials to access the S3 module through a S3 compatible transfer client. Any S3 compatible transfer client can be used to upload and download files manually and any S3 compatible SDK can be used to automate it. The production URL to be used is the following one: https://s3.apps.cssf.lu. In S3 you will use: • The “submission” folder to upload files in .zip format; • The “feedback” folder to retrieve feedbacks. Depending on the transfer client, “submission” folder may have to be manually created. 4.1.2.2 4.1.2.2.1 Reporting file Reporting format The data concerning SFDR for UCIs and IORPs shall be reported in the JSON (JavaScript Object Notation) format. Each JSON report concerns one specific UCI/IORP and contains data for one or several sub-funds of that UCI/IORP. Reported data for each sub-fund depend on its regime under SFDR (Article 8, Article 9 or Article 6) and are described in the JSON schema. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 13/81 Each JSON report must be compressed in a ZIP format. In addition to the JSON report, the ZIP archive can contain PDF files corresponding to the physical version of the precontractual document (only if the physical version of the document has never been transmitted to the CSSF). Precontractual document JSON schema The schema concerning the data of the precontractual document is available at: Publication date Version Link Release note 24/03/2023 1.0.0 schema Initial version 20/06/2023 2.0.0 schema Correction of typographical errors All the proportion, percentage and share fields are expressed as a positive percentage between 0 and 100 with a maximum of 2 decimal places after the comma. 4.1.2.2.2 Submission process The ZIP file MUST be uploaded to the “submission” folder in S3. No upload is allowed into other folders (e.g. “feedback” folder is only dedicated to CSSF feedbacks). 4.1.2.2.3 ZIP technical specifications Reporting file must be transmitted via a compressed .zip format containing one single .json file and pdf files. Here are the specifications for zip archive: Compression algorithm RFC 1951 (DEFLATE Compressed Data Format Specification version 1.3) Multi-volume archives (multi-part zipfile) No Maximum size of a file in the archive 2 Gigabytes Codepage UTF-8 4.1.2.2.4 i. Naming conventions ZIP file SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 14/81 The mandatory file naming convention for .zip files is specified below. Format: SFDR-ENNNNNNNN-TTTTT-UUID.ext Code Meaning Structure Authorised value SFDR Reporting type Char

(4)‘SFDR’ (constant) - Separator Char

(1)‘-’ (constant) E Reporting entity Char

(1)‘O’ or ‘K’ or ‘V’, or ‘F’ (depending on the entity type) NNNNN Identification NNN number - Separator Char

(1)‘-’ (constant) TTTTT Type of data Char

(5)PRECO for precontractual data - Separator Char

(1)‘-’ (constant) UUID Unique identifier UUID format Unique identifier following the rfc 4122 Number

(8)entity) norm (ReportUid) .ext 00000001…99999999 (CSSF code of the Extension Char

(5).zip (constant) UUID specifications The UUID is necessary to uniquely identified a report concerning a fund/pension fund. It is also used to prevent a file to be process several times and to allow the CSSF to share a processing order of files concerning a same UCI/IORP. A ZIP file with the same UUID of another ZIP file concerning the same UCI/IORP will be rejected with the error SFO006 (cf. chapter 4.1.3.2.3). The expected format of an UUID is: XXXXXXXX-XXXX-XXXX-XXXX-XXXXXXXXXXXX where each X data can have a value from 0 to 9 or from a to f (hexadecimal authorised characters). You can find more information about the UUID on: Universally Unique Identifier (UUID) ii. JSON report No specific naming convention will apply for the JSON report included in the zip file, but it is recommended to use report.json. iii. PDF file SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 15/81 The following naming convention apply for PDF files you may add to your report. A PDF file is required only if the fund is an AIF and the precontractual template has not yet been provided to the CSSF for the sub-fund (see technical attribute “templateAvailableToInvestorsIndicator” in Annex II – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 8 and Annex III – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 9). Format: SFDR-CCCCCCCC-TTTTT.ext Code Meaning Structure Authorised value SFDR Reporting type Char

(4)‘SFDR’ (constant) - Separator Char

(1)‘-’ (constant) CCCCC Identification Number

(8)00000001…99999999 (CSSF CCC number code of the sub-fund for an umbrella UCI/IORP) 00000000 (for a standalone UCI/IORP) - Separator Char

(1)‘-’ (constant) TTTTT Type of data Char

(5)PRECO for precontractual data .ext Extension Char

(5).pdf (constant) Example: Archive JSON report PDF file 4.1.3 SFDR-O0000xxxx-PRECO-41c13c08-ef59-4183-870f80d7a00c54e8.zip report.json SFDR-00000001-PRECO.pdf SFDR-00000002-PRECO.pdf CSSF feedback file It is up to the submitter to monitor transmission correctness. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 16/81 A feedback file in JSON format is systematically generated for each file transmitted and made available in the “feedback” folder. The schema concerning the data of the generated feedback is available in the CSSF feedback file. Please ensure that you have received a feedback file for the last file sent before submitting a new file concerning a same sub-fund. Feedback generation could take some time. If you do not receive a response within one working day, please contact our dedicated support team at ucisfdr@cssf.lu. 4.1.3.1 Naming convention Feedbacks from the CSSF are received in the “feedback” folder of the S3 transfer client. Format: SourceFileName_FEEDBACK_TrackingCode.json Code Meaning Structure Authorised value SourceFileName Reporting Char(N) Submitted file name - Refer to entity the ZIP File name structure in section 2.2.4 _ Separator Char

(1)‘_’ (constant) FEEDBACK File type Char

(8)FEEDBACK (constant) TrackingCode Unique Char

(16)Unique identifier created by the identifier CSSF system after file submission SFOYYYYMMDDXXXXXX where: YYYYMMDD: year, month and day of submission XXXXXX: daily increment _ Separator Char

