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

(1)of the 2013 Law; 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 (only when they qualify as ELTIFs) they manage; registered AIFMs, subject to Article 3

(3)of 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; IORPs, subject to the Law of 13 July 2005. The data collection exercise on periodic disclosure information is mandatory for all (sub-)funds of a UCITS/AIF/IORP disclosing under Article 8 or 9 of SFDR and subject to the scope as defined above. 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. On that basis, FMPs, for each financial product in the scope as defined above, are required to provide a set of information relating to disclosures in periodic reports, included in the annual reports issued as from 1 January 2023 and with a financial year-end on or after 30 September 2022, according to the following deadlines: For periodic reports issued, in accordance with the legal deadline to publish the annual report or to make it available to investors, between 1 January 2023 and 31 December 2023, information shall be provided to the CSSF by 31 January 2024 at the latest. For periodic reports issued as from 1 January 2024, information shall be provided to the CSSF, at the latest, one month after the legal deadline to publish the annual report or to make it available to investors. Accordingly, the aforementioned information shall be submitted to the CSSF, at the latest, 5 months after financial year-end for UCITS, respectively 7 months for AIFs and IORPs. 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. 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 are available under SFDR UCI periodic data collection – Practical and technical guidance. The SFDR data can be submitted to the CSSF via the following channels: 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 FMPs and, if needed, a testing of the reporting file submission before going into production. Please refer to the user guide for further details. 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 30 November

1. Further guidance on this solution will be provided in due course.
2. Additional information The current data collection exercise will be extended in the future to collect information contained in the PAI statements. Further details on timing and practical proceeding of this extended data collection will be communicated at a later stage. 30 June 2023 - Updated on 27 March 2024 SFDR UCI periodic data collection – Practical and technical guidance Technical document PDF (2.11Mb) Main topic: Sustainable finance Relevant for Alternative investment fund managers Investment companies in risk capital (SICARs) 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 periodic data collection Practical and technical guidance SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 1/65 SFDR UCI periodic data collection - Practical and technical guidance Contents
3. Glossary and objectives 1.1 Glossary 1.2 Context 1.3 Objectives
4. Scope 2.1 2.2 2.3 2.4 2.5 5 5 5 6 6 Who is in the scope of the data collection? 6 Which UCITS/AIF/IORP are covered by the data collection? 7 When does an IFM/IORP have to provide information? 8 Identification of a (sub-)fund of a UCITS/AIF/IORP subject to the data collection 8 Constituents and purpose of the SFDR data collection 9
5. Practical guidance 9 3.1 Information to be collected for (sub-)funds disclosing under Article 8 of SFDR 9 3.2 Information to be collected for (sub-)funds disclosing under Article 9 of SFDR 9
6. Technical guidance 9 4.1 S3 system reporting technical specifications 9 4.1.1 Reporting file 10 4.1.2 CSSF feedback file 13 4.1.3 Dedicated testing environment 16 4.2 Edesk online form 17 4.2.1 Authentication 17 4.2.2 Creation and submission of a report 17 4.2.3 Export in PDF format 18 4.2.4 Dashboard 18 4.2.5 Delegation 18 4.2.6 Correction or modification of the last accepted periodic data of a sub-fund at the exercise end date/closing date 19 4.2.7 View last accepted data 20
7. Contact information 20 Annex I – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 8 21 Annex II – Synopsis on information to be collected for sub-funds disclosing under SFDR Article 9 41 Annex III – Synopsis on information on top investments information to be collected for sub-funds disclosing under SFDR Article 8 or SFDR Article 9 60 Annex IV - Codes required in the report for closed questions 63 SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 2/65 SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 3/65 Update information Date Version Changes 27/06/2023 1.0 Publication of the document 30/11/2023 1.1 Removed paragraphs regarding transmission of reports via S
8. The method of transmitting reports via S3 is now referenced by a document available on the website. Online eDesk form for submitting reports (see point 4.2). “SFPER018” feedback message added for submission via S
9. 31/01/2024 1.2 Correction of the eDesk link (see chapter 4.2) 27/03/2024 1.3 Update of the section 2.2 SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 4/65
10. Glossary and objectives 1.1 Glossary Notion Definition CDR SFDR-RTS ESMA SB ESMA Supervisory briefing – Sustainability risks and disclosures in the area of investment management (31 May 2022, ESMA34-45-1427) 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 periodic Periodic templates set out in Annex IV respectively Annex V templates 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 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 Context The CSSF Communiqués published on 27 July 2022 and 24 March 2023 informed about the intention of the CSSF to launch a data collection exercise related to SFDR and TR. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 5/65 The present user guide concerns more particularly the data collection exercise relating to the disclosures in periodic reports for the financial products disclosing under Article 8 or Article 9 of SFDR. SFDR lays down harmonised rules on transparency regarding the provision of sustainabilityrelated information with respect to financial products. TR provides additional disclosure requirements for those financial products making sustainable investments with environmental objectives. Commission Delegated Regulation (EU) 2022/1288 supplementing SFDR as amended (SFDR RTS) provides further details on the transparency to be ensured by financial market participants (FMPs) in this respect. In this context, Investment Fund Managers (IFMs) and Institutions for Occupational Retirement Provision (IORPs) qualifying as FMPs are required to include sustainability-related information in the periodic reports of financial products disclosing under Article 8 or Article of SFDR. The purpose of the data collection exercise is to collect in a digital format on an annual basis, in accordance with the financial year-end of the financial products, information in relation to the disclosures in periodic reports. 1.3 Objectives The objective of this document is to provide practical and technical information on the SFDR Data collection exercise relating to the disclosures in periodic reports for financial products disclosing underArticle 8 or Article 9 of SFDR. The first part of the document aims at providing information to financial market participants on the scope of the data collection exercise and the CSSF expectations on the manner in which the data fields should 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 concerning in particular:
11. • Technical overview of the reporting system; • Data and file format of the reports; • Data validation and feedbacks. Scope 2.1 Who is in the scope of the data collection? The CSSF is requiring the following financial market participants (“FMPs”) to participate to this data collection exercise: SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 6/65 (a) UCITS management companies, based in Luxembourg and subject to Chapter 15 of the Law of 17 December 2010 relating to undertakings for collective investment (the “2010 Law”) or in another Member State of the European Union, in relation to all Luxembourgdomiciled UCITS they manage; (b) UCITS investment companies which did not designate a management company within the meaning of Article 27 of the 2010 Law; (c) authorised AIFMs, based in Luxembourg and subject to Article 4 of the Law of 12 July 2013 on alternative investment fund managers (the “2013 Law”), in relation to all Luxembourg-domiciled regulated and unregulated AIFs (including ELTIFs) they manage; (d) internally managed alternative investment funds within the meaning of point (b) of article 4

