FIRM STATEMENT OF PRINCIPLES ON RESPONSIBLE INVESTING

Serengeti Asset Management, LP (“Serengeti”) is a value-driven investment firm focused on investing in niche credit opportunities and providing sophisticated funding solutions. We believe that Environmental, Social and Governance (“ESG”) factors can affect performance to varying degrees across companies, sectors, regions, investment strategies and asset classes. As such, we seek to consider material ESG risks, issues and opportunities, together with financial criteria, in applicable investment processes in line with our fiduciary duty to maximize returns.

Principles for Responsible Investment

Serengeti supports the UN-backed Principles for Responsible Investment (“PRI”), and is in the process of becoming a formal signatory to the PRI and its six principles:

Incorporating ESG issues into our investment analysis and decision-making processes

Being active owners and incorporating ESG issues into ownership policies and practices in proportion to our level of influence

Seeking appropriate disclosure on ESG issues by the entities in which we invest

Promoting acceptance and implementation of the PRI principles within the investment industry

Working together to enhance our effectiveness in implementing the six principles

Reporting on our activities and progress towards implementing the six principles

Applicability

The policy is effective from 30 October 2021, covering all funds and investment vehicles that have been open to new investors since 2018.

Approach to ESG Integration

The nature of our investment strategies means that we typically are not making control investments, limiting our ability to exert influence through ownership, board seats and/or governance rights. In applicable funds and investment vehicles, we seek to consider ESG factors in new investments as part of a wider due diligence process, evaluating ESG risks, issues and opportunities, in proportion to our leverage, influence and access to information, as well as holding period and the size of the deal.

ESG as a Firm

In addition to considering ESG factors as part of our investment processes, Serengeti aims to increase its focus on incorporating responsible and sustainable practices throughout the organization.

Implementation

To implement this policy, Serengeti will:

Provide ESG training to employees

Engage external ESG advisors where appropriate

Become a signatory to PRI

Incorporate reference to this Policy into its compliance manual

Policy Sponsors: Chief Investment Officer, President and General Counsel

Last Update: October 2021