(1)‘_’ (constant) .ext Extension Char

(5).json (constant) 4.1.3.2 File content A feedback file contains several information: • A status at the report level; • ReportUids recently processed; • Feedback messages at the report/sub-fund level. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 17/81 4.1.3.2.1 Report status The report status can have three different values: • REJECTED when the report is entirely rejected. That is the case, either when the archive is not technically compliant, or when all the sub-funds concerned by the report are rejected because of problems in the reported data. • PARTIALLY_ACCEPTED when the archive is technically compliant and at least one sub-fund has been correctly reported whereas at least another one is rejected because of problems in the reported data. Only sub-funds with errors are rejected. • ACCEPTED when the archive is technically compliant and all the sub-funds concerned by the report have been correctly reported. 4.1.3.2.2 ReportUids recently processed The report can be submitted to the CSSF: • By a single initial submission for all sub-funds of the UCI/IORP; • By several initial submissions with a part of the sub-funds in each submission; • To modify the data for one or more sub-funds; • To transmit the data for a new sub-fund. This means that different data for a same sub-fund could be received in separate reports. The CSSF will consider the last processed data as up-to-date. The feedback file lists the unique identifiers (reportUid) of the last reports concerning the fund in the CSSF processing order (most recent report at the top of the list). 4.1.3.2.3 Feedback message at report/sub-fund level If a report has the REJECTED or PARTIALLY_ACCEPTED status, the possible errors, at report or sub-fund level, are listed in the table below with the severity “ERROR”. If a report has the ACCEPTED or PARTIALLY_ACCEPTED status, a feedback message with the “SFO000” code is indicated for each accepted reported sub-fund. Feedback messages Note regarding the “level” column: A feedback message at the report level contains the property “entityCssfCode” with the CSSF code of the UCI/IORP. A feedback message at the sub-fund level contains the property “subfundCssfCode” in addition to the property “entityCssfCode”. Code Message Level Severity SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 18/81 SFO000 The report of the sub-fund has been accepted by Sub- the CSSF fund SFO001 The archive is corrupted Report ERROR SFO002 The archive name is invalid. The expected naming Report ERROR convention must follow the regex: INFO SFDR- (?<entityCssfCode>[OKVF]\\d{8})(?<reportType>PRECO)-(?<reportUid>[0-9af]{8}-[0-9a-f]{4}-[0-9a-f]{4}-[0-9a-f]{4}-[09a-f]{12}).zip SFO003 The archive size cannot exceed 20 MB Report ERROR SFO004 The submitter is not authorised to transmit the Report ERROR Report ERROR Report ERROR archive for this entity SFO005 The entity defined in the archive name is not in scope SFO006 The archive with reportUid "reportUid" has already been received for this entity SFO007 The archive must contain a single JSON file Report ERROR SFO008 JSON file does not respect JSON Schema Report ERROR SFO009 The unique identifier "reportUid" in the JSON file Report ERROR Report ERROR Sub- ERROR is different from the unique identifier used in the archive name SFO010 The CSSF code of the entity in the JSON file is different from the CSSF code of the entity used in the archive name SFO011 The sub-fund is not in the scope fund SFO012 The sub-fund is referenced multiple times Sub- ERROR fund SFO013 The field "fieldname" is required Sub- ERROR fund SFO014 The PDF file of the sub-fund is required Sub- ERROR fund SFO015 Number of files into the archive cannot exceed 500 Report ERROR files SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 19/81 4.2 eDesk online form An online form is available on the eDesk platform via the SFDR - Precontractual funds /IORPs disclosures module (https://edesk.apps.cssf.lu/s3opc/edesk-sfo/home). 4.2.1 Authentication The person in charge of submitting the precontractual information is required to have an eDesk account (available with LuxTrust authentication) and must be linked to the concerned entity (IFM, self-managed fund, IORP or delegated entity). Further details can be found in the user guide “eDesk – Authentication” that can be found on the CSSF eDesk homepage (or see chapter 4.2.5). 4.2.2 Creation and submission of a declaration The declaration of new SFDR data concerning a fund/IORP is possible via the “Create a declaration” button available on the dashboard homepage. The authorised user should select the concerned fund among the funds in scope (see chapter 2.1) for the entity this user is linked to. Fill-in of the requested information for a specific sub-fund of the selected fund is done by adding it in the corresponding table (sub-funds disclosing under SFDR Article 8, SFDR Article 9 or other sub-funds) in the “SFDR Precontractual Fund/IORP disclosures” section. The drop-down list to select a sub-fund is a searchable component, so it is necessary to type the name or the CSSF code of the sub-fund to select it. The format of the element in the list is: TXXXX-YY (sub-fund name) where TXXXX is the fund/IORP CSSF code and YY the sub-fund CSSF code ex: O9999-1 (O9999 sub-fund 1) SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 20/81 The “Upload of the precontractual disclosure templates” section must be used only if the physical version of the precontractual document has never been filed to the CSSF. A specific question “Did you already provide the pre-contractual template to the CSSF for the sub-fund?” must be answered for each sub-fund concerned by the declaration. If the answer is “No”, a line will appear in the “Upload of the precontractual disclosure templates” section for the corresponding sub-fund enabling the upload of a document. The “Did you already provide the pre-contractual template to the CSSF for the sub-fund?” question is neither available for UCITS nor IORPs because the template has been already sent to the CSSF in annex to the prospectus. For UCITS and IORPs, the “Upload of the precontractual disclosure templates” section should not be completed. A declaration can be submitted via the “Submit Questionnaire” button available in the “Submission of the declaration” section. The eDesk form guarantees that a declaration meets all the applicable validation rules (essentially those with a sub-fund level in chapter 4.1.3.2.3). 4.2.3 Export in PDF format It is possible to export in PDF format the data of a specific declaration that was created, whether it has been submitted or not. 4.2.4 Dashboard A dashboard lists all the declarations initiated by an authenticated user linked to the entity. The declaration might be incomplete (and not submitted), complete but not yet submitted and complete and submitted. It is possible to see the details of a declaration via the dashboard and modify or delete those not yet submitted. 4.2.5 Delegation Please note that the creation and submission of the declaration may be delegated by the IFM/IORP in charge to another person from another entity by clicking on the top right "Manage delegations" button. This will open the table of delegates with the status of the delegation(

