Anchorage is an equal employment opportunity employer and does not discriminate against any employee, applicant, intern, or non-employee because of actual or perceived race, color, creed, traits historically associated with race, including, but not limited to, hair texture and protective hairstyles, religion, sex, sexual or reproductive health decisions, pregnancy status, childbirth and related medical conditions, breastfeeding, and conditions related to breastfeeding, national origin, mental or physical disability, age, veteran status, military status, immigration or citizenship status, marital status, familial status, caregiver status, sexual orientation, gender identity or expression, status as a victim of domestic violence, sex offense, or stalking, genetic information, or any other characteristic protected by applicable law (referred to as “protected status”).

All activities of Anchorage, including, but not limited to, recruiting and hiring, recruitment advertising, promotions, performance appraisals, training, job assignments, compensation, demotions, transfers, terminations (including layoffs), benefits, and other terms, conditions, and privileges of employment, are and will be administered on a non-discriminatory basis, consistent with all applicable federal, state, and local requirements.

Sustainability-related disclosures
As Anchorage Capital Advisors, L.P. and its relying advisors, (collectively, “Anchorage”) manages certain alternative investment funds (“AIFs”) registered for marketing under the Alternative Investment Fund Managers Directive (2011/61/EU) (the “AIFMD”) in one or more member states of the European Economic Area (“EEA”), Anchorage is required by the Sustainable Finance Disclosure Regulation (Regulation 2019/2088) (the “SFDR”) to make certain disclosures on its website, including information about Anchorage’s policies on the integration of sustainability risks into its investment decision-making process; its approach to principal adverse impacts on sustainability factors; and the consistency of its remuneration policies with the integration of sustainability risks. For these purposes, sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Article 3 SFDR – Policies on the integration of sustainability risks into the investment decision-making process
Anchorage recognizes that an environmental, social or governance event or condition, if it occurs, could cause a material negative impact on the value of an investment. As such, Anchorage believes sustainability risks should generally be part of its investment analysis and decision-making processes, and has an ESG Policy that sets out its approach with respect to sustainability risks.

Accordingly, where it is deemed appropriate by Anchorage’s investment team and in accordance with the ESG Policy, when considering a prospective investment, Anchorage will consider the potential impact of sustainability risks.

Sustainability risks consist of one category of risk among others taken into account by Anchorage. Anchorage’s level of consideration of sustainability risks will vary by investment due to factors including, among others, the type of investment, potential duration of the investment, available information, timing of an investment opportunity, and Anchorage’s ability to influence an outcome with respect to sustainability risks.

Anchorage is a signatory to the Principles for Responsible Investment (“PRI”). In signing the PRI, Anchorage commits, where consistent with its fiduciary responsibilities, to the implementation of the PRI’s Six Principles. These Principles set out actions that can support Anchorage’s consideration of sustainability risks in investment analysis and decision-making and portfolio management.

Article 4 SFDR – No consideration of sustainability adverse impacts
Anchorage does not currently consider principal adverse impacts of investment decisions on sustainability factors as distinct from the approach to sustainability risks as described above. Each AIF’s primary focus is set forth in such AIF’s offering document.

Article 5 SFDR – Consistency of remuneration policies
Anchorage’s remuneration practices are consistent with its approach to the integration of sustainability risks into the investment decision making process. As sustainability risks are a type of investment risk, Anchorage acknowledges that failure to consider such risks could have an adverse impact on the performance of investments and the performance of AIFs.

Anchorage generally awards fixed and variable remuneration to staff. Variable remuneration is generally awarded on a discretionary basis and takes into account the performance of an individual employee, the funds managed by Anchorage, and the overall financial performance of the Anchorage group. Accordingly, to the extent that sustainability risks have an adverse impact on performance of funds managed by Anchorage, this is likely to be reflected in the overall level of variable remuneration awarded to staff.