(1)of the 2013 Law; (

1. e)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 (only when they qualify as ELTIFs) they manage; (
2. f)registered AIFMs, subject to Article 3

(3)of 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; (g) IORPs, subject to the Law of 13 July 2005. The data collection exercise on periodic disclosure information is mandatory for all (sub-)funds of a UCITS/AIF/IORP disclosing under Article 8 or Article 9 of SFDR and subject to the scope as defined above. 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. 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. 2.2 Which UCITS/AIF/IORP are covered by the data collection? The data collection is mandatory for all (sub-)funds of a UCITS/AIF/IORP disclosing under Article 8 or Article 9 of SFDR at year-end or period-end and subject to the scope as defined under 2.1 above. For (sub)-funds requalified from Article 8 or Article 9 of SFDR to Article 6 SFDR during the year/period, no data collection regarding “periodic disclosure” is required for the year/period. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 7/65 The term “Period-end” applies when the period does not correspond to 12 months (i.e. latest period before the liquidation or the merger of a (sub-)fund). For (sub-)funds that had no investment during the entire reporting period, the data collection is not applicable either. 2.3 When does an IFM/IORP have to provide information? FMPs, for each financial product in the scope as defined above, are required to provide a set of information relating to disclosures in periodic reports, included in the annual reports issued as from 1 January 2023 and with a financial year-end on or after 30 September 2022, according to the following deadlines: - For periodic reports issued, in accordance with the legal deadline to publish the annual report or to make it available to investors, between 1 January 2023 and 31 December 2023, information shall be provided to the CSSF by 31 January 2024 at the latest. - For periodic reports issued as from 1 January 2024, information shall be provided to the CSSF, at the latest, one month after the legal deadline to publish the annual report or to make it available to investors. Accordingly, the aforementioned information shall be submitted to the CSSF, at the latest, 5 months after financial year-end for UCITS, respectively 7 months for AIFs and IORPs. 2.4 Identification of a (sub-)fund of a UCITS/AIF/IORP subject to the data collection The (sub-)funds of a UCITS/AIF/IORP 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. The CSSF identification number for (
3. i)a non-regulated entity being an ELTIF managed by an authorised AIFM based in another Member State of the European Union or (
4. ii)an IORP cannot be obtained via a dedicated list available on the CSSF website. As a result, an IFM or IORP should contact the CSSF directly in case of issues in obtaining this information. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 8/65 2.5 Constituents and purpose of the SFDR data collection The SFDR data collection consists of mostly quantitative or binary questions that are based on the SFDR periodic templates and depend on the SFDR Article under which the (sub-)fund is disclosing. The aim of this data collection exercise is to collect in a digital format on an annual basis, in accordance with the financial year-end of the financial products, information contained in the periodic templates. The information must be provided for: i. Sub-funds disclosing under SFDR Article 8; ii. Sub-funds disclosing under SFDR Article 9. The data collection relates to the environmental and/or social characteristics of the sub-funds. 3. Practical guidance 3.1 Information to be collected for (sub-)funds disclosing under Article 8 of SFDR Please refer to Annex I and Annex III. 3.2 Information to be collected for (sub-)funds disclosing under Article 9 of SFDR Please refer to Annex II and Annex III. 4. Technical guidance The SFDR PAI for IFMs 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 Method of transmitting reports via Application Programming Interface can be found on our website following the link. On the edesk IT management console, the “IT Expert” must create a bucket “SFDR – periodical disclosures”. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 9/65 4.1.1 Reporting file 4.1.1.1 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 subfunds of that UCI/IORP. Reported data for each sub-fund depend on its regime under SFDR (Article 8 or Article 9) and are described in the JSON schema. 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 periodic document (mandatory only for LU non-regulated funds). The schema concerning the data of the periodic document is available at: Periodic document JSON schema 4.1.1.2 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). 4.1.1.3 ZIP technical specifications Reporting file must be transmitted via a compressed .zip format containing one single .json file and optional .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 The responsibility of the bucket is to grant access to our system. It is not intended for long term storage. Regular cleaning might be performed by the CSSF. 4.1.1.4 4.1.1.4.1 Naming conventions ZIP file The mandatory file naming convention for .zip files is specified below. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 10/65 Format: SFDR-ENNNNNNNN-TTTTT-YYYY-MM-DD-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) NNNN Identification NNNN number - Separator Char

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

(5)PERIO for periodic data - Separator Char

(1)‘-’ (constant) YYYY- Exercise Date Exercise end date corresponding to the MM- date Number

