SFDR

Sustainability-related
disclosures

Document version of 25 October 2026

L2M Global HY Fund SCSp does not promote environmental or social characteristics and does not have sustainable investment as its objective. It is a financial product falling within Article 6 of Regulation (EU) 2019/2088 on sustainability‑related disclosures in the financial services sector (SFDR). The disclosures below are made at the level of the manager and at the level of the Fund.

1. Scope and basis of these disclosures

These disclosures are made by L2M Investments S.à r.l. (the Manager), which will act as general partner of L2M Global HY Fund SCSp (the Fund).

ManagerL2M Investments S.à r.l.
Legal formSociété à responsabilité limitée, Luxembourg
RCS LuxembourgB312969
Registered office2 Place de Strasbourg, L‑2526 Luxembourg
Regulatory statusApplication for registration as a sub‑threshold manager under Article 3(2) of Directive 2011/61/EU (AIFMD) pending with the CSSF
FundL2M Global HY Fund SCSp
Fund legal formSociété en commandite spéciale, Luxembourg
SFDR classificationArticle 6 — no promotion of environmental or social characteristics

Registration status. The Manager has applied to the CSSF for registration as a sub‑threshold alternative investment fund manager under Article 3(2) of AIFMD. At the date of this document that application is pending. The Manager is not registered, does not manage the Fund and provides no financial services. It will begin to do so once its registration with the CSSF is confirmed.

These disclosures are published in advance of that date. They set out the approach the Manager has adopted and will apply from the date on which it is registered and begins to manage the Fund, and they will be reviewed and, if necessary, amended at that point. Where the sections below describe how the Manager assesses sustainability risk, they describe that adopted approach rather than activity already carried on.

These disclosures accordingly cover Articles 3, 4 and 5 of SFDR at the level of the Manager, and Articles 6 and 7 of SFDR together with Articles 5, 6 and 7 of Regulation (EU) 2020/852 (the Taxonomy Regulation) at the level of the Fund.

2. Integration of sustainability risks — Article 3 SFDR

Sustainability risk means an environmental, social or governance event or condition which, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

The Manager does not pursue a sustainability objective and does not use sustainability criteria as an investment‑selection filter. It operates no exclusion list, screening process, minimum sustainability rating or other sustainability constraint, and maintains no dedicated sustainability function or personnel. Sustainability factors play no part in the Manager’s selection of service providers, its internal operations or its general conduct of business.

The Manager does, however, consider financially material sustainability risks within its general investment risk analysis. Before each investment, alongside credit, market, liquidity, interest rate, currency and counterparty risk, the Manager considers whether an environmental, social or governance event or condition affecting an issuer, its sector or its jurisdiction could have a material negative effect on the value of the instrument. That assessment draws on issuer disclosures, offering documentation, credit rating agency research and publicly available information on the issuer and its sector.

The distinction is between the integration of financially material sustainability risk, which the Manager practises, and a sustainable investment strategy, which the Manager does not pursue. Sustainability risk is one input among several and is not a determinative factor. No investment is made or declined on sustainability grounds alone. Where sustainability risk is identified as material to the value of an instrument, it is reflected in the Manager’s overall view of the risk and return of that instrument and, where appropriate, in the price at which the Manager is willing to transact.

Given the Manager’s size and the nature of the Fund’s strategy, this assessment forms part of the Manager’s general investment risk process rather than a separate sustainability framework.

3. No consideration of adverse sustainability impacts — Article 4 SFDR

The Manager does not consider the adverse impacts of its investment decisions on sustainability factors within the meaning of Article 4(1)(b) of SFDR. It has chosen not to operate a systematic process for identifying, prioritising, measuring and reporting such impacts at this time. Its reasons are set out below.

The Manager employs fewer than 500 persons and is therefore not required to publish the statement prescribed by Article 4(3) and (4) of SFDR. That threshold concerns the mandatory large‑entity statement only; it does not remove the obligation under Article 4(1)(b) to give clear reasons for the position taken, which the Manager discharges here.

Availability and comparability of data. The indicators prescribed in Annex I to Commission Delegated Regulation (EU) 2022/1288 require issuer‑level data which is not consistently reported by the high yield issuers, fund vehicles and derivative counterparties in which the Fund invests. Coverage across the Fund’s investable universe is incomplete, and estimates would form a substantial part of any figure the Manager could report. The Manager does not consider that reporting on that basis would give investors a reliable picture.

Proportionality. The Manager is a small entity with limited personnel and no dedicated sustainability function. Establishing and maintaining the data collection, due diligence, methodology and reporting processes contemplated by Article 4, to a standard the Manager could defend, would be disproportionate to its size, nature and scale and to the Fund’s investment strategy.

