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Sustainable Finance Disclosure Regulation Policy

Fortified Capital Ltd – Sustainability Finance Disclosure Regulation
(SFDR) Website Disclosure

(Regulation (EU) 2019/2088 and Taxonomy Regulation (EU) 2020/852

Introduction

Fortified Capital Ltd (“Forticap” or the “AIFM”) is required to make certain sustainability-related disclosures in accordance with the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”), Commission Delegated Regulation (EU) 2022/1288 supplementing SFDR (the “SFDR RTS”), and the Taxonomy Regulation (EU) 2020/852 (the “Taxonomy Regulation”). These regulations establish transparency obligations for financial market participants with respect to the integration of sustainability risks, the consideration of adverse sustainability impacts and the classification of financial products. These regulations require both entity-level and product-level disclosures to enhance transparency and comparability across the financial sector.

Forticap manages several alternative investment funds. All funds except one are classified as Article 6 SFDR financial products, meaning they integrate sustainability risks as part of the overall investment and risk analysis only to the extent that they are judged materially relevant to financial risk and return, and do not promote environmental or social characteristics and do not have a sustainable investment objective.

Green Melon Energies Fund an investment compartment of Green Melon RAIF F.C.I.C. Plc (the “RAIF”), managed by Forticap, is classified as an Article 8 SFDR financial product, meaning that it promotes environmental characteristics but does not have a sustainable investment objective and does not commit to making “sustainable investments” within the meaning of Article 2(17) SFDR

1. ENTITY-LEVEL DISCLOSURES

  • SFDR Article 3 disclosure – Sustainability Risk Integration in the investment decision-making process
    Forticap integrates sustainability risks into its investment decision-making process and ongoing risk monitoring where such risks are considered relevant and material to the strategy, asset class and region of the relevant fund.

    • For funds classified as Article 6 SFDR financial products, sustainability risks (e.g. climate, environmental, social or governance issues that could affect value) are assessed as part of the overall investment and risk analysis, to the extent that they may materially affect the financial performance or risk/return of the investment. These products do not promote environmental or social characteristics and do not pursue sustainable investment as an objective.
    • For Green Melon Energies Fund, which is classified as an Article 8 SFDR financial product, sustainability risks with particular emphasis on environmental and regulatory risks are integrated in a more structured manner into due diligence, investment selection and ongoing monitoring, in line with the environmental characteristics that the fund promotes. The specific manner in which sustainability risks are integrated at product level, and the likely impact of sustainability risks on returns, is described in the fund’s Offering Supplement and SFDR pre-contractual disclosure (Annex II) provided hereinbelow.

Forticap’s broader investment philosophy remains centered on long-term financial performance, risk-adjusted returns and capital preservation across its strategies (Private Equity, Hedge Funds, and Real Estate). Sustainability risks are considered to the extent that they may have a material impact on those objectives.

This position is reviewed at least annually and following material regulatory developments under SFDR and the Taxonomy Regulation

SFDR Article 4 Disclosure – No consideration of Principal Adverse Impact (PAIs)

In accordance with Article 4(1)(b) of SFDR, Forticap does not currently consider principal adverse impacts (“PAIs”) of investment decisions on sustainability factors at the entity level or at the level of its financial products.

The decision not to consider PAIs is based on:

    • Data limitations: ESG-related data, in particular for private and real-asset strategies and emerging technologies, is often incomplete, inconsistent and not sufficiently reliable or comparable across all relevant investments, sectors, and jurisdictions.
    • Methodological limitations: There is no universally accepted and robust methodology that can be consistently applied across all asset classes and strategies used by Forticap to quantify principal adverse impacts at product level.
    • Proportionality and operational considerations: Forticap’s current product range and investment strategies are not structured to support the comprehensive PAI reporting framework envisaged by SFDR RTS.

Forticap’s position on the consideration of PAIs is reviewed at least annually and may be revised in the future if data quality, methodologies and regulatory expectations evolve to a point where meaningful, reliable PAI reporting at product level becomes feasible.

SFDR Article 5 Disclosure – Remuneration Policy

The Forticap’s remuneration policy is designed to promote sound and effective risk management and to support the long-term interests of the funds it manages and their investors.  It is reviewed annually and structured to:

    • Promote sound and effective risk management;
    • Avoid incentives that could encourage excessive risk-taking;
    • Ensure remuneration does not incentivize behavior inconsistent with fund mandates or risk profiles;
    • Align with Performance Objectives: Where applicable compensation is linked to fund performance and risk-based targets;
    • Comply with Regulatory Standards: Practices adhere to AIFMD and CySEC regulatory requirements, ensuring fairness and transparency.

ESG Integration in Remuneration: At this time, Forticap does not incorporate ESG-specific or sustainability criteria or metrics into its remuneration framework. If this changes, the remuneration policy and the relevant SFDR disclosures will be updated accordingly.