(8)00000001…99999999 (CSSF code of the entity) end reported data. DD If the fund ceased its activity during the period, the end of activity date must be indicated instead of the exercise end date. UUID Unique identifier UUID format norm (ReportUid) .ext Extension Unique identifier following the rfc 4122 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 processed 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 SFPER007 (cf. chapter 4.1.2.2.3). 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) SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 11/65 4.1.1.4.2 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. 4.1.1.4.3 PDF file The following naming convention apply for PDF files you may add to your report (mandatory only for LU non regulated funds). Format: SFDR-CCCCCCCC-TTTTT-YYYY-MM-DD.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)PERIO for periodic data YYYY- Exercise end date Date Exercise MM-DD end corresponding date to the reported data. If the fund ceased its activity during the period, the end of activity date indicated instead must of be the exercise end date. .ext Extension Char

(5).pdf (constant) Example: Archive SFDR-O0000xxxx-PERIO-2023-03-31-41c13c08-ef59-4183870f-80d7a00c54e8.zip SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 12/65 JSON report report.json SFDR-00000001-PERIO-2023-03-31.pdf PDF file 4.1.2 SFDR-00000002-PERIO-2023-03-31.pdf CSSF feedback file It is up to the submitter to monitor transmission correctness. 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 at: Publication date Version Link Release note 27/06/2023 1.0.0 schema Initial version 30/11/2023 2.0.0 schema Feedback message "SFPER018" added Please ensure that you have received a feedback file for the last file sent before submitting a new file concerning a same sub-fund for a specific period. 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. 4.1.2.1 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 4.1.1 _ 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 SFPERYYYYMMDDXXXXX SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 13/65 where: YYYYMMDD: year, month and day of submission XXXXX: daily increment _ Separator Char

(1)‘_’ (constant) .ext Extension Char

(5).json (constant) 4.1.2.2 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. 4.1.2.2.1 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 subfund 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. 4.1.2.2.2 ReportUids recently processed The report can be submitted to the CSSF for a specific exercise period: • 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. This means that different data for a same sub-fund could be received in separate reports, for a same exercise period. 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). SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 14/65 4.1.2.2.3 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 “SFPER000” 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 SFPER000 The report of the sub-fund has been accepted by Sub- INFO the CSSF fund SFPER001 The archive is corrupted Report ERROR SFPER002 The archive name is invalid. The expected naming Report ERROR convention must follow the regex: SFDR- (?<entityCssfCode>[OKVF]\\d{8})(?<reportType>PERIO)-(?<exerciseEndDate>[19][0-9][0-9]{2}-([0][1-9]|[1][0-2])-([1-2][09]|[0][1-9]|[3][0-1]))-(?<reportUid>[0-9af]{8}-[0-9a-f]{4}-[0-9a-f]{4}-[0-9a-f]{4}-[09a-f]{12}).zip SFPER003 The archive size cannot exceed 20 MB Report ERROR SFPER004 The submitter is not authorised to transmit the Report ERROR Report ERROR Report ERROR Report ERROR archive for this entity, at the reported period SFPER005 The entity defined in the archive name is not in scope for the reported period SFPER006 The exercise end date of the entity defined in the archive name is not correct. It doesn't correspond to the expected exercise end date or to the closing date of the fund in case of cessation of activity. SFPER007 The archive with reportUid "reportUid" has already been received for this entity SFPER008 The archive must contain a single JSON file Report ERROR SFPER009 JSON file does not respect JSON Schema Report ERROR SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 15/65 SFPER010 The unique identifier "reportUid" in the JSON file Report ERROR Report ERROR Report ERROR The sub-fund is not in the scope for the reported Sub- ERROR period fund The sub-fund is referenced multiple times Sub- is different from the unique identifier used in the archive name SFPER011 The CSSF code of the entity in the JSON file is different from the CSSF code of the entity used in the archive name SFPER012 The exercise end date of the entity in the JSON file is different from the exercise end date of the entity used in the archive name SFPER013 SFPER014 ERROR fund SFPER015 SFPER016 SFPER017 SFPER018 4.1.3 The field "fieldname" is required by condition Sub- “fieldname:value” fund At least one largest investment is required for the Sub- sub-fund fund The PDF file of the sub-fund at the reported period Sub- is required fund At least one largest investment is defined for a Sub- subfund that is neither Article 8 nor Article 9 fund ERROR ERROR ERROR ERROR 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. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 16/65 4.2 Edesk online form An online form is available on the eDesk platform via the SFDR - Periodic funds/IORPs disclosures module (https://edesk.apps.cssf.lu/sfper/edesk-sfper/home ). 4.2.1 Authentication The person in charge of submitting the periodical 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. 4.2.2 Creation and submission of a report The report of new SFDR data concerning a fund/IORP is possible via the “Create report” button available on the dashboard homepage. The user then chooses the type of report: periodic report (at exercise end date) or closing report (at closing date). The list of funds/IORPs is displayed according to the scope and the entity to which the user is linked (see chapter 2.1). Finally, the user selects the exercise end date/closing date concerned. Fill-in of the requested information for a specific sub-fund of the selected fund is done by adding it in the corresponding table (Article 8 sub-funds or Article 9 sub-funds and Largest investments of article 8 and article 9 sub-funds) in the “SFDR Periodic 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) The periodic disclosure templates must be provided under the “Upload of the periodic disclosure templates” section only for: • Luxembourg-domiciled unregulated AIFs managed by authorised AIFM, based in Luxembourg and subject to Article 4 of the Law of 12 July 2013 on alternative investment fund managers (the “2013 Law”). • Luxembourg-domiciled unregulated AIFs (only when they qualify as ELTIFs) managed by authorised AIFMs, based in another Member State of the European Union. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 17/65 A report can be submitted via the “Submit” button available in the “Submission of the report” section. The eDesk form guarantees that a report meets all the applicable validation rules (essentially those with a sub-fund level in chapter 4.1.2.2.3). 4.2.3 Export in PDF format It is possible to export in PDF format the data of a specific report that was created, whether it has been submitted or not. 4.2.4 Dashboard A dashboard lists all the reports initiated by an authenticated user linked to the entity. The report might be incomplete (and not submitted), complete but not yet submitted and complete and submitted. It is possible to see the details of a report via the dashboard and modify or delete those not yet submitted. 4.2.5 Delegation Please note that the creation and submission of the report 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(s) already created. Things to know about 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), • 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, SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 18/65 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 delegation, o the “trash bin” icon will cancel the delegation (available in any status o the “resend” icon will send a new email to the delegate (only for the except “Canceled”), 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 report(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 report. 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. 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 periodic data of a sub-fund at the exercise end date/closing date When creating a new report, you can correct the periodic data of a sub-fund based on the data already transmitted to the CSSF in a previous report. When you add a sub-fund in one of the tables (Article 8 sub-funds or Article 9 subfunds), the data previously submitted to the CSSF are automatically loaded into the form. You can then modify the data. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 19/65 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. 5. Contact information In case of questions, please contact ucisfdr@cssf.lu. To facilitate the processing of your request, please precise the following information: • 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 (periodic). SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 20/65 Annex I – 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 the of the information to periodic disclosure be provided in the template JSON file (cf. 4.1.2.2.1) CSSF code of the sub-fund to 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. Has the sub-fund been liquidated during the subfundLiquidatedIndi Only a “Yes” or “No” answer is required. year? cator If yes, indicate the date of the start of the subfundStartDateLiqui Only if the answer to the question liquidation period. dationPeriod “subfundLiquidatedIndicator” SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 21/65 Information to be provided Technical attribute CSSF guidance Reference to the of the information to periodic disclosure be provided in the template JSON file (cf. 4.1.2.2.1) is “Yes”, indicate the starting date of the liquidation. The subfund promoted Environmental/Social sustainableInvestment characteristics and while it did not have as its sIndicator Only a “Yes” or “No” answer is required. Questions from derived the graphical objective a sustainable investment, it made representation of the sustainable investments question Proportion (in %) of sustainable investments sustainableInvestment Only if the answer to the question sProportion1 “sustainableInvestmentsIndicator” the proportion during the period is required With an environmental objective in economic environmentalObjectiv Only if the answer to the question activities eTaxonomyIndicator “sustainableInvestmentsIndicator” is “Yes”, is qualify as environmentally a “Yes” or “No” answer required. With an environmental objective in economic environmentalObjectiv Only if the answer to the question activities eNoTaxonomyIndicato “sustainableInvestmentsIndicator” that do not qualify as financial product have a r SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 22/65 sustainable objective?” Cf.