1. s)already created. Things to know concerning the columns of the table: • First name / Last name: only appears in the table when the delegate has accepted the delegation (status “Active”) by clicking on the link received via email and connecting to eDesk, • E-mail: email of the person to whom entities (funds/IORP) have been delegated (see below), SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 21/81 • Role: the only possible delegation role is “Contribution and submission” (see below), • Status: The different statuses of a delegation are as follows: o To be transmitted: an email address and one or more funds (IORP) have been specified but the delegation has not been transmitted yet (double-click on the specific line to access the “Transmit” button), o Pending: the email has been transmitted to the delegate but this latter has not yet accepted the delegation by clicking on the link received via email and connecting to eDesk, he/she has 72 hours to do this, o Expired: the delegate has not accepted the delegation by clicking on the link received via email and connecting to eDesk within 72 hours, a specific icon will appear in the “Actions” column to resend the email to him/her, o Active: the delegated has accepted the delegation by clicking on the link received via email and connecting to eDesk, his/her first name and last name will appear in the table, o • Canceled: the delegation has been canceled by clicking on the “trash bin” icon in the “Actions” column Actions: the following actions are possible: o the “magnify” icon will open the detailed view of the related o the “trash bin” icon will cancel the delegation (available in any o the “resend” icon will send a new email to the delegate (only delegation, status except “Canceled”), for the status “Expired”). To create a new delegation, click on the “Create delegation” button. First fill in the professional email address of the person to which you want to delegate the creation and submission of the declaration(s), add a communication that will be part of the invitation email automatically sent to the delegate, and “Save”. Please note that the only possible role for the delegate is "Contribution and submission". This role allows creation and submission of the declaration. Then click on the “Add” button in the “Delegated funds/IORPs” table to specify the funds/IORP concerned by this delegation or click on the “Add all” button to specify all the funds/IORP. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 22/81 This will open a list of the funds/IORP managed by your entity. Tick only the checkboxes of the concerned fund(s)/IORP. Click on "Select" button and then click on the top right "Transmit" button to send the invitation to the email address of the delegate. The status of the delegation is now "Pending". Please note that at least one fund/IORP must be linked to the delegate to perform this action. Then, just wait for the delegate to accept the delegation (he/she must click on the email link and connect to eDesk). 4.2.6 Correction or modification of the last accepted pre-contractual data of a sub-fund When creating a new declaration, you can correct the pre-contractual data of a sub-fund based on the data already transmitted to the CSSF in a previous declaration. When you add a sub-fund in one of the tables (sub-funds disclosing under SFDR Article 8, sub-funds disclosing under SFDR Article 9, other sub-funds), the data previously submitted to the CSSF are automatically loaded into the form. You can then modify the data. The data are not preloaded in case of a change of the SFDR article under which the sub-fund discloses. 4.2.7 View last accepted data The connected user can consult the last data accepted by the CSSF by clicking on the "View last accepted data" button on the dashboard homepage. These data may have been submitted through eDesk or S3 channel. You can consult the details of sub-funds’ data by clicking on the “Consult” button in the “Actions” column of the dashboard. 4.2.8 Declarations to submit The connected user can consult the list of sub-funds for which a declaration is expected by clicking on the “Declarations to submit” button on the dashboard homepage. EDesk users with the "Board member" or "Conductive officer" role (advanced user if applicable) of the IFMs in charge receive an email when data is missing for at least one sub-fund. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 23/81 You must submit a report or justify why you consider you should not submit a report. To justify, please click on the "Justify" button in the "Actions" column. You must choose a reason from the list provided and add a comment if necessary. If you submit a report, please do not use the "Justify" action. 4.3 Reporting entities obligations 4.3.1 Data quality Entities are strongly advised to review and validate the reporting files (ZIP and JSON files) before any submission. Files must be validated against the JSON schema provided by the CSSF. 4.3.2 Review the feedback files and correct the rejected reports Entities must ensure that all feedback files are properly analysed and that any rejected data are corrected and resubmitted. 4.4 Testing with CSSF CSSF offers ways for entities to test their reporting file submission before going into production: • Connectivity check; • Dedicated testing environment. 4.4.1 Connectivity check A connectivity check is highly recommended before the Go-Live. Besides the main “SFDR” service, a dedicated “Echo Service” is at your disposal to ensure the good connectivity between your entity and our systems. The authentication steps are similar to the regular report in regard to getting the credentials (see 4.1.2.1.4) and uploading a file (see 4.1.2.1.5). The “IT Expert” has to create a new access on the “Echo” bucket that is presented below in order to get the right S3 credentials. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 24/81 You can upload a dummy file to the “submission” folder. If the connectivity check is completed, you will get a dummy feedback file as confirmation in the “feedback” folder. Please note that this service remains always available. In case you are unable to connect to the Echo Service or that you are not receiving any feedback, please contact ucisfdr@cssf.lu. 4.4.2 Dedicated testing environment End-to-end tests can be performed, on demand, in a dedicated environment. This environment will be open for a well-defined timeframe and its stability will be guaranteed at best effort level. There are differences between entities/UCIs/IORPs/sub-funds descriptive data on this environment and production data. This may have an impact on controls performed, especially scope controls. For this testing environment, S3 credentials will directly be provided by the CSSF (without enrolment). All data transmitted on this environment must be understood as test data only. If you are interested in test SFDR reports submission to the CSSF through this testing environment, please send an email to ucisfdr@cssf.lu to receive the necessary information. Please note that the CSSF will need a range of external IP addresses of your entity to configure the testing environment. 5. Contact information If you have any questions, please contact ucisfdr@cssf.lu. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 25/81 To facilitate the processing of your request, please provide the following information: 6. • CSSF code and name of the IFM; • CSSF code and name of the UCI/IORP; • Type of UCI/IORP (UCITS/AIF/IORP); • Type of report (precontractual). Questions & Answers Please find below a selection of questions and answers that might be useful for you. 6.1 Is a LuxTrust certificate mandatory for using eDesk? Yes. Only authenticated users (through LuxTrust token) are able to access eDesk and get the keys to configure the S3 client. Our eDesk support team is here to help you create your eDesk account if needed (edesk@cssf.lu). 6.2 Who can grant the "IT Expert" role to a user within my entity? The “IT Expert” is a specific role that can be granted to one (or several) person(
2. s)within your entity. The “Advanced User” assigned in your entity is able to grant this specific role to a user registered in eDesk and already linked to the entity. If the identified person does not have any eDesk account yet, please follow the procedure for eDesk account creation 1. 6.3 What is the role of the "IT Expert"? The designated "IT Expert" manages access to the S3 API provided by the CSSF. This role is responsible for creating, viewing and revoking access keys. These keys will be used to send SFDR UCI data reporting to the CSSF (either manually or with an automated tool). 1 On the eDesk portal homepage (https://edesk.apps.cssf.lu/), the eDesk Authentication User Guide (pdf file) is a guide that describes how to configure authentication and that can be found in the “Getting started” menu. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 26/81 6.4 Is it possible to share S3 credentials externally? The "IT Expert" is in charge of monitoring all S3 credentials that might be created. The sharing of S3 credentials and file upload through a third party remains the sole responsibility of the entity. 6.5 How might we parameter the S3 protocol? This new solution is based on the use of a well-documented protocol (S3). The use of the S3 protocol can be done either via various applications supporting this protocol (S3 transfer client) or directly via the programming language of your choice by using a client library supporting this protocol. 6.6 Is S3 similar to a SFTP solution? Yes, the principle remains the same. The difference is that the S3 protocol is based on “https” standards. 6.7 What is the “ECHO” service? As good practice for API supply, an ECHO service is available in production to check connectivity. Input files are dummy files and feedbacks are dummy feedbacks. Each submitted file in the ECHO folder produces one immediate feedback only. 6.8 Can you please explain how to set up an S3 compatible transfer client? Any S3 transfer client tool can be configurated with the following information: • File protocol: S3; • Host name: s3.apps.cssf.lu; • Port number: 443; • Access Key ID and Secret access key that your "IT Expert" can collect on eDesk. Depending on the tool nature, you will eventually have to change your “URL style” to “Path” in its parameters. 6.9 My entity did choose to configure an S3 transfer client. However, I am not seeing any "submission" folder in my S3 bucket. What should I do? For each type of report to be filed, the IT Expert must create a ‘submission’ folder - to upload the first file into our server’s bucket. The ‘feedback’ folder is automatically created when generating the feedback. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 27/81 6.10 Which file format is expected by the CSSF? For SFDR UCI data report, a ZIP file containing at least a JSON file – that respects the nomenclature as defined in the User Guide – is expected. 6.11 Is the S3 protocol linked to a commercial cloud provider? In this context, S3 only refers to the technical protocol for managing object storage and does not rely on any services provided by commercial cloud providers. 6.12 What is the retention period for files in the bucket? The files in the "submission" and "feedback" folders are cleaned by the CSSF 20 days after their creation. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 28/81 Annex I – Synopsis on information to be collected for sub-funds not disclosing under SFDR Article 8 or SFDR Article 9 * CSSF guidance: Please refer to annex IV for the codes to be used in the report for closed questions (Yes/No answers, or answers referring to a predefined list) Information to be provided CSSF code of the sub-fund Technical attribute of the information CSSF guidance* Reference to the to be provided in the JSON file (cf. precontractual 4.1.2.2.1) template subfundCssfCode Please refer to point 2.4 above in order to identify the CSSF code. Number corresponding to the compartment without zero in front of the number. For a stand-alone fund, please enter 0. For a multiple compartment fund, please indicate the corresponding number. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 29/81 None Article 6 SFDR Are sustainability risks integrated into the investment decisions for article6Indicator Only a “Yes” or “No” answer is None required this financial product (Art. 6 SFDR)? Is the information in informationArticle6DisclosedIndicator accordance with Article 6 Only a “Yes” or “No” answer is None required SFDR disclosed? Article 7 SFDR Are principal impacts on adverse article7Indicator sustainability Only a “Yes” or “No” answer is None required factors considered for this financial product (Art. 7 SFDR)? Is the information in informationArticle7DisclosedIndicator accordance with Article 7 Only a “Yes” or “No” answer is required SFDR disclosed? SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 30/81 None Annex II – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 8 CSSF guidance: Please refer to annex IV for the code to be used in the report for closed questions (Yes/No answers, or answers referring to a predefined list) Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) CSSF code of the sub-fund subfundCssfCode Please refer to point 2.4 above in order to identify the CSSF code. Number corresponding to the compartment without zero in front of the number. For a stand-alone fund, please enter 0. For a multiple compartment fund, please indicate the corresponding number. The sub-fund promotes Environmental / Social sustainableInvestment characteristics and while it does not have as sIndicator Only a “Yes” or “No” answer is required. Questions from the derived graphical its objective a sustainable investment, it will representation of the make sustainable investments question “Does this Minimum proportion investments of sustainable sustainableInvestment Only if the answer to the question sMinimumProportion1 “sustainableInvestmentsIndicator” SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 31/81 financial product have a sustainable Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) is “Yes”, a positive percentage reflecting investment the minimum commitment is required objective?” With an environmental objective in economic environmentalObjectiv Only if the answer to the question activities eTaxonomyIndicator “sustainableInvestmentsIndicator” is “Yes”, is that qualify as environmentally sustainable under the EU Taxonomy a “Yes” or “No” answer required. With an environmental objective in economic environmentalObjectiv Only if the answer to the question activities eNoTaxonomyIndicato “sustainableInvestmentsIndicator” is r “Yes”, is that do not qualify as environmentally sustainable under the EU Taxonomy a “Yes” or “No” answer required. With a social objective socialObjectiveIndicat Only if the answer to the question or “sustainableInvestmentsIndicator” is “Yes”, is a “Yes” or “No” answer required. What environmental and/or social eAndSCharacteristics characteristics are promoted by the sub-fund Please select the appropriate characteristics from the below list. Please note that multiple selections are possible: SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 32/81 Cf. below the table