This position should not be read as a statement that the Fund’s investments have no adverse impacts on sustainability factors, or that such impacts could not in principle be measured. It reflects the Manager’s decision, on the grounds above, not to operate a reporting process for them at present.

The Manager records the rationale for this decision and reviews it at least annually. Should it decide to consider adverse sustainability impacts, it will publish a statement to that effect together with the date from which they are considered.

4. Remuneration policy — Article 5 SFDR

Remuneration of all relevant personnel of the Manager is fixed, determined by reference to role and prevailing market rates, with no variable, performance‑linked or discretionary component. No part of it is linked to the performance of an individual investment, to short‑term returns, or to any sustainability‑related target.

Because remuneration is fixed, the Manager’s arrangements create no incentive to take sustainability risk beyond its stated risk appetite, and none to disregard sustainability risk in the investment risk analysis described in section 2. The Manager accordingly considers its remuneration arrangements consistent with the integration of sustainability risks. It has not adopted a formal written remuneration policy; should it do so, it will disclose how that policy is consistent with the integration of sustainability risks.

5. Integration of sustainability risks in the Fund — Article 6 SFDR

Manner of integration. Sustainability risk is assessed as part of the investment risk analysis the Manager carries out before each investment on behalf of the Fund, in the manner described in section 2. The analysis considers whether an environmental, social or governance event or condition affecting an issuer, its sector or its jurisdiction could have a material negative effect on the value of the instrument — for example exposure to transition or physical climate risk, regulatory or litigation exposure, or weaknesses in governance bearing on an issuer’s ability to service its obligations.

Sustainability risk forms part of the Manager’s overall view of the risk and return of an instrument. It is not a principal driver of investment decisions and does not operate as a filter: no sustainability‑based exclusions, screens or minimum ratings are applied, and the Fund may hold instruments issued by entities with material exposure to sustainability risk.

Likely impact on returns. The Manager considers that sustainability risks could have a negative effect on the value of the Fund’s investments and therefore on its returns. In a portfolio of high yield fixed‑income instruments, the principal channels through which this could occur are:

  • a decline in the market value or credit quality of an issuer exposed to environmental regulation, carbon pricing or physical climate events;
  • losses arising from an issuer’s governance failures, including fraud, misreporting or sanctions exposure;
  • reduced liquidity in instruments issued by sectors subject to investor withdrawal on sustainability grounds, which may widen spreads or impair the Fund’s ability to realise a position;
  • impairment or default where an issuer’s business model is adversely affected by the transition to a lower‑carbon economy.

The Manager does not quantify the impact of sustainability risks on the Fund’s returns and does not consider that a reliable quantification is available. Investors should not assume that the Manager’s consideration of sustainability risk reduces the Fund’s exposure to it. The statement required under Article 7 of the Taxonomy Regulation is set out in section 7.

6. Adverse sustainability impacts at Fund level — Article 7 SFDR

The Fund does not consider the adverse impacts of its investment decisions on sustainability factors.

The reasons are those set out in section 3: the issuer‑level data required by the prescribed indicators is not consistently available or comparable across the instruments in which the Fund invests, and establishing a defensible reporting methodology would be disproportionate to the Manager’s size, nature and scale. As stated in that section, this is not a statement that the Fund’s investments have no adverse impacts on sustainability factors.

No information under Article 7(1)(a) of SFDR is therefore provided.

7. Taxonomy Regulation

The Fund does not have sustainable investment as its objective and does not promote environmental or social characteristics. The following statement is made under Article 7 of the Taxonomy Regulation:

The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.

The Fund has not assessed the proportion of its investments aligned with the EU Taxonomy and does not report a Taxonomy‑alignment percentage.

8. No sustainability claims

The Fund promotes no environmental or social characteristics within the meaning of Article 8 of SFDR and has no sustainable investment objective within the meaning of Article 9. As at the date of this document, and on the basis of the Manager’s review of the Fund’s investor‑facing materials, neither the Fund’s name nor its constitutional documents, offering documentation or any marketing communication makes a sustainability‑related claim, and the Manager has given no commitment to apply sustainability criteria to the Fund’s portfolio.

Investors should not rely on these disclosures as an indication that the Fund pursues any environmental or social outcome.

9. Review, amendment and contact

The Manager will review these disclosures on confirmation of its registration, at least annually thereafter, and whenever there is a material change to the Fund’s investment strategy or to the Manager’s approach to sustainability risk. Where a disclosure is amended, the Manager will publish a clear explanation of the amendment alongside the revised text, as required by Article 12 of SFDR.

Questions about these disclosures may be addressed to info@L2Mfund.com, or by post to L2M Investments S.à r.l., 2 Place de Strasbourg, L‑2526 Luxembourg.