(1)below the table If No, no information is required. that this investment is “Yes”, a positive percentage reflecting sustainable under the EU Taxonomy “Did is Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) environmentally sustainable under the EU “Yes”, Taxonomy required. a “Yes” or “No” answer is socialObjectiveIndicat Only if the answer to the question or “sustainableInvestmentsIndicator” is “Yes”, is a “Yes” or “No” answer required. What are the environmental and/or social the of the information to JSON With a social objective to eAndSCharacteristics characteristics promoted that the subfund met? Please select the appropriate characteristics from the below list. Please note that multiple selections are possible: • Environmental – energy; • Environmental – renewable energy; • Environmental – raw materials; • Environmental – water and land; • Environmental – waste; • Environmental • Environmental – biodiversity; • Environmental – circular economy; – greenhouse gas emissions; SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 23/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) • Environmental – other; • Social – inequality; • Social – social cohesion; • Social – social integration: • Social – labour relations: • Social – investment in human capital; • Social • Social – other. – economically or socially disadvantaged communities; specify other environmental characteristics otherEnvironmentalCh Only if “Environmental aracteristicsDescriptio selected 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 the of the information to JSON Please to 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). SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 24/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) good investee governance practices companies considered of the goodGovernancePracti for cesIndicator Only a “Yes” or “No” answer is required. investments aligned to environmental and/or social characteristics respectively investments with a sustainable objective? If no, please explain the of the information to JSON Were to noGoodGovernancePra Only if the answer to the question cticesDescription “goodGovernancePracticesIndicator” is “No”, please provide a short explanation (in English and ideally not exceeding 100 characters). What were the objectives of the sustainable sustainableInvestment The below list contains the objectives of investments that the sub-fund partially made? sObjectives Article 9 TR as well as “Social objective”. 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 PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 25/65 Information to be provided Technical attribute CSSF guidance Reference to the of the information to periodic disclosure 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; • Did the subfund consider principle adverse principalAdversImpact impacts on sustainability factors? ConsiderationIndicator Proportion of investments aligned Social objective. Only a “Yes” or “No” answer is required. with alignedESCharacteristi A positive percentage reflecting the Questions environmental or social characteristics (in %) csInvestmentsProporti proportion during the period is required. from derived graphical representation of the on Proportion of sustainable investments (in %) the sustainableInvestment If the answer to the question sProportion2 “sustainableInvestmentsIndicator” is “Yes”, a positive percentage reflecting the proportion during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 26/65 question “What was the proportion of sustainability-related investments?” Information to be provided Technical attribute CSSF guidance Reference to the of the information to periodic disclosure be provided in the template JSON file (cf. 4.1.2.2.1) If the answer to the question “sustainableInvestmentsIndicator” is “No”, no value is required. Proportion of Taxonomy-aligned (in %) taInvestmentsProporti on If the answer to the table. It should be noted question that the box environmentalObjectiveTaxonomyIndica “Investments” tor is “Yes”, a positive percentage constitutes the 100% reflecting the proportion during the base and the different period is required. percentages of each If the answer to the question environmentalObjectiveTaxonomyIndica tor is “No”, no value is required. Proportion of Other environmental (in %) Cf.