(1)Information to be provided Technical attribute CSSF guidance to of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) • Environmental – energy; • Environmental – renewable energy; • Environmental – raw materials; • Environmental – water and land; • Environmental – waste; • Environmental – greenhouse gas emissions; • Environmental – biodiversity; • Environmental – circular economy; • Environmental – other; • Social – inequality; • Social – social cohesion; • Social – social integration: • Social – labour relations: • Social – investment in human capital; • Social – economically or socially disadvantaged communities; • Social – other. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 Reference 33/81 the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) Please specify other environmental characteristics otherEnvironmentalCh Only aracteristicsDescriptio selected if “Environmental n eAndSCharacteristics, specify characteristic(

1. s)on for – the based other” is question a the short description/catch words (in English and ideally not exceeding 50 characters). Please specify other social characteristics otherSocialCharacteris Only if “Social – other” is selected for the ticsDescription question eAndSCharacteristics, specify the characteristic(
2. s)based on a short description/catch words (in English and ideally not exceeding 50 characters). What are the objectives of the sustainable sustainableInvestment The below list contains the objectives of investments sObjectives Article 9 TR as well as “Social objective”. that the sub-fund partially intends to make? Please note that multiple selections are possible. If the answer to the question “sustainableInvestmentsIndicator” is “Yes”, select the appropriate objectives from the list is required: • Climate change mitigation ; SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 34/81 the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) • Climate change adaptation ; • The sustainable use and protection of water and marine resources; • The transition to a circular economy; • Pollution prevention and control; • The protection and restoration of biodiversity and ecosystems; • Does the sub-fund consider principle adverse principalAdversImpact impacts on sustainability factors? ConsiderationIndicator What investment strategy does the sub-fund investmentsStrategies follow? Social objective. Only a “Yes” or “No” answer is required. The below list is based on the nonexhaustive list provided in point 35 of the ESMA SB. Multiple selections are possible. • Best in class • Thematic • ESG integration SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 35/81 the Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) Please specify other investment strategies • ESG engagement • Impact investing • Exclusions • Other otherInvestmentsStrat Only if “Other” is selected for the egiesDescription question investmentsStrategies, specify the investment strategy(-ies) based on a short description/catch words (in English and ideally not exceeding 50 characters). Is a policy applied to assess good governance goodGovernancePolicy practices of the investee companies? Indicator Only a “Yes” or “No” answer is required. Recasting of question “What is the policy to assess good governance practices of the companies” investee into binary question. If no, please explain noGoodGovernancePol Only if the answer to the question icyDescription goodGovernancePolicyIndicator is “No”, please provide a short explanation (in SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 36/81 a Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) English and ideally not exceeding 100 characters). Minimum proportion of investments aligned alignedESCharacteristi A positive percentage reflecting the Questions with environmental or social characteristics - csInvestmentsMinimu minimum commitment is required. from #1 mProportion Aligned with E/S characteristics (in graphical representation of the percent) Minimum the derived question “What is the proportion of sustainable investments – 1#A Sustainable (in percent) sustainableInvestment If the answer to the question sMinimumProportion2 “sustainableInvestmentsIndicator” is for financial product?” the minimum commitment is required. table. If It should be noted the answer to the question is otherESCharacteristics The percentage should be the difference characteristics investments that do not qualify InvestmentsMinimumP of the percentages provided in response as sustainable investments - #1B Other E/S roportion to questions alignedESCharacteristicsInvestmentsMi SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 37/81 below the the box “Investments” Minimum proportion of environmental or social nimumProportion that

(2)this “Yes”, a positive percentage reflecting “No”, no value is required. Version diffusée - Juin 2024 allocation planned Cf. “sustainableInvestmentsIndicator” characteristics (in percent) asset and constitutes the 100 percent base and the different percentages of each box should be Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) sustainableInvestmentsMinimumProport expressed in relation ion2 to that base. Minimum proportion of remaining investments remainingInvestments A positive percentage or 0 percent are which MinimumProportion possible. Minimum proportion of Taxonomy-aligned (in taInvestmentsMinimu If percent) mProportion environmentalObjectiveTaxonomyIndica are neither aligned with the environmental or social characteristics, nor are qualified as sustainable investments - #2 Other (in percent) the answer to the question tor is “Yes”, a positive percentage reflecting the minimum commitment is required. If the answer to the question environmentalObjectiveTaxonomyIndica tor is “No”, no value is required. Minimum proportion of Other environmental otherEnvironmentalMi If the answer to (in percent) nimumProportion environmentalObjectiveNoTaxonomyInd icator SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 38/81 the question Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) is “Yes”, a positive percentage reflecting the minimum commitment is required If the answer to the question environmentalObjectiveNoTaxonomyInd icator is “No”, no value is required. Minimum proportion of Social (in percent) socialMinimumProporti If to the question on socialObjectiveIndicator the is “Yes”, positive answer percentage reflecting a the minimum commitment is required. If the answer to the socialObjectiveIndicator is question “No”, no value is required. Does the sub-fund use derivatives as defined derivativesUseIndicato in Article 2