2. PRODUCT-LEVEL DISCLOSURE

SFDR Article 6 Disclosure – Financial Products Not Promoting Environmental or Social Characteristics
With the exception of Green Melon Energies Fund, the financial products currently managed by Forticap are classified as Article 6 SFDR financial products. For these funds:

    • Sustainability risks are considered as part of the overall investment and risk analysis only to the extent that they are judged materially relevant to financial risk and return;
    • Do not promote environmental or social characteristics;
    • Do not have sustainable investment as their objective;
    • Do not commit to making sustainable investments.

These products are therefore not subject to the additional product-level disclosure requirements applicable to Article 8 or Article 9 SFDR products, other than the Article 6 SFDR sustainability-risk disclosures as described above and in their Offering Documents.

SFDR Article 8 & Article 10 – Product-Level Website Disclosure – Green Melon Energies Fund

The following information is provided in accordance with SFDR Article 10 and Article 24-36 of Commission Delegated Regulation (EU) 2022/1288 for Green Melon Energies Fund (the “Fund”) investment compartment of Green Melon RAIF F.C.I.C. Ltd (the “RAIF”).

Summary

Green Melon Energies Fund is classified as an Article 8 SFDR financial product. It promotes environmental characteristics but does not have a sustainable investment objective and does not commit to making sustainable investments under Article 2(17) SFDR. It applies binding investment criteria to ensure that at least 80% of its Net Asset Value is invested in activities aligned with its environmental characteristics. It does not use a designated reference benchmark and does not commit to any minimum proportion of Taxonomy-aligned investments. This website disclosure complements the pre-contractual (Annex II) and periodic (Annex IV) disclosures and is intended to meet the website obligations set out in Articles 24–36 of the SFDR RTS for Article 8 products.

Green Melon Energies Fund is a financial product that promotes environmental characteristics in line with Article 8 SFDR. The Fund:

    • Does not have a sustainable investment objective;
    • Does not make any “sustainable investments” as defined in Article 2(17) SFDR (minimum share of sustainable investments: 0%);
    • Does not commit to any minimum proportion of Taxonomy-aligned investments (current share: 0%)

The Fund primarily invests in private companies and project vehicles engaged in:

    • Carbon removal and sequestration, including biomass pyrolysis and biochar production;
    • Renewable energy and renewable fuels (eg. Biodiesel, SAF, sustainable marine fuels);
    • Recycling and waste-to-energy infrastructure;
    • Circular use of waste and residue biomass; and
    • Related decarbonization and resource-efficiency solutions.

The environmental characteristics, binding criteria, asset allocation and methodology are described below and in the Fund’s Offering Supplement and SFDR Annex II pre-contractual disclosure.

No Sustainable Investment Objective

Green Melon Energies Fund does not have sustainable investment as its objective under SFDR Article 9. Instead, it seeks to achieve long-term capital appreciation and attractive risk-adjusted returns, while promoting specific environmental characteristics as an integral part of its investment strategy.
This Fund:

    • does not have a sustainable investment objective (Article 9 SFDR does not apply);
    • does not make or does not commit to making any “sustainable investments” as defined in Article 2(17) SFDR; (the minimum share of such sustainable investments is therefore 0%)
    • does not commit to any minimum proportion of Taxonomy-aligned investments (current share: 0%).

Environmental Characteristics Promoted

The Fund promotes the following environmental characteristics:

    • Support for climate-change mitigation through carbon-removal and avoided-emission activities (e.g., biochar production, carbon sequestration, renewable fuels and renewable energy);
    • Promotion of circular use of waste and residue materials, including agricultural and forestry residues and other waste streams;
    • Contribution to long-term carbon storage and resource efficiency via technologies such as biomass pyrolysis, biochar utilization, recycling and waste-to-energy.

Investment Strategy and Binding Criteria

The Green Melon Energies Fund pursues a multi‑strategy private equity and private‑markets approach designed to support the environmental characteristics it promotes. Investments may be made both directly and indirectly, including through special purpose vehicles (SPVs) and co‑investment structures, in order to achieve diversification and efficient capital deployment.

It primarily invests in private companies and project vehicles that:

    • Develop, construct, own and/or operate biomass pyrolysis and biochar plants, carbon-removal projects, renewable energy or renewable fuel facilities; and/or
    • Operate in recycling, waste-to-energy and sustainable mobility sectors that contribute to decarbonization and circular-economy outcomes.

The Green Melon Energies Fund excludes investments in fossil fuels, coal and other environmentally harmful activities. All investee companies are required to maintain valid environmental permits and comply with health, safety and environmental (“HSE”) standards. In addition to environmental criteria, the Fund assesses the good governance practices of investee companies, including sound management structures, employee relations, remuneration of staff and tax compliance, in line with Article 28 of the SFDR Delegated Regulation.