(2)below the otherEnvironmentalPr If oportion environmentalObjectiveNoTaxonomyInd the answer to the question icator is “Yes”, a positive percentage reflecting the proportion during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 27/65 box should be expressed in relation to that base. Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) If the answer to the question environmentalObjectiveNoTaxonomyInd icator is “No”, no value is required. socialProportion If the answer to socialObjectiveIndicator positive percentage the question is “Yes”, reflecting a the proportion during the period is required. If to the socialObjectiveIndicator the answer is question “No”, no value is required. Proportion of investments aligned the of the information to JSON Proportion of Social (in %) to with otherESCharacteristics The percentage should be the difference environmental or social characteristics that do InvestmentsProportion of the percentages provided in response not qualify as sustainable investments (in %) to questions alignedESCharacteristicsInvestmentsPro portion and sustainableInvestmentsProportion2. Proportion of remaining investments which are remainingInvestments The percentage should be the difference neither aligned with the environmental or Proportion between the percentage of total social characteristics, nor are qualified as investments (100%) and the percentage sustainable investments (in %) provided in response to the question SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 28/65 Information to be provided Technical attribute CSSF guidance Reference to the of the information to periodic disclosure be provided in the template JSON file (cf. 4.1.2.2.1) alignedESCharacteristicsInvestmentsPro portion. Did the sub-fund invest in fossil gas related fossilGasInvestmentsI If the answer to the question Questions referring to activities complying with the EU Taxonomy? ndicator environmentalObjectiveTaxonomyIndica the taxonomy aligned tor is “Yes”, only a “Yes” or “No” answer investments. is required. Did the sub-fund invest in nuclear energy nuclearEnergyInvestm If related entsIndicator environmentalObjectiveTaxonomyIndica activities complying with the EU Taxonomy? the Cf.

(3)below the answer to the question tor is “Yes”, only a “Yes” or “No” answer is required. Taxonomy aligned investments in fossil gas related activities including sovereign bonds expressed as a share of turnover (in %) fossilGasInvestmentsIn clSovereignBondsTurn overProportion If the answer to the question fossilGasInvestmentsIndicator is “Yes”, a positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 29/65 table. Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) Taxonomy aligned investments in nuclear nuclearEnregyInvestm If energy related activities including sovereign entsInclSovereignBon nuclearEnergyInvestmentsIndicator bonds expressed as a share of turnover (in %) dsTurnoverProportion the answer to the question is “Yes”, a positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. fossil gas activities) and investments (excluding remainingInvestments If energy related InclSovereignBondsTu environmentalObjectiveTaxonomyIndica sovereign bonds rnoverProportion tor is “Yes”, a positive percentage nuclear including the of the information to JSON Taxonomy aligned to expressed as a share of turnover (in %) the answer to the question reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in fossil gas fossilGasInvestmentsI If related activities including sovereign bonds nclSovereignBondsCap fossilGasInvestmentsIndicator is “Yes”, the answer to the question expressed as a share of CapEx (in %) exProportion a positive percentage reflecting the proportion during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 30/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. Taxonomy aligned investments in nuclear nuclearEnregyInvestm If energy related activities including sovereign entsInclSovereignBon nuclearEnergyInvestmentsIndicator bonds expressed as a share of CapEx (in %) dsCapexProportion the answer to the question is “Yes”, a positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. fossil gas activities) and investments (excluding nuclear including the of the information to JSON Taxonomy aligned to remainingInvestments If the answer to the question energy related InclSovereignBondsCa environmentalObjectiveTaxonomyIndica sovereign bonds pexProportion tor is “Yes”, a positive percentage expressed as a share of CapEx (in %) reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in fossil gas fossilGasInvestmentsI If the answer to related activities including sovereign bonds nclSovereignBondsOpe fossilGasInvestmentsIndicator is “Yes”, expressed as a share of OpEx (in %) xProportion SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 31/65 the question Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) a positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclear nuclearEnergyInvestm If energy related activities including sovereign entsInclSovereignBon nuclearEnergyInvestmentsIndicator bonds expressed as a share of OpEx (in %) dsOpexProportion “Yes”, a positive percentage reflecting the answer to the question is the actual proportion is required. If the answer is “No”, no value is required. fossil gas activities) and investments (excluding nuclear including the of the information to JSON Taxonomy aligned to remainingInvestments If the answer to the question energy related InclSovereignBondsOp environmentalObjectiveTaxonomyIndica sovereign bonds exProportion tor is “Yes”, a positive percentage expressed as a share of OpEx (in %) reflecting the actual proportion is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 32/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) Taxonomy aligned investments in fossil gas fossilGasInvestmentsE If related activities excluding sovereign bonds xclSovereignBondsTur fossilGasInvestmentsIndicator is “Yes”, expressed as a share of turnover (in %) noverProportion a positive percentage reflecting the the answer to the question proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclear nuclearEnergyInvestm If energy related activities excluding sovereign entsExclSovereignBon nuclearEnergyInvestmentsIndicator bonds expressed as a share of turnover (in %) dsTurnoverProportion “Yes”, a positive percentage reflecting the answer to the question is the actual proportion is required. If the answer is “No”, no value is required. fossil gas activities) and investments (excluding nuclear excluding the of the information to JSON Taxonomy aligned to remainingInvestments If the answer to the question energy related ExclSovereignBondsTu environmentalObjectiveTaxonomyIndica sovereign bonds rnoverProportion tor is “Yes”, a positive percentage expressed as a share of turnover (in %) reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 33/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) Taxonomy aligned investments in fossil gas fossilGasInvestmentsE expressed as a share of CapEx (in %) If the answer to the question xclSovereignBondsCap fossilGasInvestmentsIndicator is “Yes”, exProportion a positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclear nuclearEnergyInvestm If energy related activities excluding sovereign entsExclSovereignBon nuclearEnergyInvestmentsIndicator bonds expressed as a share of CapEx (in %) dsCapexProportion “Yes”, a positive percentage reflecting the answer to the question is the actual proportion is required. If the answer is “No”, no value is required. Taxonomy aligned fossil gas activities) and investments (excluding nuclear excluding the of the information to JSON related activities excluding sovereign bonds to remainingInvestments If the answer to the question energy related ExclSovereignBondsCa environmentalObjectiveTaxonomyIndica sovereign bonds pexProportion tor is “Yes”, a positive percentage expressed as a share of CapEx (in %) reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 34/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) related activities excluding sovereign bonds expressed as a share of OpEx (in %) fossilGasInvestmentsE xclSovereignBondsOpe xProportion If the answer to the question fossilGasInvestmentsIndicator is “Yes”, a positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclear nuclearEnergyInvestm If energy related activities excluding sovereign entsExclSovereignBon nuclearEnergyInvestmentsIndicator bonds expressed as a share of OpEx (in %) dsOpexProportion “Yes”, a positive percentage reflecting the answer to the question is the actual proportion is required. If the answer is “No”, no value is required. Taxonomy aligned fossil gas activities) and investments (excluding nuclear excluding the of the information to JSON Taxonomy aligned investments in fossil gas to remainingInvestments If the answer to the question energy related ExclSovereignBondsOp environmentalObjectiveTaxonomyIndica sovereign bonds exProportion tor is “Yes”, a positive percentage expressed as a share of OpEx (in %) reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 35/65 Information to be provided Technical attribute CSSF guidance Reference to the of the information to periodic disclosure be provided in the template JSON file (cf. 4.1.2.2.1) What was the share of investments made in transitionalActivitiesIn If transitional activities (in %)? vestmentsShare environmentalObjectiveTaxonomyIndica the answer to the question tor is “Yes”, a positive percentage reflecting the actual proportion is required. If the answer is “No”, no value is required. What was the share of investments made in enablingActivitiesInves If enabling activities (in %)? tmentsShare environmentalObjectiveTaxonomyIndica the answer to the question tor is “Yes”, a positive percentage reflecting the actual proportion is required. If the answer is “No”, no value is required. Has a specific index been designated as a referenceBenchmarkD reference benchmark for the purpose of esignatedIndicator Only a “Yes” or “No” answer is required. Question referring to question “How did attaining the environmental and/or social this financial product characteristics promoted by the subfund? perform compared to the reference benchmark ?”. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 36/65 Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template 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. 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 the of the information to JSON Specify the to 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 PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 37/65 None Information to be provided Technical attribute CSSF guidance Reference periodic disclosure be provided in the template file (cf. 4.1.2.2.1) performance of the subfund compared to the reference benchmark (in %) the of the information to JSON Out/under to performanceCompared If ReferenceBenchmark referenceBenchmarkDesignatedIndicato the answer to the question r is “Yes”, the percentage should be the difference between the performance of the subfund and the performance of the reference benchmark. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 38/65