(1), point

(29), of Regulation (EU) r Only a “Yes” or “No” answer is required. No 600/2014 to attain the environmental or social characteristics they promote? Taxonomy-aligned activities are expressed as taCalculationMethod a share of: If the answer to the question environmentalObjectiveTaxonomyIndica tor is “Yes”, the answer should be one SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 39/81 the Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) single selection out of the three possible Questions referring to options from the below list: the taxonomy aligned investments. • Turnover; • Capital expenditure; Cf. • Operational expenditure. table. Does the sub-fund invest in fossil gas related fossilGasInvestmentsI If activities complying with the EU Taxonomy? ndicator environmentalObjectiveTaxonomyIndica the answer to the question tor is “Yes”. Only a “Yes” or “No” answer is required. Does the sub-fund invest in nuclear energy nuclearEnergyInvestm If related entsIndicator environmentalObjectiveTaxonomyIndica activities complying with the EU Taxonomy? the answer to the question tor is “Yes”. Only a “Yes” or “No” answer is required. Minimum percentage of investments in fossil fossilGasInvestmentsI If gas nclSovereignBondsMin fossilGasInvestmentsIndicator is “Yes”, imumProportion a positive percentage reflecting the related activities aligned taxonomy including sovereign bonds with EU the answer to the question minimum commitment is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 40/81

(3)below the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. Minimum percentage of investments in nuclear nuclearEnregyInvestm If energy related activities aligned with EU entsInclSovereignBon nuclearEnergyInvestmentsIndicator taxonomy including sovereign bonds dsMinimumProportion “Yes”, a positive percentage reflecting the answer to the question is the minimum commitment is required. If the answer is “No”, no value is required. Minimum percentage of investments remainingInvestments If (excluding fossil gas and nuclear energy InclSovereignBondsMi environmentalObjectiveTaxonomyIndica related activities) aligned with EU taxonomy nimuProportion tor is “Yes”, a positive percentage including sovereign bonds the answer to the question reflecting the minimum commitment is required. If the answer is “No”, no value is required. Minimum percentage of investments in fossil fossilGasInvestmentsE If gas xclSovereignBondsMini fossilGasInvestmentsIndicator is “Yes”, mumProportion a positive percentage reflecting the related activities aligned with taxonomy excluding sovereign bonds EU the answer to the question minimum commitment is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 41/81 the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. Minimum percentage of investments in nuclear nuclearEnregyInvestm If energy related activities aligned with EU entsExclSovereignBon nuclearEnergyInvestmentsIndicator taxonomy excluding sovereign bonds dsMinimumProportion “Yes”, a positive percentage reflecting the answer to the question is the minimum commitment is required. If the answer is “No”, no value is required. Minimum percentage of investments remainingInvestments If (excluding fossil gas and nuclear energy ExclSovereignBondsMi environmentalObjectiveTaxonomyIndica related activities) aligned with EU taxonomy nimuProportion tor is “Yes”, a positive percentage the answer to the question reflecting the minimum commitment is excluding sovereign bonds required. If the answer is “No”, no value is required. What is the minimum share of investments in transitionalActivitiesIn If transitional activities? vestmentsMinimumSh environmentalObjectiveTaxonomyIndica are tor is “Yes”, a positive percentage or the answer to SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 42/81 the question the Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) zero reflecting the minimum commitment is required. If the answer is “No”, no value is required. What is the minimum share of investments in enablingActivitiesInves If the answer to the question enabling activities? tmentsMinimumShare environmentalObjectiveTaxonomyIndica tor is “Yes”, a positive percentage or zero reflecting the minimum commitment is required. If the answer is “No”, no value is required. Are there any minimum environmental or environmentalOrSocial social safeguards for investments included SafeguardsMinimumIn under “#2 Other”? dicator Is a specific index designated as a reference referenceBenchmarkD benchmark to determine whether the sub- esignatedIndicator Only a “Yes” or “No” answer is required. Only a “Yes” or “No” answer is required. Question referring to question “Is a specific fund is aligned with the environmental and/or index designated as a social characteristics that it promotes? reference benchmark (…)?” SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 43/81 Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) Is an ISIN code available for the reference referenceBenchmarkIs If benchmark? inCodeIndicator referenceBenchmarkDesignatedIndicato the answer to the question None r is “Yes”, only a “Yes” or “No” answer is required. If the answer is “No”, no value is required. Specify the ISIN code of the reference benchmark referenceBenchmarkIs If the answer to the question inCode referenceBenchmarkIsinCodeIndicator is “Yes”, provide the ISIN code of the benchmark. If the answer is “No”, no value is required. Specify the name of the reference benchmark referenceBenchmarkN If ame referenceBenchmarkIsinCodeIndicator is the “No”, answer provide to the the name question of the benchmark. If the answer is “Yes”, no value is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 44/81 None the Information to be provided Technical attribute CSSF guidance Reference to of the information to precontractual be provided in the template JSON file the (cf. 4.1.2.2.1) Indicate the referenceBenchmarkC If question Question referring to methodology used for the calculation of the where website link of alculationMethodWebsi referenceBenchmarkDesignatedIndicato the answer to the question “Where can designated index can be found teLink r is “Yes”, provide the website link of the the benchmark. used If the answer is “No”, no value is required. More product-specific information can be found on the website methodology for calculation the of found?” subfundSpecificInform A hyperlink to the website referred to in ationWebsiteLink Article 23 of the SFDR-RTS is required. The following set of questions is for supervisory purposes, but does not derive from the precontractual template Does the above-mentioned hyperlink direct complianceArt23Indica investors tor to a separate “Sustainability-related section disclosures” titled in Only a “Yes” or “No” answer is required. None Only a “Yes” or “No” answer is required. None the same part of the website (as specified in Q3 of the CSSF SFDR FAQ) as the other information relating to the financial product, including marketing communications, in line with and as further detailed in Article 23 of the SFDR RTS? Does the product-related website disclosures, complianceArt24Indica available tor through the above-mentioned SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 45/81 the designated index be Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) hyperlink, provide all information set out in Article 10