The Green Melon Energies Fund applies binding investment criteria to support these characteristics, including:

    • A commitment to invest at least 80% of its Net Asset Value in investments aligned with the environmental characteristics it promotes (“Aligned Investments”) currently the Fund ;
    • Aligned Investments are concentrated in sectors such as carbon removal/sequestration (including biochar), renewable energy, renewable fuels, recycling, waste-to-energy and related decarbonization activities.
    • A cap of 20% of NAV for “Other Investments” (cash, liquidity and hedging instruments);
      • Restrictions on feedstock and resource inputs (e.g., preference for waste/residue inputs and avoidance of material competition with food production or significant negative land-use change);
    • The Fund will not knowingly invest in projects whose core activities are clearly incompatible with its environmental characteristics (eg. fossil-fuel extraction or coal-based power generation as a primary business).
    • Investee companies must obtain and maintain all relevant environmental, operational and health-and-safety permits and operate in compliance with applicable laws and regulations as applicable.
    • The Fund invests in companies that follow good governance practices, including sound management structures, fair employee relations, appropriate remuneration of staff, and tax compliance.

The remaining up to 20% of NAV may be invested in Other Investments such as cash, cash equivalents, short-term liquid instruments and derivatives used for hedging and efficient portfolio management. Other Investments do not promote environmental characteristics and are not treated as Aligned Investments, but they are managed so as not to undermine those characteristics.

Proportion of Investments

    • Aligned Investments (#1B Other E/S characteristics): minimum 80% of NAV, consisting of investments aligned with the environmental characteristics promoted but not counted as sustainable investments under SFDR.
    • Sustainable Investments (#1A): 0%. The Fund does not make sustainable investments within the meaning of Article 2(17) SFDR.
    • Other Investments (#2 Other): up to 20% of NAV, consisting of cash, cash equivalents, hedging instruments and ancillary assets that do not promote environmental characteristics.

No part of the portfolio is committed as Taxonomy-aligned under the EU Taxonomy Regulation. The minimum share of Taxonomy-aligned activities is 0%.

Monitoring of Environmental Characteristics

The attainment of the environmental characteristics is monitored through a combination of direct reporting and modeled estimates. Key indicators include:

    • Volumes of biomass or waste processed;
    • Quantities/volumes of biochar or renewable fuels produced;
    • Estimated CO₂ removals and/or avoided emissions;
    • Environmental permit status and HSE compliance.

Monitoring is conducted periodically on an ongoing basis and reviewed regularly at least annually to ensure alignment with its environmental characteristics and binding criteria. Where direct measurement is not possible, estimates and modeling are used, based on recognized or conservative assumptions.

Methodologies for environmental or social characteristics

The Fund uses established methodologies, where available, to assess environmental impacts, including:

    • Lifecycle assessment (LCA) analysis;
    • Carbon-accounting methodologies used by recognized voluntary carbon standards for carbon-removal projects;
    • Sector-specific emission factors and baseline scenarios to estimate avoided emissions.

Where direct measurement is not feasible, the Green Melon Energies Fund relies on modeled estimates using conservative assumptions and recognized methodologies.

Methodologies are reviewed periodically to reflect evolving standards and data availability.

Data Sources and Processing

Data is sourced from investee reporting, environmental permits, operational metrics, and third-party ESG data providers (to the extent applicable). Estimates are derived using sector benchmarks and modeling tools. Data is reviewed periodically and validated internally to ensure consistency and reliability.

Data may include estimates or models where direct measurement is not feasible. The AIFM prioritizes verified and measured data and seeks to use conservative assumptions where uncertainties exist.

Limitations to Methodologies and Data

The main limitations include:

    • incomplete or estimated data in early-stage projects;
    • evolving methodologies for carbon removal, LCA and biochar stability;
    • delayed data;
    • reliance on estimates;
    • differences in data quality and reporting standards across investees;
    • variability in reporting standards across investees and jurisdictions.

These limitations do not prevent the Fund from promoting environmental characteristics but may affect the precision of environmental metrics.

Due Diligence

Sustainability risks are integrated into due diligence, including pre-investment screening, assessment of environmental compliance, and ongoing ESG monitoring. Governance practices are also assessed to ensure investee companies maintain sound management structures, good employee relations, remuneration policies, and tax compliance.

Engagement Policies

The AIFM if applicable engages with investee companies to:

    • Obtain required environmental and operational data;
    • Encourage adherence to environmental and HSE standards;
    • Address material compliance issues;
    • Maintain governance and reporting standards.

The AIFM does not operate a formal engagement or voting policy comparable to large public-equity managers, but uses its contractual rights, governance participation and ongoing relationships to support the environmental characteristics it promotes.

Use of Derivatives

Derivatives may be used solely for hedging and efficient portfolio management purposes (e.g., to hedge interest-rate, currency or market exposures). They are not used to attain environmental characteristics and are classified as “Other Investments.”

Designated Reference Benchmark

Green Melon Energies Fund does not use a designated reference benchmark for the attainment of its environmental characteristics. Performance is measured against the Fund’s investment objectives and internal indicators rather than an index.

