A Global, Multi-Strategy Investment Approach

Fund Manager Disclosure pursuant to Hong Kong Fund Manager Code of Conduct

Linden Advisors LP ("Linden") considers environmental, social and governance ("ESG") issues and opportunities, including climate-related risks and opportunities, as part of its investment approach in monitoring investment merit and risk across investment strategies. Linden seeks to implement a policy that considers ESG risks and opportunities while acting in the best interests of its investors. As industry guidelines and best practices will evolve over time, Linden will periodically review its relevant policies to ensure that they evolve accordingly. Linden's investment professionals are responsible for identifying ESG risks and opportunities in the investment process and have extensive experience in assessing ESG risk factors and opportunities. ESG matters may be presented in issuer filings, issuer statements, or discussions between Linden and company management. In addition, Linden incorporates data and ESG ratings from third party providers into its ESG assessment. Linden has developed a multi-disciplinary approach to ESG oversight whereby senior investment team members, Compliance and the Brokerage Committee have a role in monitoring Linden’s incorporation of ESG factors into investment decisions and in analyzing ESG trends in the portfolio. Linden's CEO, Chief Risk Officer and Research Director are responsible for maintaining ongoing awareness and monitoring of salient ESG matters across the portfolio and Linden's Compliance Group monitors ESG trends in the portfolio and provides reporting to the investment team and senior management. Linden’s Brokerage Committee, comprised of senior management personnel, reviews quarterly reporting on the summary of ESG ratings across Linden’s portfolio as well as recent ratings trends for individual issuers and the total portfolio.

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Entity level website disclosures pursuant to Articles 3, 4 and 5 of the EU Sustainable Finance Disclosure Regulation (2019/2088) (SFDR)

Sustainability-related disclosures

As Linden Advisors LP (“Linden”) manages certain alternative investment funds (the “Funds”) that have been registered for marketing under the Alternative Investment Fund Managers Directive (2011/61/EU) (the “AIFMD”) in one or more member states of the European Economic Area (“EEA”), Linden is required by the Sustainable Finance Disclosure Regulation (Regulation 2019/2088) (the “SFDR”) to make certain disclosures on its website, including information about the AIFM’s policies on the integration of sustainability risks into its investment decision-making process; its approach to adverse sustainability impacts; and the consistency of its remuneration policies with the integration of sustainability risks. For these purposes, sustainability risk means an environmental, social or governance (“ESG”) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

No consideration of sustainability adverse impacts

As the Funds and portfolios managed by Linden are not designed to promote specific ESG outcomes, and as Linden’s objective is typically to generate superior, risk-adjusted returns, other than in relation to sustainability risks, Linden does not currently consider the adverse impacts on sustainability factors that may result from its investment decisions as part of its investment management process.

Policies on the integration of sustainability risks into the investment decision-making process

Linden believes that incorporating the consideration of sustainability risks into its investment process is consistent with its mandate to deliver superior, risk-adjusted returns to investors. Where it is practicable to do so, Linden will seek to consider sustainability-related risks as part of its investment analysis and processes in the manner further described below.

ESG Management and Accountability

Linden employs investment professionals who have responsibility for identifying sustainability risks in the investment process.  In instances where material sustainability risks are identified, the investment professionals will be responsible for escalating those issues for consideration in the investment decision-making process by the relevant group head, portfolio manager or investment committee, as appropriate.  The Risk Manager, Head of Research and Senior Portfolio Manager are responsible for maintaining ongoing awareness and monitoring of salient sustainability risks across the portfolio.

Investment Merit and Risk Monitoring

Linden assesses the materiality of sustainability risks in its consideration of prospective fundamental investments and throughout the investment lifecycle.  Consistent with its fiduciary duties and the investment mandates of the Funds and separately managed accounts, Linden does not intend to negatively screen opportunities from the investable universe (except where required by a separately managed account), but rather evaluate and monitor sustainability risks that may have material impacts on investments.  Sustainability risk exposure areas that will be considered may include, but are not limited to, ethics, data privacy, bribery and corruption, labor conditions, environmental impact, and supply chain compliance.  Linden may engage internal and external experts, where appropriate, to enhance its investment process and evaluation of sustainability risks.

Sustainability risks will be integrated into continuous risk monitoring processes in order to inform ongoing portfolio and market awareness.

Linden adjusts its engagement in sustainability risk-related issues in accordance with the likelihood of such sustainability risk factors and opportunities impacting upon the value of the portfolio. For these purposes, and where appropriate, Linden will share its ESG policy with portfolio companies, communicate ESG findings and encourage accretive ESG management.

Consistency of remuneration policies

Linden’s remuneration policies are consistent with its approach to the integration of sustainability risks into the investment decision-making process. As sustainability risks are a type of financial risk, Linden acknowledges that failure to consider such risks could have an adverse impact on the performance of investments and the performance of the Funds and portfolios managed by Linden. Pursuant to Linden’s remuneration policies, Linden awards fixed and variable remuneration to staff. Variable remuneration is awarded on a discretionary basis and takes into account the performance of an individual employee, the performance of the Funds and/or portfolios, and the overall financial performance of the Linden group. Accordingly, to the extent that sustainability risks have an adverse impact on performance of the Funds or the portfolios, this is likely to be reflected in the overall level of variable remuneration awarded to staff.