(1)SFDR and Articles 25 to 36 SFDRRTS, through the sections and order as specified in Article 24 SFDR-RTS? Did you already provide the precontractual templateProvidedToCs template to the CSSF for the sub-fund? sfIndicator The answer is only required for AIFs. None Only a “Yes” or “No” answer is required. If the answer is “No”, you must provide the precontractual archive according template in to naming the the convention in the chapter 4.1.2.2.4 Sub-fund still in a ramp-up period? rampUpPeriodIndicato r Ramp-up period end date rampUpPeriodEndDate The answer is only required for AIFs. Only a “Yes” or “No” answer is required. The answer is only required for AIFs. If the answer to the question rampUpPeriodIndicator is “Yes”, provide the end date of the ramp-up period in the format “YYYY-MM-DD”. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 46/81 the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. Please confirm that the precontractual templateAvailableToIn template is available to investors vestorsIndicator For AIFs not integrating the precontractual templateNotInProspect template in the prospectus, please advise usWhereAndHowAvaila where and how it is available to investors bleToInvestors The answer is only required for AIFs. Only a “Yes” or “No” answer is required. The answer is only required for AIFs. If the answer to the question templateProvidedToCssfIndicator is “No”, please advise where and how the template is available. The answer shall not exceed 1,000 characters. If the answer is “Yes”, no value is required. For AIFs not integrating the precontractual specificESGInvestment template Policy in the prospectus, ESG-specific investment policy The answer is only required for AIFs. If the answer to the question templateProvidedToCssfIndicator is “No”, please describe the ESG-specific investment policy. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 47/81 the Information to be provided Technical attribute CSSF guidance precontractual be provided in the template file (cf. 4.1.2.2.1) The answer shall not exceed 1,000 characters. If the answer is “Yes”, no value is required. Prominent statement in the main body of the prominentStatementM prospectus/issuing document ainBodyProspectusIndi Only a “Yes” or “No” answer is required. cator They comply with the requirements set out in requirementsCDRCom the CDR; especially the general principles plianceIndicator foreseen in Article 2 of the CDR They do not contradict with the information noContradictionWithW currently published for the respective (sub-) ebsiteLinkIndicator fund on the website (link) in accordance with The answer is only required for AIFs. Only a “Yes” or “No” answer is required. The answer is only required for AIFs. Only a “Yes” or “No” answer is required. Article 10 of Regulation (EU) 2019/2088 on disclosures in the financial services sector (SFDR) SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to of the information to JSON sustainability‐related Reference 48/81 the Information to be provided Technical attribute CSSF guidance precontractual be provided in the template file (cf. 4.1.2.2.1) not contradict with information noContradictionWithDi disclosed under Article 22 and 23 of the sclosedInformationIndi AIFMD; information disclosed in the PRIIPs cator The answer is only required for AIFs. Only a “Yes” or “No” answer is required. KID (if applicable) or information contained in any marketing communication according to Article 13 SFDR They are accurate and reflect what has been reflectImplementation actually implemented Indicator Are sustainability risks integrated into the sustainabilityRisksCon investment decisions for this financial product sideredIndicator The answer is only required for AIFs. Only a “Yes” or “No” answer is required. Only a “Yes” or “No” answer is required. (Art. 6 SFDR)? Is the information in accordance with Article 6 art6InformationDisclos SFDR disclosed? edIndicator Confirm that the template(s) used for the templateCDRCopyIndi precontractual cator disclosures of (sub-)funds qualifying as Article 8 Product (“Product 8”) or Only a “Yes” or “No” answer is required. The answer is only required for AIFs. Only a “Yes” or “No” answer is required. Article 9 Product (“Product 9”) under SFDR is a one-to-one copy of the template foreseen in annex II or III respectively of the CDR and has not been altered except perhaps as regards SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to of the information to JSON They do Reference 49/81 the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) the size and front type of characters or the colour used as permitted by Article 2 CDR All sections of the template have been properly templateAllSectionsCo completed and those which are not applicable mpletedIndicator have been disclosed as such Does the information provided here latestPublishedInform correspond to the latest published information ationCorrespondenceI ndicator Date of the latest template (version) issued precontractual The answer is only required for AIFs. Only a “Yes” or “No” answer is required. The answer is only required for AIFs. Only a “Yes” or “No” answer is required. templateLatestIssued The date in the format “YYYY-MM-DD” is Date required. For UCITS, the date of the prospectus is required. For AIFs, it might be the date of the prospectus, or the date of disclosure to investors referred to in Article 23

(1)of Directive 2011/61/EU to the investors. For a prospectus disclosing “Month Name YYYY” on its cover page shall regard the format above and insert SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 50/81 the Information to be provided Technical attribute CSSF guidance Reference of the information to precontractual be provided in the template JSON file (cf. 4.1.2.2.1) “YYYY-MM-01” (e.g. 2023-01-01). SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 51/81 January 2023 the

(2)Note that “Investments” constitute the 100 percent base and the different percentages of each box should be expressed in relation to that base. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 52/81

(3)SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 53/81 Annex III – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 9 CSSF guidance: Please refer to annex IV for the code to be used in the report for closed questions (Yes/No answers, or answers referring to a predefined list) Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) CSSF code of the sub-fund subfundCssfCode Please refer to point 2.4 above in order to identify the CSSF code. Number corresponding to the compartment without zero in front of the number. For a stand-alone fund, please enter “0”. For a multiple compartment fund, please indicate the corresponding number. The sub-fund will make a minimum sustainableInvestments Only a “Yes” or “No” answer is of sustainable investments with an Indicator required. environmental objective SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 54/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Minimum proportion of sustainable sustainableInvestments If the answer investments with an environmental EnvironmentalMinimum “sustainableInvestmentsIndicator” graphical representation of the objective Proportion1 is percentage question “Does this reflecting the minimum commitment product have a is required. investment “Yes”, a to the positive question In economic activities that qualify as environmentalObjective Only if the answer to the question environmentally sustainable under TaxonomyIndicator “sustainableInvestmentsIndicator” the EU Taxonomy is “Yes”, a “Yes” or “No” answer is required. In economic activities that do not environmentalObjective Only if the answer to the question qualify NoTaxonomyIndicator “sustainableInvestmentsIndicator” as environmentally is “Yes”, a “Yes” or “No” answer is sustainable under the EU Taxonomy required. The sub-fund will make a minimum of sustainable investments with a socialObjectiveIndicator Only a “Yes” or “No” answer is required. social objective SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 55/81 Questions derived from the financial sustainable objective?” Cf.

(1)below the table. Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) Minimum percentage of sustainable sustainableInvestments If investments with a social objective SocialMinimalProportion “socialObjectiveIndicator” is “Yes”, a 1 positive percentage reflecting the the answer to the question minimum commitment is required. What is the sustainable investment environmentalAndSocial The objective of the sub-fund? Objectives objectives of Article 9 TR as well as below list contains the “Social objective”. Please note that multiple selections are possible: • Climate change mitigation; • Climate change adaptation; • The sustainable protection of use and water and marine resources; • Transition to a circular economy; • Pollution prevention control; SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 56/81 and the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) • The protection restoration of and biodiversity and ecosystems; • Reduction in carbon emissions; • Social objective. Does the sub-fund consider principle principalAdversImpactC Only a “Yes” or “No” answer is adverse impacts on sustainability onsiderationIndicator required. investmentsStrategies The below list is based on the non- factors? What investment strategy does the sub-fund follow? exhaustive list provided in point 35 of the ESMA SB. Multiple selections are possible: • Best in class; • Thematic; • ESG integration; • ESG engagement; • Impact investing; SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 57/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Please specify other investment strategies • Exclusions; • Other. otherInvestmentsStrate Only if “Other” is selected for the giesDescription question investmentsStrategies, specify the investment strategy(ies) on a short description/keywords (in English and based ideally not exceeding 50 characters). Is a policy applied to assess good goodGovernancePolicyI Only a “Yes” or “No” answer is Recasting of the question “What is governance practices of the investee ndicator required. the policy governance companies? investee to practices companies?” binary question. If no, please explain noGoodGovernancePolic Only if the answer to the question yDescription goodGovernancePolicyIndicator “No”, please provide a is short explanation (in English and ideally not exceeding 100 characters). SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 58/81 assess good of the into a Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Minimum proportion of sustainable sustainableInvestments If investments – 1# Sustainable (in MinimalProportion “sustainableInvestmentsIndicator” graphical representation of the and/or the answer to the question question socialObjectiveIndicator is “Yes”, a allocation positive percentage reflecting the financial product?” minimum commitment is required. the table. If the answer to both questions is Note that the box “Investments” “No”, no value is required. constitutes the 100 percent base percent) the answer to the question Questions derived “What from the is the asset planned for this Cf.