Article 10 – Website Disclosure Status

This section of the Website Disclosure together with the RAIF’s Offering Document and Supplement and its SFDR Annex II pre-contractual disclosure, constitutes the SFDR Article 10 website disclosure for the RAIF Green Melon RAIF F.C.I.C. Ltd and its compartment Green Melon Energies Fund.

In accordance with Articles 24–36 of Regulation (EU) 2022/1288, the RAIF, as a multi option product, provides product specific disclosures for each investment compartment. At present, only Green Melon Energies Fund is available as an Article 8 option. Future compartments, if introduced, will be accompanied by their own Annex II pre-contractual disclosures and Annex IV periodic disclosures, ensuring comparability across options within the RAIF umbrella.

Further detail on the environmental characteristics it promotes, the methodologies and data sources used, the monitoring arrangements and applicable limitations is provided in the Annex II pre-contractual disclosure and Annex IV periodic reporting.
For further information related to the RAIF and its compartments, please contact [email protected].

3. TAXONOMY REGULATION

Article 7 SFDR and Article 5-6 of the Taxonomy Regulation ((EU) 2020/852) DISCLOSURE

In accordance with Article 7 SFDR and Article 5-6 of the Taxonomy Regulation, Forticap confirms that:

    • The investments underlying all financial products it manages, including the Article 6 Funds and the Article 8 compartment Green Melon Energies Fund, do not currently take into account the EU criteria for environmentally sustainable economic activities as defined in the Taxonomy Regulation; and
    • No Fund commits to any minimum proportion of Taxonomy-aligned investments.

Accordingly, the current proportion of Taxonomy-aligned investments is considered to be 0% for all managed Funds, including the Article 8 compartment Green Melon Energies Fund. Some underlying investments may, on an incidental or non-intentional basis, meet certain technical screening criteria of the Taxonomy Regulation, but such alignment is not targeted, measured or used as a binding constraint within the current investment strategies.

4. REVIEW OF THIS DISCLOSURE POLICY                                                       

This Website Disclosure is reviewed at least annually and upon the occurrence of any material regulatory changes or developments in Forticap’s investment strategies, including changes to the SFDR classification of any of the managed Funds or the introduction of any sustainable investment objectives or Taxonomy-aligned targets.
Any material updates will be reflected on this website and, where applicable, in the relevant legal and Offering Documents and SFDR disclosures.

Annex II - Green Melon Energies Fund | SFDR Disclosure

SFDR ANNEX II

Template pre-contractual disclosure for the financial products referred to in Article 8, paragraphs 1, 2 and 2a, of Regulation (EU) 2019/2088 and Article 6, first paragraph, of Regulation (EU) 2020/852
Product name:
GREEN MELON ENERGIES FUND
Legal entity identifier:
254900W7B1JIP4BSXS83
Publication date:
•/•/2025
Last reviewed:
•/•/2025
Environmental and/or social characteristics
Does this financial product have a sustainable investment objective?
Yes
It will make a minimum of sustainable investments with an environmental objective: ___%
in economic activities that qualify as environmentally sustainable under the EU Taxonomy
in economic activities that do not qualify as environmentally sustainable under the EU Taxonomy
It will make a minimum of sustainable investments with a social objective: ___%
No
It promotes Environmental/Social (E/S) characteristics and while it does not have as its objective a sustainable investment, it will have a minimum proportion of ___% of sustainable investments
with an environmental objective in economic activities that qualify as environmentally sustainable under the EU Taxonomy
with an environmental objective in economic activities that do not qualify as environmentally sustainable under the EU Taxonomy
with a social objective
It promotes E/S characteristics, but will not make any sustainable investments
What environmental and/or social characteristics are promoted by this financial product?

This financial product, the Green Melon Energies Fund an investment compartment of Green Melon RAIF F.C.I.C. Plc, promotes environmental characteristics. It does not promote social characteristics and does not have a sustainable investment objectives.

The environmental characteristics promoted are:

  • Climate-change mitigation, by supporting activities that reduce or remove greenhouse-gas ("GHG") emmissions, including biomass pyrolysis, biochar production, projects that contribute to lower GHG emissions compared with conventional fossil-based alternatives;
  • Circular use of waste and residue biomass, by investing in projects and companies that utilise agricultural, forestry and other residual biomass and waste streams which would otherwise be landfilled, openly burned or left to decompose, thereby reducing uncontrolled emissions and improving resource efficiency;
  • Long-term carbon storage, by producing and using biochar and similar carbon-rich materials in applications such as soil enhancement and cement or construction materials, enabling the long-term sequestration of biogenic carbon;
  • Resource efficiency and waste valorization, by supporting recycling, waste-to-energy and other circular-economy solutions that convert low-value or discarded materials into useful products or energy, thereby reducing pressure on natural resources.

These environmental characteristics are embedded in the investment policy and strategy of the product and are supported by binding investment criteria.

