Star Capital, in compliance with the provisions of UE Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 (the "Regulation") on sustainability reporting for the financial services industry, provides the following disclosure in accordance with Articles 3.1 and 4.1.b of the Regulation.

Disclosure of sustainability risk integration policies pursuant to Article 3.1 of the Regulation

Sustainability risk is defined as "an environmental, social or governance event or condition that, if it occurs, could cause a significant actual or potential adverse impact on the value of the investment." Sustainability risks are risks that, if they were to occur, would cause a significant negative impact on the value of the portfolio of the Funds managed by Star Capital. The company, with reference to the Regulations, has adopted its own ESG policy to integrate sustainability risks into its investment decision-making processes. Sustainability risks are considered both during the due diligence phase of a potential investment and during the monitoring of the investee portfolio companies.

Statement by the financial market participant on negative impacts on sustainability factors pursuant to Article 4.1.b

The term "principal adverse impacts" refers to "the effects of investment decisions that have a negative impact on sustainability factors". Star Capital, to date, does not take into account the negative impacts as referred in the Regulatory Technical Standard (RTS) published by ESMA on February 2, 2021, because, at the time of entry in force of the Regulation, the Funds were already established and the fundraising already completed. Moreover, while waiting for further details to be defined by the competent Authorities regarding sustainability indicators, Star Capital uses, for the purpose of monitoring activities related to ESG issues, some indicators inspired by the RTS. Star Capital will be responsible for monitoring the evolution of the regulations in order to adapt its procedures to the best practice in the sector.