(2)below and the different percentages of each box should be expressed in relation to that base. Minimum proportion of sustainable sustainableInvestments If environmental investments - #1 EnvironmentalMinimum sustainableInvestmentsIndicator Sustainable Environmental (in Proportion2 “Yes”, - percent) the answer a to positive the question is Questions percentage question reflecting the minimum commitment allocation is required. financial product?” SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 59/81 from the graphical representation of the the table. Version diffusée - Juin 2024 derived “What is the asset planned for this Cf.

(2)below Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) It should be noted that the box “Investments” constitutes the 100 percent base and the different percentages of each box should be expressed in relation to that base. Minimum proportion of Taxonomy- sustainableInvestments If aligned EnvironmentalTaMinimu environmentalObjectiveTaxonomyIn graphical representation of the mProportion dicator - #1 Sustainable - Environmental - Taxonomy-aligned (in percent) the answer Questions derived the allocation commitment is required. financial product?” Cf.

(2)below to the question “What from question answer a question positive the “Yes”, the percentage reflecting the minimum If is to is the asset planned for this the table. environmentalObjectiveTaxonomyIn It should be noted that the box dicator is “No”, no value is required. “Investments” constitutes the 100 percent base and the different percentages of each box should be expressed in relation to that base. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 60/81 Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Minimum proportion of Other - #1 sustainableInvestments If the answer Sustainable - Environmental - Other EnvironmentalOtherMini sustainableInvestmentsIndicator (in percent) mumProportion “Yes”, question is derived allocation is required. financial product?” answer to the question is “No”, no value is required. the answer to the sustainableInvestments If social investments #1 Sustainable - SocialMinimumProportio socialObjectiveIndicator is “Yes”, a Social (in percent) n2 positive percentage reflecting the question minimum commitment is required. the answer to the the “What is planned the asset for this Cf.

(2)below the table. It should be noted that the box “Investments” constitutes the 100 Minimum proportion of sustainable If from graphical representation of the reflecting the minimum commitment sustainableInvestmentsIndicator question socialObjectiveIndicator is “No”, no value is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 Questions question the positive the percentage If a to 61/81 percent base and the different percentages of each box should be expressed in relation to that base. Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Minimum proportion of sustainable investments -#2 not notSustainableInvestm A positive percentage or 0 percent Not entsMinimumProportion are possible. sustainable (in percent) The percentage should be the “Investments” not falling under “#1 Sustainable”. Does the sub-fund use derivatives as derivativesUseIndicator defined in Article 2

(1), point

(29), of Only a “Yes” or “No” answer is required. Regulation (EU) No 600/2014 to attain the environmental or social characteristics they promote? Taxonomy-aligned activities expressed as a share of are taCalculationMethod If the answer to the question environmentalObjectiveTaxonomyIn dicator is “Yes”, the answer should be one single selection out of the three possible options from the below list: • Turnover; • Capital expenditure; SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 62/81 Questions referring to the taxonomy aligned investments. Cf.

(3)below the table Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) • Operational expenditure. the answer Does the sub-fund invest in fossil gas fossilGasInvestmentsIn If related activities complying with the dicator environmentalObjectiveTaxonomyIn EU Taxonomy? to the question dicator is “Yes”, only a “Yes” or “No” answer is required. Does the sub-fund invest in nuclear nuclearEnergyInvestme If energy related activities complying ntsIndicator environmentalObjectiveTaxonomyIn with the EU Taxonomy? the answer to the question dicator is “Yes”, only a “Yes” or “No” answer is required. Minimum percentage of investments fossilGasInvestmentsIn If in fossil gas related activities aligned clSovereignBondsMinim fossilGasInvestmentsIndicator with umProportion “Yes”, EU taxonomy sovereign bonds including the answer a to positive the question is percentage reflecting the minimum commitment is required. If the answer is “No”, no value is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 63/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) Minimum percentage of investments nuclearEnregyInvestme If in nuclear energy related activities ntsInclSovereignBonds nuclearEnergyInvestmentsIndicator aligned with EU taxonomy including MinimumProportion is sovereign bonds the answer “Yes”, a to the positive question percentage reflecting the minimum commitment is required. If the answer is “No”, no value is required. Minimum percentage of investments remainingInvestmentsI If (excluding fossil gas and nuclear nclSovereignBondsMini environmentalObjectiveTaxonomyIn energy related activities) aligned muProportion dicator with EU taxonomy including the answer is to “Yes”, the a question positive percentage reflecting the minimum sovereign bonds commitment is required. If the answer is “No”, no value is required. Minimum percentage of investments fossilGasInvestmentsEx If in fossil gas related activities aligned clSovereignBondsMinim fossilGasInvestmentsIndicator with umProportion “Yes”, EU taxonomy sovereign bonds excluding the answer a to positive the question is percentage reflecting the minimum commitment is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 64/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. Minimum percentage of investments nuclearEnregyInvestme If in nuclear energy related activities ntsExclSovereignBonds nuclearEnergyInvestmentsIndicator aligned with EU taxonomy excluding MinimumProportion is the answer “Yes”, a to the positive question percentage reflecting the minimum commitment sovereign bonds is required. If the answer is “No”, no value is required. Minimum percentage of investments remainingInvestmentsE If (excluding fossil gas and nuclear xclSovereignBondsMini environmentalObjectiveTaxonomyIn energy related activities) aligned muProportion dicator with EU taxonomy sovereign bonds excluding the answer is to “Yes”, the a question positive percentage reflecting the minimum commitment is required. If the answer is “No”, no value is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 65/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) What is the minimum share of transitionalActivitiesInv If investments in transitional activities? estmentsMinimumShare environmentalObjectiveTaxonomyIn the answer dicator is to the “Yes”, a question positive percentage is required. If the answer is “No”, no value is required. What is the minimum share of enablingActivitiesInvest If investments in enabling activities? mentsMinimumShare environmentalObjectiveTaxonomyIn the answer dicator is to the “Yes”, a question positive percentage is required. If the answer is “No”, no value is required. Are there any minimum environmentalOrSocialS Only a “Yes” or “No” answer is environmental or social safeguards afeguardsMinimumIndic required. for investments included under “#2 ator Not sustainable”? SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 66/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Is a specific index designated as a referenceBenchmarkDe Only a “Yes” or “No” answer is reference benchmark to determine signatedIndicator required. Question referring to question “Is whether the sub-fund is aligned with the environmental and/or a specific index designated as a social reference benchmark (…)?” characteristics that it promotes? Is an ISIN code available for the referenceBenchmarkIsi If reference benchmark? nCodeIndicator referenceBenchmarkDesignatedIndi the answer to the question cator is “Yes”, only a “Yes” or “No” answer is required. If the answer is “No”, no value is required. Specify the ISIN reference benchmark code of the referenceBenchmarkIsi If the answer to the question nCode referenceBenchmarkIsinCodeIndicat or is “Yes”, provide the ISIN code of the benchmark. If the answer is “No”, no value is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 67/81 Information to be provided Technical attribute of CSSF guidance Reference the information to be to the precontractual template provided in the JSON file (cf. 4.1.2.2.1) Specify the name of the reference referenceBenchmarkNa If the answer to the question benchmark me referenceBenchmarkIsinCodeIndicat or is “No”, provide the name of the benchmark. If the answer is “Yes”, no value is required. Indicate the referenceBenchmarkCal If methodology used for the calculation website link of culationMethodWebsiteL referenceBenchmarkDesignatedIndi the answer to the question “Where can the methodology used of the designated index can be found ink cator is “Yes”, provide the website for link of the benchmark. designated index be found?” If the answer is “No”, no value is required. More product-specific information can be found on the website subfundSpecificInforma A hyperlink to the website referred tionWebsiteLink to in Article 23 of the SFDR-RTS is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 68/81 Question the referring to calculation question of the Information to be provided Technical attribute of CSSF guidance Reference the information to be to precontractual template provided in the JSON file (cf. 4.1.2.2.1) The following set of questions are for supervisory purposes, but do not derive from the precontractual template Does the above-mentioned hyperlink complianceArt23Indicat Only a “Yes” or “No” answer is direct investors to a separate section or required. Does the product related website complianceArt37Indicat Only a “Yes” or “No” answer is disclosures, available through the or required. titled None “Sustainability-related disclosures” in the same part of the website (as specified in Q3 of the CSSF SFDR FAQ) as the other information relating to the financial product, including marketing communications, in line with and as further detailed in Article 23 of the SFDR RTS? above-mentioned hyperlink, provide all information set out in Article 10