No reference benchmark has been designated for the purpose of attaining these characteristics.

What sustainability indicators are used to measure the attainment of each of the environmental or social characteristics promoted by this financial product?

To measure the attainment of its environmental or social characteristics, the External Manager uses a set of quantitative and qualitative sustainability indicators, as appropriate to each investment. These indicators are monitored at least annually based on data reported by the investee companies and, where relevant, by independent third parties.

Key indicators include:

  • Volume of waste and residue biomass utilised - Tonnes of agricultural, forestry or other eligible waste and residue biomass processed per year.

    This indicator measures the contribution to the environmental characteristics of circular use of waste and residue biomass by showing the extent to which residual feedstocks are diverted from landfill, open burning or uncontrolled decomposition.
  • Production of biochar and other low-carbon outputs:
    • Tonnes of biochar produced per year
    • Where applicable, volumes of renewable fuels or renewable energy generated
    These indicators measure the extent to which the product contributes to long-term carbon storage and resource efficiency, by quantifying the outputs that embody sequestered carbon or displace higher-emission alternatives.
  • Estimated GHG emission reductions and/or CO₂ removals
    • Estimated tonnes of CO₂-equivalent ("tCO₂e") removed through carbon sequestration (e.g. stable carbon stored in biochar over its expected lifetime)
    • Estimated ("tCO₂e") of avoided emissions, for example through substitution of fossil fuels or avoidance of methane and other emissions from alternative disposal pathways for biomass or waste.
    These indicators measure the contribution of the product to climate-change mitigation by estimating the reduction or removal GHG emissions attributable to the product's investments, based on appropriate methodologies to the extent available.
  • Environmental compliance and HSE performance:
    • Status of environmental permits and licences (e.g. valid permits; any suspensions or material non-compliances).
    • Number and nature of reported environmental or health and safety incidents, and follow-up actions taken

The specific metrics used for given investment may vary depnding on the nature of the activity and information availability. The overall objective is to ensure that the portfolio's Aligned Investments can demonstrate, through measurable indicators, their contribution to the environmental characteristics the product promotes.

Where direct measurement is not possible, estimates and modeling are used, based on recognized or conservative assumptions.

What are the objectives of the sustainable investments that the financial product partially intends to make and how does the sustainable investment contribute to such objectives?

N/A – This financial product does not make any "sustainable investments" within the meaning of Article 2(17) SFDR and does not commit to any minimum proportion of sustainable investments.

The only objective of the product are:

  • a financial objective of achieving long-term capital appreciation and attractive risk-adjusted returns; and
  • the promotion of environmental characteristics as described above, which are pursued through the product's investment strategy and binding criteria, but without constituting a "sustainable investment objective" under SFDR.
How do the sustainable investments that the financial product partially intends to make, not cause significant harm to any environmental or social sustainable investment objective?

N/A – As noted above, this financial product does not intend to make any sustainable investments within the meaning of Article 2(17) SFDR and does not commit to a minimum share of such investments. The requirement to assess "do no significant harm" ("DNSH") at the level of sustainable investment, as described in the SFDR and associated regulatory technical standards, is therefore not applicable to this product.

How have the indicators for adverse impacts on sustainability factors been taken into account?

N/A – Because this financial product does not make sustainable investments within the meaning of Article 2(17) SFDR, and because the External Manager has chosen not to consider principal adverse impacts of investment decisions on sustainability factors at product level in accordance with Article 4(1) SFDR, the requirements in the SFDR and its regulatory technical standards relating specifically to the use of indicators for principal adverse impacts of investment decisions on sustainability factors in the context of sustainable investments are not applicable to this product.

How are the sustainable investments aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights? Details:

N/A – this question is not applicable, as noted above the financial product does not intend to make any sustainable investments.

The EU Taxonomy sets out a "do not significant harm" principle by which Taxonomy-aligned investments should not significantly harm EU Taxonomy objectives and is accompanied by specific EU criteria.

The "do no significant harm" principle applies only to those investments underlying the financial product that take into account the EU criteria for environmentally sustainable economic activities. The investments underlying the remaining portion of this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

Any other sustainable investments must also not significantly harm any environmental or social objectives.

Principal Adverse Impacts
Does this financial product consider principal adverse impacts on sustainability factors?
Yes,
No

This financial product does not consider principal adverse impacts ("PAIs") of investment decisions on sustainability factors within the meaning of Article 7 of Regulation (EU) 2019/2088 ("SFDR"). The reasons for not considering PAIs at product level are:

  • Insufficient availability of reliable, consistent and comparable data from underlying investments, particularly for private-market and real-asset strategies in which the financial product ivests;
  • Absence of adequate and standardized methodologies for measuring principal adverse impacts across sectors and jurisdictions relevant to this financial product;
  • Proportionality considerations, given that the financial product promotes environmental characteristics but does not commit to making any "sustainable investments" as defined in Article 2(17) SFDR and does not pursue a sustainable investment objective.

