American Securities believes that Environmental, Social and Governance (“ESG”) considerations may impact investment outcomes. As a result, American Securities strives to focus on ESG throughout the investment lifecycle.

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 the investment (“Sustainability Risk”). Sustainability Risk is treated in the same way as other risks which could cause a material negative impact on the value of a fund or portfolio.

American Securities considers a variety of sustainability factors in connection with the investment strategies of its funds. Such factors are set out in American Securities’ Environmental, Social and Governance (ESG) Policy (the “ESG Principles and Implementation”). It is important to American Securities that all colleagues are fully aligned with the ESG Principles and Implementation, and as with all the Firm’s policies, adherence to such policy will be considered in every individual’s performance assessments. Such performance assessments will be linked to and may impact the remuneration of colleagues based on their relevant role and responsibilities.

American Securities does not currently consider the adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR. Whilst ESG considerations are integrated into American Securities’ investment process as outlined in the ESG Principles and Implementation, the detailed rules underlying the SFDR will require American Securities to ascertain the availability of the data expected to be reported under the new requirements of the SFDR. As such, the position will continue to be monitored and reviewed by American Securities as the underlying rules and their application become embedded in market practice.