(1)SFDR and Articles 38 to 49 SFDR-RTS, through the sections and order as specified in Article 37 SFDRRTS? SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 69/81 None the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) Did you already provide the precontractual template to the CSSF templateProvidedToCssf Indicator for the sub-fund? The answer is only required for AIFs. None Only a “Yes” or “No” answer is required. If the answer is “No”, you must provide the precontractual template in the archive according to the naming convention in the chapter 4.1.2.2.4 Sub-fund still in a ramp-up period? rampUpPeriodIndicator The answer is only required for AIFs. None Only a “Yes” or “No” answer is required. Ramp-up period end date rampUpPeriodEndDate The answer is only required for AIFs. If the answer to the rampUpPeriodIndicator question is “Yes”, provide the end date of the ramp-up period in the format “YYYY-MM-DD”. If the answer is “No”, no value is required SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 70/81 None the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) Please confirm that the precontractual template is available templateAvailableToInv estorsIndicator to investors The answer is only required for AIFs. None Only a “Yes” or “No” answer is required. For AIFs not integrating the pre- templateNotInProspectu contractual sWhereAndHowAvailabl template in the prospectus, please advise where and eToInvestors how it is available to investors The answer is only required for AIFs. If the answer to the question templateProvidedToCssfIndicator is “No”, please advise where and how the template is available. The answer shall not exceed 1.000 characters. If the answer is “Yes”, no value is required. For AIFs not integrating the pre- specificESGInvestmentP contractual olicy template in the prospectus, ESG-specific investment policy The answer is only required for AIFs. If the answer to the question templateProvidedToCssfIndicator is “No”, please describe the specific investment policy. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 71/81 ESG None the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) The answer shall not exceed 1.000 characters. If the answer is “Yes”, no value is required. Prominent statement in the main prominentStatementMai Only a “Yes” or “No” answer is body nBodyProspectusIndicat required. of the prospectus/issuing document or They comply with the requirements requirementsCDRCompl set out in the CDR; especially the ianceIndicator general principles foreseen in Article 2 of the CDR The answer is only required for AIFs. Only a “Yes” or “No” answer is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 72/81 None the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) They do not contradict the information currently published for noContradictionWithWe bsiteLinkIndicator the respective (sub-)fund on the The answer is only required for AIFs. Only a “Yes” or “No” answer is required. website (link) in accordance with Article 10 of the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (SFDR) They do not contradict information noContradictionWithDis disclosed under Article 22 and 23 of closedInformationIndica the AIFMD; information disclosed in tor the PRIIPs KID (if applicable) or information contained in The answer is only required for AIFs. Only a “Yes” or “No” answer is required. any marketing communication according to Article 13 SFDR They are accurate and reflect what reflectImplementationI has actually been implemented ndicator The answer is only required for AIFs. Only a “Yes” or “No” answer is required. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 73/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) Are sustainability risks integrated sustainabilityRisksConsi Only a “Yes” or “No” answer is into the investment decisions for this deredIndicator required. Is the information in accordance with art6InformationDisclose Only a “Yes” or “No” answer is Article 6 SFDR disclosed? dIndicator required. Confirm that the template(s) used templateCDRCopyIndic The answer is only required for AIFs. for the precontractual disclosures of ator financial product (Art. 6 SFDR)? (sub-)funds qualifying as Article 8 Product (“Product 8”) or Article 9 Only a “Yes” or “No” answer is required. Product (“Product 9”) under SFDR is a one-to-one copy of the template foreseen in annex II or III respectively of the CDR and has not been altered except eventually as regards the size and front type of characters or the colour used as permitted by Article 2 CDR SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 74/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) All sections of the template have templateAllSectionsCo been properly completed and those mpletedIndicator which are not applicable have been Does the information provided here latestPublishedInformat correspond to the latest published ionCorrespondenceIndic information ator Date of the latest issued precontractual template (version) The answer is only required for AIFs. Only a “Yes” or “No” answer is required. disclosed as such The answer is only required for AIFs. Only a “Yes” or “No” answer is required. templateLatestIssuedD The date in the format “YYYY-MM- ate DD” is required. For UCITS, the date of the prospectus is required. For AIFs, it might be the date of the prospectus/issuing document or the date of referred disclosure to Directive in to Article 2011/61/EU investors 23

(1)of to the investors . SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 75/81 the Information to be provided Technical attribute of CSSF guidance Reference the information to be precontractual template provided in the JSON file (cf. 4.1.2.2.1) For a prospectus disclosing “Month Name YYYY” on its cover page shall regard the format above and insert “YYYY-MM-01” (e.g. January 2023  2023-01-01). SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 to 76/81 the

(2)It should be noted that “Investments” constitute the 100 percent base and the different percentages of each box should be expressed in relation to that base. SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 77/81

(3)SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 78/81 Annex IV – Codes required in the report for closed questions Label Code for JSON file Yes Y No N Climate change mitigation CCM Climate change adaptation CCA The sustainable use and protection of water and marine UPWM resources The transition to a circular economy TCE Pollution prevention and control PPC The protection and restoration of biodiversity and PRBE ecosystems Reduction in carbon emissions RCE Social objective SO Best in class BIC Thematic THE ESG integration ESGI ESG engagement ESGE Impact investing II Exclusions E Other O Environmental - energy EEN Environmental - renewable energy EREN Environmental - raw materials ERMA Environmental - water and land EWL Environmental - waste EWAS Environmental - greenhouse gas emissions EGGE Environmental - biodiversity EBIO Environmental - circular economy ECECO SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 79/81 Label Code for JSON file Environmental - other EOTH Social - inequality SINEQ Social - social cohesion SSOCO Social - social integration SSOIN Social - labour relations SLARE Social - investment in human capital SIHC Social - economically or socially disadvantaged SESDC communities Social - other SOTH Turnover T Capital expenditure CAPEX Operational expenditure OPEX SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 80/81 Commission de Surveillance du Secteur Financier 283, route d’Arlon L-2991 Luxembourg (+352) 26 25 1-1 direction@cssf.lu www.cssf.lu SFDR UCI PRECONTRACTUAL DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE Version diffusée - Juin 2024 81/81