Because PAIs are not considered, the detailed PAI indicators and disclosures referred to in Article 11(2) SFDR and in Table 1, Table 2 and Table 3 of ANNEX I of SFDR are not applicable to this financial product and are not included in its periodic reporting.

Investment Strategy
What investment strategy does this financial product follow?

This financial product (Green Melon Energies Fund) pursues a multi-strategy private equity and private-markets investment strategy with a primary objective of achieving long-term capital appreciation and attractive risk-adjusted returns. The financial product will be managed on a total return basis and it will be actively managed without reference to any specific benchmark, from an asset allocation and returns perspective.

To attain the environmental characteristics it promotes, the product invests mainly in:

  • Companies and project vehicles that develop, construct, own and/or operate biomass pyrolysis and biochar production facilities and other carbon-removal projects which process waste and residue biomass into biochar and renewable energy or fuels;
  • Businesses and projects in the fields of renewable energy, renewable fuels (e.g. biodiesel, sustainable aviation fuel, sustainable marine fuels), recycling, sustainable mobility/transportation and waste-to-energy, where there is a clear environmental rationale such as reduced GHG emissions, circular use of resources, and support for the low-carbon transition.

Investments may be made directly or indirectly (e.g. through special purpose vehicles, holding companies or co-investment structures) and may span different stages of development (venture, growth, expansion, project finance, buy-out or restructuring), provided they are consistent with the fund's financial objective and with the environmental characteristics and binding criteria described in this document.

The product does not have a sustainable investment objective and does not make any "sustainable investments" within the meaning of Article 2(17) SFDR. Its strategy is therefore to invest in assets that are financially attractive and that promote environmental characteristics, not to achieve a specific sustainable investment outcome.

What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product?

The following elements of the investment strategy are binding and are systematically applied when selecting, managing and monitoring investments in order to attain the environmental characteristics promoted by the product:

  • Minimum allocation to Aligned Investments – The product is required to invest at least 80% of its NAV in "Aligned Investments", defined as investments that support one or more of the environmental characteristics promoted by the product (climate-change mitigation, circular use of waste and residue biomass, long-term carbon storage and resource efficiency), and that are consistent with the investment strategy set out in the pre-contractual documentation.
  • Binding portfolio construction limits – The product maintains a distinction between Aligned Investments and Other Investments. Other Investments, may include cash, cash equivalents, liquid instruments and hedging positions held for treasury or risk-management purposes, are limited to a maximum of 20% of the product's NAV and are not permitted to undermine the attainment of the environmental characteristics.
  • The product invests primarily in carbon-removal/sequestration projects such as biochar and biomass pyrolysis, renewable energy and renewable fuels, recycling and waste-to-energy, and sustainable mobility/decarbonisation solutions. Investments outside these sectors are only permitted if they fall within the limited "Other Investments" bucket described below and do not undermine the environmental characteristics promoted by the product.
  • Environmental and regulatory compliance requirements – Investee companies must obtain and maintain all material environmental, health and safety and operational permits and licences required under the applicable law. Severe or repeated non-compliance with environmental or HSE legislation is incompatible with the Fund's binding criteria and may preclude investment or trigger remedial action or divestment.
  • Exclusion of certain activities – The product will not intentionally invest in activities that are fundamentally misaligned with its environmental characteristics, such as:
    • Fossil-fuel extraction, refining or coal-based power generation as core business;
    • Projects that are primarily based on the extraction and combustion of coal, crude oil or unconventional fossil fuels;
    • Activities that clearly cause significant and irreversible environmental damage or are otherwise incompatible with the product's environmental characteristics.
  • Monitoring of environmental indicators – For each Aligned Investment, the External Manager will apply, to the extent each investment's stage permits, regular monitoring on relevant environmental indicators, such as:
    • Annual volumes of waste or residue feedstock processed;
    • Volumes of biochar or renewable fuels produced;
    • To the extent possible estimates of CO₂ removed and/or emissions avoided;
    • Status of environmental permits and any material HSE incidents, along with corrective actions taken.
    These indicators to the extent applicable and subject to the availability of relevant measurements on a case by case basis will be reviewed as part of the ongoing monitoring process and will be used to verify whether and to what extent the environmental characteristics are being attained.
What is the committed minimum rate to reduce the scope of the investments considered prior to the application of that investment strategy?
  • The product does not commit to a specific numerical minimum rate of reduction of the initial investment universe, expressed as a percentage, prior to the application of its investment strategy.
  • Instead, the product applies the binding environmental and exclusion criteria described above as qualitative filters that define which investments may be treated as Aligned Investments and counted towards the minimum 80% allocation.

In practice, this means that:

  • The Fund's investment universe is effectively limited to sectors and activities that can contribute to the environmental characteristics promoted by the product and that meet the mandatory environmental and governance criteria;
  • Investments that do not satisfy these binding criteria are not considered as Aligned Investments and may either be excluded entirely or, where appropriate, only be held within the limited "Other Investments" bucket which is capped at 20% of the NAV and cannot undermine the environmental characteristics.

