The Firm seeks to comply with the EU’s Sustainable Finance Disclosure Regulation ("SFDR"), as applicable. In connection with the forgoing, compensation-related determinations include a holistic assessment of individuals’ compliance with all Firm policies and procedures, including the Firm’s ESG policy. However, as further detailed in client disclosures, the Firm does not consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors in respect of advisory clients. Taking into account the nature and scale of our investment activities, having carefully evaluated the SFDR’s requirements regarding principal adverse impacts and the draft Regulatory Technical Standards published February 2021 (the "PAI regime"), at this time it would be disproportionate to comply with the SFDR’s specific PAI regime. Additional information is set forth in governing client agreements.