SFDR Statement

Saratoga Capital Partners Limited – SFDR Transparency Statement

Purpose
This statement provides transparency regarding sustainability-related disclosures in accordance with EU Regulation 2019/2088 (SFDR) and reflects Saratoga Capital's commitment to evolving best practices in responsible investment.

Integration of Sustainability Risks
Saratoga Capital currently does not implement entity-level ESG policies, nor are sustainable investments the primary objective of its managed strategies under Article 9 of the SFDR. That said, we acknowledge the growing importance of environmental, social, and governance (ESG) considerations for long-term value creation. Sustainability risks are increasingly recognized as factors that may materially affect investment performance. As such, Saratoga Capital intends to progressively integrate ESG considerations into its investment assessment and monitoring processes, with a focus on identifying, understanding, and mitigating material sustainability risks where relevant whilst not risking positive investor financial outcomes.

Adverse Sustainability Impacts
We recognize that investment activities can have broader sustainability implications. While Saratoga Capital does not currently carry out a systematic assessment of the principal adverse impacts of investment decisions on sustainability factors, it is committed to keeping this approach under review. We may implement more structured processes in line with regulatory developments, industry best practice, and investor expectations, ensuring that sustainability considerations are appropriately reflected in investment decision-making over time.

Remuneration Policy
Saratoga Capital's remuneration framework is designed to align employee incentives with our risk management principles. Compensation structures are calibrated to avoid incentivizing excessive risk-taking, including risks related to sustainability factors, thereby supporting long-term value creation for investors and stakeholders.

Pre-Contractual Disclosures
Where relevant, offering documents and pre-contractual materials will detail how sustainability risks are considered in investment decisions and their potential impact on returns. In instances where sustainability risks are not deemed material, a clear explanation will be provided to ensure transparency and informed decision-making for clients.

Forward-Looking Commitment
Saratoga Capital is committed to the ongoing development of responsible investment practices. We will continue to evaluate ESG integration and sustainability reporting, adapting its approach as market standards evolve, with the goal of fostering sustainable, risk-aware, and value-driven investment outcomes for our clients and portfolio companies.

Last updated: January 1, 2026.