Because the Fund's investment strategy is already inherently focused on activities with an environmental rationale (carbon removal, renewable energy/fuels, recycling, etc.), the application of these binding criteria primarily serves to ensure that all core investments remain aligned with the promoted characteristics, rather than to reduce a broad generic universe by a measurable percentage. For this reason, the fund does not state a numerical minimum "reduction rate" but instead commits to the 80% minimum allocation to Aligned Investments and to the qualitative exclusion and sustainability criteria described above.

What is the policy to assess good governance practices of the investee companies?

Although the promotion of environmental characteristics is the focus of the product, the financial product may invest only in investee companies that follow good governance practices, including with respect to sound management structures, employee relations, remuneration and tax compliance.

The External Manager applies the following policy to assess good governance practices:

  • Pre-investment governance due diligince – Before making an investment in a company or project, the External Manager undertakes a due diligence review that includes an assessment of governance practices.
  • Ongoing monitoring of governance – After an investment is made, the External Manager monitors the investees's governance practices on an ongoing basis by:
    • Reviewing periodic financial statements, audit reports where applicable by the local requirements;
    • Engaging with management and, where applicable, representatives on boards;
    • Monitoring any material legal, regulatory, compiance or ESG-related incidents, including those related to business ethics, corruption, labour disputes or environmental violations;
    • Requesting remedial actions or enhancements to governance frameworks where weaknesses or concerns are identified.
Proportion of Investments
What is the asset allocation planned for this financial product?

This financial product (Green Melon Energies Fund) pursues a multi-strategy private equity and private-markets strategy focused on environmental themes. Although many Aligned Investments are expected to contribute positively to environmental outcomes, the financial product does not commit to making any "sustainable investments". To ensure that the promoted environmental characteristics are effectively attained, its portfolio wil consists of:

  • At least 80% of the financial product's NAV will be invested in Aligned Investments – these will typically consist of equity investments linked to private companies and project vehicles that:
    • develop, construct, own and/or operate biomass pyrolysis and biochar facilities, carbon-removal projects, renewable energy and renewable fuel projects, and recycling and waste-to-energy assets;
    • and/or engage in activities that demonstrably support the product's environmental characteristics, such as decarbonisation of industrial processes, circular use of waste and residue materials, long-term carbon storage and improved resource efficiency.
    Aligned Investments are selected and monitored in accordance with the binding elements of the investment strategy, including sector and activity focus, exclusion of incompatible sectors (such as fossil-fuel extraction and coal-based energy generation as a core business) and mandatory environmental compliance and monitoring requirements.
  • Up to 20% of the financial product's NAV may be invested in Other Investments – these may include cash cash and cash equivalents, bank deposits and short-term money-market instruments, hedging instruments and other derivatives used for efficient portfolio management or risk-mitigation purposes (for example, to hedge interest-rate, currency or other financial risks), that do not themselves promote the environmental characteristics of the product but are held to support its operation and liquidity.

Other Investments are not counted towards the 80% minimum allocation to Aligned Investments and are not used to pursue the environmental characteristics. However, they are managed in a way that ensures they do not significantly undermine the environmental characteristics promoted by the product.

Investments
#1 Aligned with E/S characteristics
(≥80% NAV)
#2 Other
(≤20% NAV)
#1B Other E/S characteristics
(≥80% NAV)

#1 Aligned with E/S characteristics includes the investments of the financial product used to attain the environmental or social characteristics promoted by the financial product.

- The sub-category #1B Other E/S characteristics covers investments aligned with the environmental or social characteristics that do not qualify as sustainable investments.

#2Other includes the remaining investments of the financial product which are neither aligned with the environmental or social characteristics, nor are qualified as sustainable investments.

How does the use of derivatives attain the environmental or social characteristics promoted by the financial product?

The financial product does not use derivatives to directly attain or increase exposure to the environmental characteristics it promotes and are not counted as Aligned Investments for the purposes of the minimum 80% allocation to Aligned Investments.

The financial product may use derivatives (within the meaning of Article 2(1), point (29), of Regulation (EU) No 600/2014) solely for hedging and efficient portfolio management purposes, for example to hedge interest-rate, currency or market exposures or to manage liquidity during capital deployment. Such derivative positions are classified as "#2 Other" investments and as shown in the diagram below are not counted towards the minimum share of investments used to promote the environmental characteristics of the financial product.

EU Taxonomy
To what minimum extent are sustainable investments with an environmental objective aligned with the EU Taxonomy?

N/A
This financial product does not make any "sustainable investments" within the meaning of Article 2(17) SFDR and does not commit to making investments in economic activities that qualify as environmentally sustainable under Regulation (EU) 2020/852 (the "EU Taxonomy Regulation").