(2)SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 39/65 It should be noted that “Investments” constitute the 100% base and the different percentages of each box should be expressed in relation to that base.

(3)SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 40/65 Annex II – 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 file (cf. 4.1.2.2.1) subfundCssfCode the disclosure template provided in the JSON CSSF code of the sub-fund to 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. Has the sub-fund been liquidated subfundLiquidatedIndic Only a “Yes” or “No” answer is during the year? ator required. If yes, indicate the date of the start subfundStartDateLiquid Only if the answer to the question of the liquidation period ationPeriod “subfundLiquidatedIndicator” SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 41/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be to the periodic disclosure template provided in the JSON file (cf. 4.1.2.2.1) is “Yes”, indicate the starting date of the liquidation. The subfund made sustainable investments with an environmental sustainableInvestments Only a “Yes” or “No” answer is Questions Indicator required. graphical representation of the objective Proportion of sustainable sustainableInvestments If the answer investments with an environmental EnvironmentalProportio “sustainableInvestmentsIndicator” objective n1 is “Yes”, a to the positive question percentage reflecting the proportion during the period is required. 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. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 42/65 derived question “Did this product have a from the financial sustainable investment objective?” Cf.

(1)below the table. Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) 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 required. The sub-fund made sustainable socialObjectiveIndicator investments with a social objective Proportion of sustainable investments with a social objective Only a “Yes” or “No” answer is required. sustainableInvestments If the answer to the question SocialProportion1 “socialObjectiveIndicator” is “Yes”, a positive percentage reflecting the minimum commitment is required. Were good governance practices of goodGovernancePractic Only a “Yes” or “No” answer is the investee companies considered esIndicator required. for investments with the disclosure template provided in the JSON sustainable under the EU Taxonomy to sustainable objectives? SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 43/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) noGoodGovernancePrac Only if the answer to the question ticesDescription goodGovernancePracticesIndicator is “No”, please provide a short explanation (in English and ideally not exceeding 100 characters). What were the objectives of the sustainable investments that subfund made? the sustainableInvestments Objectives the disclosure template provided in the JSON If no, please explain to The below list contains the objectives of Article 9 TR as well as “Social objective”. Please note that multiple selections are possible: • Climate change mitigation ; • Climate change adaptation ; • The sustainable use and protection of water and marine resources; • Transition to a circular economy; • Pollution prevention and control; • The protection and restoration of biodiversity and ecosystems; • Reduction in carbon emissions; SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 44/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be to the periodic disclosure template provided in the JSON file (cf. 4.1.2.2.1) • Social objective. Did the subfund consider principle principalAdverseImpact Only a “Yes” or “No” answer is adverse impacts on sustainability ConsiderationIndicator required. sustainableInvestments If EnvironmentalProportio sustainableInvestmentsIndicator n2 “Yes”, factors? Proportion of sustainable environmental investments (in %) the answer a to positive the question is percentage Questions derived from the graphical representation of the question “What was reflecting the proportion during the proportion of period is required. related investments?” the sustainability- Cf.

