VISIONSQUARE FUND

SFDR Disclosures

This disclosure provides the sustainability-related information required under Article 6(1) and Article 4(1)(b) of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (as amended, the “SFDR”) as at March 10, 2021.

In accordance with the SFDR, for the purposes of this disclosure, “sustainability risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment, and “sustainability factors” means environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

The manner in which the Investment Manager integrates sustainability risks into its investment decisions

The Investment Manager has adopted a two-part approach to the integration of sustainability risks into its investment decisions: (i) investment selection and (ii) stewardship.

The Investment Manager believes that good corporate governance, including the management of sustainability risks by an investee company management, mitigates risk and creates long-term value for shareholders. The most important criterion in VISIONSQUARE FUND’s investment selection process is its view of the long-term quality of a business, which is informed by, among other things, our assessment of the long-term impact of the company on all of its stakeholders and society at large, and how its management and board manage sustainability risks. Assessing the sustainability risks of a potential investment is a critical component of our investment selection process.

The Investment Manager is a fundamental value investor that utilizes an active approach to stewardship. Its strategy is to make investments in high quality, durable growth businesses over which it often has substantial influence. The Investment Manager employs that influence in a manner that is intended to create long-term value for investors. In many instances, the Investment Manager has identified companies with excellent governance and significant engagement on ESG issues, including environmental stewardship programs, community engagement, and diversity and inclusion initiatives. In other instances, the Investment Manager believes that engagement with the management of certain investee companies to improve their ESG practices can improve long-term shareholder value.

The results of the Investment Manager’s assessment of the likely impacts of sustainability risks on the returns of the Company and statement on consideration of adverse impacts

The Investment Manager believes that the likely impact of sustainability risks on the Company’s returns are limited in light of its approach to investment selection. The Investment Manager assesses the impacts of sustainability risks on the long-term success of each of its portfolio companies by seeking to deeply understand the business and the industry in which it operates. This due diligence process enables the Investment Manager to avoid making investments where it concludes that the sustainability risks associated with core business products or services do not align with its investment principles.

The Investment Manager’s assessment of sustainability risks and factors is limited, however, by the availability and quality of available data. Data addressing sustainability factors is not always disclosed by investee companies, may not otherwise be available and/or may be incomplete or inaccurate. Furthermore, most of the available information on a company’s sustainability factors is generally based on historical data, which may not fully reflect the future performance of that company or the sustainability risks it is exposed to. While the Investment Manager seeks to incorporate all appropriate information into its investment decision-making process, there can be no assurance that such policies and methodologies will capture all relevant information on sustainability risks and factors with respect to investee companies. In addition, although the Investment Manager takes into account sustainability risks and other ESG factors as part of its investment process, given the evolving nature of the regulatory environment and the lack of consensus as to how ESG factors and their adverse impacts are defined and evaluated, the Investment Manager does not currently utilize the set of sustainability factors in the manner set forth in the Regulatory Technical Standards under the SFDR to consider and evaluate the adverse impact of sustainability issues on its investment decisions.

EU Taxonomy Regulation Statement

The following statement is made pursuant to Article 7 of Regulation (EU) 2020/852 (the “Taxonomy Regulation”): The investments underlying the Company do not take into account the EU criteria for environmentally sustainable economic activities.