The investee companies are not designated as "Taxonomy-aligned sustainable investments" for the purposes of SFDR and the Taxonomy Regulation. They are treated as Aligned Investments to promote environmental characteristics under Article 8 SFDR, but they are not counted towards any minimum share of Taxonomy-aligned or other sustainable investments.

Because the financial product does not make sustainable investments within the meaning of Article 2(17) SFDR and does not commit to any minimum proportion of investments in environmentally sustainable economic activities under the EU Taxonomy Regulation:

  • the detailed information referred to in Article 15(1)(b)–(d) of the EU Taxonomy Regulation (including a description of the environmental objectives pursued by Taxonomy-aligned investments and how those investments are assessed against the Taxonomy criteria) is not applicable; and
  • the additional information referred to in Article 15(2) and (3) of the EU Taxonomy Regulation (including any breakdown between climate change mitigation and climate change adaptation, transitional activities and enabling activities) is also not applicable.
Does the financial product invest in fossil gas and/or nuclear energy related activities that comply with the EU Taxonomy1?
Yes:
In fossil gas
In nuclear energy
No

1 Fossil gas and/or nuclear related activities will only comply with the EU Taxonomy where they contribute to limiting climate change ("climate change mitigation") and do not significantly harm any EU Taxonomy objective - see explanatory note in the left hand margin. The full criteria for fossil gas and nuclear energy economic activities that comply with the EU Taxonomy are laid down in Commission Delegated Regulation (EU) 2022/1214.

What is the minimum share of investments in transitional and enabling activities?

This financial product does not commit to making sustainable investments within the meaning of Article 2(17) SFDR and does not commit to investing in economic activities that qualify as environmentally sustainable under Regulation (EU) 2020/852 (the "EU Taxonomy Regulation").

Accordingly:

  • the minimum share of investments in Taxonomy-aligned transitional activities is 0% of the financial product's Net Asset Value; and
  • the minimum share of investments in Taxonomy-aligned enabling activities is 0% of the financial product's NAV.

Any investments that may, on an incidental or non-intentional basis, fall within the scope of transitional or enabling activities under the EU Taxonomy are not counted towards any binding minimum share, and the financial product does not use the EU Taxonomy as a binding investment constraint.

Sustainable Investments
What is the minimum share of sustainable investments with an environmental objective that are not aligned with the EU Taxonomy?

This financial product does not make any sustainable investments within the meaning of Article 2(17) SFDR. Accordingly, the minimum share of sustainable investments with an environmental objective that are not aligned with the EU Taxonomy is 0% of the financial product's NAV.

What is the minimum share of socially sustainable investments?

Not applicable to this financial product. This financial product does not make any sustainable investments within the meaning of Article 2(17) of SFDR and does not promote social characteristics. Accordingly, the minimum share of socially sustainable investments is 0% of the financial product's NAV.

What investments are included under "#2 Other", what is their purpose and are there any minimum environmental or social safeguards?

The category "#2 Other", comprises the portion of the financial product's investments that do not promote the environmental characteristics of the financial product and do not qualify as sustainable investments under Article 2(17) SFDR. For this financial product, "#2 Other" investments may include:

  • Cash and cash equivalents, including cash held for liquidity management and operational needs;
  • Bank deposits and short-term money-market instruments;
  • Units or shares of money-market funds used for liquidity and treasury purposes;
  • Hedging instruments, including derivatives used solely for currency, interest-rate or market-risk hedging;
  • Receivables, payables or settlement balances arising from portfolio operations;

These category "#2 Other" investments serve primarily to:

  • Ensure sufficeint liquidity for capital calls, expenses and commitments;
  • Support efficient portfolio management and risk mitigation;
  • Manage temporary cash balances during investment deployment;
  • Facilitate the orderly operation of the financial product.

These investments do not contribute to the attainment of the environmental characteristics promoted by the financial product and are not counted toward the minimum 80% allocation to Aligned Investmetns.

Designated Reference Benchmark
Is a specific index designated as a reference benchmark to determine whether this financial product is aligned with the environmental and/or social characteristics that it promotes?

The product is an actively managed private markets fund that invests primarily in private companies and project vehicles such as biomass pyrolysis and biochar projects, recycling and waste-to-energy assets for which no suitable, representative and commonly accepted envrionmental benchmark exists. The environmental characteristics promoted by the product are therefore assessed and monitored directly at the level of the underlying investment, using the sustainability indicators and binding investment criteria described in this pre-contractual disclosure, rather than by reference to an external index.

How is the reference benchmark continuously aligned with each of the environmental or social characteristics promoted by the financial product?

N/A

How is the alignment of the investment strategy with the methodology of the index ensured on a continuous basis?

N/A

How does the designated index differ from a relevant broad market index?

N/A

Where can the methodology used for the calculation of the designated index be found?

N/A

Additional Information
Where can I find more product specific information online?

More product-specific information can be found on the External Manager's website at: www.forticap.eu under SFDR DISCLOSURE tab.