(2)below the table. the answer sustainableInvestments If %) EnvironmentalTaProport environmentalObjectiveTaxonomyIn “Investments” ion dicator 100% is to “Yes”, the a question It should be noted that the box Proportion of Taxonomy-aligned (in positive base constitutes and the the different percentage reflecting the proportion percentages of each box should be during the period is required. expressed in relation to that base. If the answer to the question environmentalObjectiveTaxonomyIn dicator is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 45/65 Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) sustainableInvestments If the answer EnvironmentalOtherPro environmentalObjectiveNoTaxonom portion yIndicator is to the “Yes”, a question positive percentage reflecting the proportion during the period is required. If the answer to the question environmentalObjectiveNoTaxonom yIndicator is “No”, no value is required. Proportion of sustainable investments (in %) social the disclosure template provided in the JSON Proportion of Other (in %) to sustainableInvestments If the answer to the question SocialProportion2 socialObjectiveIndicator is “Yes”, a positive percentage reflecting the proportion during the period is required. If the answer to the question socialObjectiveIndicator is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 46/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be to the periodic disclosure template provided in the JSON file (cf. 4.1.2.2.1) Proportion of not sustainable investments (in%) notSustainableInvestm The percentage should be the entsProportion difference between the percentage of total investments (100%) and the percentage of sustainable investments. Did the sub-fund invest in fossil gas fossilGasInvestmentsIn If related activities complying with the dicator environmentalObjectiveTaxonomyIn EU Taxonomy? the answer to the question dicator is “Yes”, only a “Yes” or “No” answer is required. Did the subfund 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. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 47/65 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 file (cf. 4.1.2.2.1) Taxonomy aligned investments in fossilGasInvestmentsIn If fossil gas related activities including clSovereignBondsTurno fossilGasInvestmentsIndicator sovereign bonds expressed as a verProportion “Yes”, the answer a to the positive question is percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclearEnergyInvestme If nuclear ntsInclSovereignBondsT nuclearEnergyInvestmentsIndicator urnoverProportion is energy related activities including sovereign bonds expressed as a share of turnover (in %) the answer “Yes”, a to the positive question percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned the disclosure template provided in the JSON share of turnover (in %) to investments remainingInvestmentsI If the answer (excluding fossil gas and nuclear nclSovereignBondsTurn environmentalObjectiveTaxonomyIn energy related activities) including overProportion dicator is to “Yes”, the a question positive sovereign bonds expressed as a percentage reflecting the proportion share of turnover (in %) during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 48/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. Taxonomy aligned investments in fossilGasInvestmentsIn If fossil gas related activities including clSovereignBondsCapex fossilGasInvestmentsIndicator sovereign bonds expressed as a Proportion “Yes”, the answer a to the positive question is percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclearEnergyInvestme If nuclear ntsInclSovereignBonds nuclearEnergyInvestmentsIndicator CapexProportion is energy related activities including sovereign bonds expressed as a share of CapEx (in %) the disclosure template provided in the JSON share of CapEx (in %) to the answer “Yes”, a to the positive question percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 49/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) aligned investments remainingInvestmentsI If (excluding fossil gas and nuclear nclSovereignBondsCape environmentalObjectiveTaxonomyIn xProportion dicator energy related activities) including the answer is to the “Yes”, a question positive percentage reflecting the proportion sovereign bonds expressed as a during the period is required. share of CapEx (in %) If the answer is “No”, no value is required. Taxonomy aligned investments in fossilGasInvestmentsIn If fossil gas related activities including clSovereignBondsOpexP fossilGasInvestmentsIndicator sovereign bonds expressed as a roportion “Yes”, share of OpEx (in %) the answer a to the positive question is percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclearEnergyInvestme If nuclear ntsInclSovereignBonds nuclearEnergyInvestmentsIndicator OpexProportion is energy related activities including sovereign bonds expressed as a share of OpEx (in %) the disclosure template provided in the JSON Taxonomy to the answer “Yes”, a to the positive question percentage reflecting the proportion during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 50/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. aligned investments remainingInvestmentsI If (excluding fossil gas and nuclear nclSovereignBondsOpex environmentalObjectiveTaxonomyIn energy related activities) including Proportion dicator the answer is to “Yes”, the a question positive sovereign bonds expressed as a percentage reflecting the proportion share of OpEx (in %) during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in fossilGasInvestmentsEx If fossil gas related activities excluding clSovereignBondsTurno fossilGasInvestmentsIndicator sovereign bonds expressed as a verProportion “Yes”, share of turnover (in %) the disclosure template provided in the JSON Taxonomy to the answer a to positive the question is percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 51/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) Taxonomy aligned investments in nuclearEnergyInvestme If nuclear ntsExclSovereignBonds nuclearEnergyInvestmentsIndicator TurnoverProportion is energy related activities sovereign bonds the answer “Yes”, a to the positive question percentage expressed as a share of turnover (in reflecting the proportion during the %) period is required. If the answer is “No”, no value is required. Taxonomy aligned investments remainingInvestmentsE If (excluding fossil gas and nuclear xclSovereignBondsTurn environmentalObjectiveTaxonomyIn energy related activities) excluding overProportion dicator the answer is to “Yes”, the a question positive sovereign bonds expressed as a percentage reflecting the proportion share of turnover (in %) during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in fossilGasInvestmentsEx If fossil gas related activities excluding clSovereignBondsCapex fossilGasInvestmentsIndicator sovereign bonds expressed as a Proportion “Yes”, share of CapEx (in %) the disclosure template provided in the JSON excluding to the answer a to positive the question is percentage reflecting the proportion during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 52/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. nuclearEnergyInvestme If ntsExclSovereignBonds nuclearEnergyInvestmentsIndicator the answer CapexProportion is “Yes”, a to the positive question percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments (excluding fossil gas and nuclear energy related activities) excluding sovereign bonds expressed as a share of CapEx (in %) the disclosure template provided in the JSON Taxonomy aligned investments in nuclear energy related activities excluding sovereign bonds expressed as a share of CapEx (in %) to remainingInvestmentsE If xclSovereignBondsCape environmentalObjectiveTaxonomyIn the answer xProportion dicator is to “Yes”, the a question positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 53/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) fossilGasInvestmentsEx If the answer clSovereignBondsOpexP fossilGasInvestmentsIndicator roportion “Yes”, a to the positive question is percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments in nuclear energy related activities excluding sovereign bonds expressed as a share of OpEx (in %) nuclearEnergyInvestme If the answer ntsExclSovereignBonds nuclearEnergyInvestmentsIndicator OpexProportion is “Yes”, a to the positive question percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. Taxonomy aligned investments (excluding fossil gas and nuclear energy related activities) excluding sovereign bonds expressed as a share of OpEx (in %) the disclosure template provided in the JSON Taxonomy aligned investments in fossil gas related activities excluding sovereign bonds expressed as a share of OpEx (in %) to remainingInvestmentsE If the answer xclSovereignBondsOpex environmentalObjectiveTaxonomyIn Proportion dicator is to “Yes”, the a question positive percentage reflecting the proportion during the period is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 54/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be the disclosure template provided in the JSON file (cf. 4.1.2.2.1) If the answer is “No”, no value is required. What was the share of investments transitionalActivitiesInv If made in transitional activities (in estmentsShare environmentalObjectiveTaxonomyIn the answer dicator %)? to is to “Yes”, the a question positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. What was the share of investments enablingActivitiesInvest If made in enabling activities (in %)? mentsShare environmentalObjectiveTaxonomyIn the answer dicator is to “Yes”, the a question positive percentage reflecting the proportion during the period is required. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 55/65 periodic Information to be provided Technical attribute of CSSF guidance Reference the information to be to the periodic disclosure template provided in the JSON file (cf. 4.1.2.2.1) Has a specific index been designated as a reference benchmark for the purpose of attaining the environmental and/or social characteristics promoted by the subfund? referenceBenchmarkDe signatedIndicator Only a “Yes” or “No” answer is Question required. “How did this financial product Is an ISIN code available for the referenceBenchmarkIsi If reference benchmark? nCodeIndicator referenceBenchmarkDesignatedIndi perform the answer to the question answer is required. If the answer is “No”, no value is required. the ISIN reference benchmark code of the to compared reference benchmark ?”. cator is “Yes”, only a “Yes” or “No” Specify referring referenceBenchmarkIsi If the answer to the question nCode referenceBenchmarkDesignatedIndi cator is “Yes”, provide the ISIN code of the benchmark. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 56/65 question to the Information to be provided Technical attribute of CSSF guidance Reference the information to be file (cf. 4.1.2.2.1) Specify the name of the reference referenceBenchmarkNa If benchmark me referenceBenchmarkIsinCodeIndicat the answer to the question or is “No”, provide the name of the benchmark. If the answer is “Yes”, no value is required. performance of the subfund compared to the reference benchmark (in %): the disclosure template provided in the JSON Out/under to performanceCompared If ReferenceBenchmark referenceBenchmarkDesignatedIndi the answer to the question cator is “Yes”, the percentage should be the difference between the performance of the subfund and the performance of the reference benchmark. If the answer is “No”, no value is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 57/65 periodic

(2)It should be noted that “Investments” constitute the 100% base and the different percentages of each box should be expressed in relation to that base. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 58/65

(3)SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 59/65 Annex III – Synopsis on information on top investments information to be collected for sub-funds disclosing under SFDR Article 8 or 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). The below table shall be completed for each of the fifteen investments constituting the largest proportion of investments of the sub-fund during the period covered by the periodic report. By way of derogation from above paragraph, where the number of investments constituting fifty percent of the investments of the financial product during the period covered by the periodic report is less than fifteen, the below table shall be completed for those investments only. Information to be provided Technical attribute of CSSF guidance Reference the information to be to the periodic disclosure 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 Question referring to question: to identify the CSSF code. “What were the top investments 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 PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 60/65 of this financial product?” Cf

(1)below the table. Information to be provided Technical attribute of CSSF guidance Reference the information to be disclosure template provided in the JSON file (cf.4.1.2.2.1) ISIN code available? Largest investments ISIN code largestInvestmentISINC Only a “Yes” odeIndicator required. largestInvestmentISINC If ode largestInvestmentISINCodeIndicator the or “No” answer to the answer is question is “Yes”, provide the ISIN code of the of the investment. Largest investments name largestInvestmentName If the answer to the question largestInvestmentISINCodeIndicator is “No”, provide the name of the of the investment. Percentage of assets to the largestInvestmentAsset a positive percentage reflecting the sPercentage percentage of investment during assets the for the year is required. SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 61/65 periodic

(1)SFDR UCI PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 62/65 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 PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 63/65 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 PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 64/65 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 PERIODIC DATA COLLECTION - PRACTICAL AND TECHNICAL GUIDANCE 65/65