Octopus Energy Generation: investment adviser

OEGEN is a wholly owned subsidiary of Octopus Energy Fund Management Holdings Ltd whose ultimate owner is Octopus Energy Group Limited (“OEGL”). Advisory Services. OEGEN provides discretionary advisory and sub advisory services to private funds, professional, accredited, and institutional investors. These consist of pooled alternative investment funds, Separate Managed Accounts as well as one investment trust listed on the London Stock Exchange (singularly, the “Fund”; collectively, the “Funds”). Separate Managed Accounts are managed in accordance with the particular investment objectives, strategies, restrictions, and guidelines detailed in relevant agreements. Pooled investment funds are not tailored to the individualised needs of any particular investor. Each investor receives a complete set of offering materials with detailed information regarding investment objectives and investment style prior to investing. Assets under management. As of 31 March 2026, OEGEN has $11.7bn in discretionary and advisory assets under management. This is calculated as Gross Asset Value + Undrawn subscriptions of all mandates managed by the business.

We are permitted by advisory agreements related to pooled investment funds we manage to, at our sole discretion, waive, reduce or rebate all or a portion of our management and / or performance fees for the benefit of any limited partner. These fee waivers do not impact fees paid by any other investors in these pooled investment funds. Performance fees are typically based on a percentage (e.g. 5%) of distributions in excess of a specific real rate of return over a specified period. Generally, no performance fees are paid until clients have received back their invested capital plus a specific rate of return on that invested capital, adjusted for inflation. Details regarding this fee may be found in the offering materials for each Fund. Other costs involved. In addition to the investment manager fees shown above, expenses associated with making investments on behalf of the Funds will also be incurred. These fees

include: legal fees, accounting or audit services, insurance, interest or bank charges, taxation advisory or compliance services, and costs related to diligence or review of investments. For avoidance of doubt, these fees are payable directly by the Fund to third party service providers, not OEGEN.

We recognise the existence of performance-based fees has the potential to create an incentive for OEGEN to favour accounts paying higher fees. OEGEN seeks to address the potential for conflicts of interest in these matters with its allocation policy and allocation committee and the investment committee to ensure investment opportunities are allocated to Funds in accordance with each Fund’s investment guidelines and Governing Documents, as well as other factors that do not include the amount of performance-based compensation received by OEGEN. Our conflicts of interest policy outlines how conflicts are managed.

Origination. OEGEN has a dedicated team of over 40 people responsible for the originating and closing of investment opportunities across the United Kingdom, Europe, Asia and North America. The investment team constantly generates a pipeline of investment opportunities by (i) maintaining relationships and partnerships with asset owners, developers and M&A counterparties (ii) being visible as an active participant in renewable energy markets through industry press and thought leadership, and (iii) by being known by asset owners and advisers as a trusted, experienced counterparty that delivers on its promises. By being part of the broader OEGL, a global clean energy tech pioneer, we believe that we will have better access to projects that enable us to change the entire energy lifecycle and make every green electron matter, delivering the best outcomes for customers, investors, the environment and society. OEGEN’s affiliated entities also provide live insights into the energy transition propositions that customers are keen to buy, and OEGEN can then ensure we proactively target and back the platforms and infrastructure assets that deliver those customer needs. Investment screening. Each investment opportunity goes through a thorough and detailed due diligence process and the sites of all new investments are visited by an appropriate member of the team before investment. All deals are evaluated in the specific Fund model and then valued using detailed financial models. At the outset the risk objectives and constraints of the Fund are defined in-line with the Fund’s return objectives and any other applicable restrictions (for example a Fund may want a country specific investment mandate). Prior to the start of the investment process, it is confirmed during an allocations process that a potential opportunity adheres to the return and risk objectives of the Fund it will be allocated to. Investment process. The investment team own the identification, quantification, and mitigation of risks throughout the asset origination and investment process. Each team focused on a new investment includes a member of asset management and, where appropriate, construction teams. A team of specialist top tier advisors (legal, technical, market, insurance, tax and accounting) from our panel are engaged on each investment to assist the team in identifying and mitigating the risks of each investment opportunity. OEGEN has a robust investment approval process which is consistently applied across investment opportunities. The process is governed by the Investment Committee (“IC”). The investment process follows four stages: • •

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Strategy and Green Light Approval: Before entering a new market OEGEN undertakes a detailed market assessment which is presented to IC for Green Light Approval. Origination and Approval in Principle: Once market entry is approved, OEGEN originates assets through a number of defined strategies. After receiving Approval in Principle for an investment from IC, the investment team will appoint a range of advisers from our panel. Negotiation, due diligence, and Final Approval: A consistent and rigorous due diligence process is applied to each opportunity. Our experience enables us to identify key issues early and to focus due diligence on the areas that matter. This detailed due diligence process helps support an effective negotiation process. Our market knowledge and skills ensure an equitable share of risk and reward. Throughout this stage of the process, regular updates are provided to the IC.

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Execution and Pre-Completion Note: When a final investment decision has been received, the deal team negotiates the final terms of the transaction within the framework set out in the final investment decision and prepares the transaction for completion.

Where assets are sold, the divestment process and approval process is similar to the above. Investment specific risks are tracked and reported to the IC and relevant Fund board throughout the investment process. During the Approval in Principle, and Final Approval stage, of the investment process all identified and reported risks are approved (or declined as the case may be) by the IC before proceeding to close. Our experience as a manager usually means that material risks are identified at the Approval in Principle stage. Critically this enables the IC to make an early and informed view on whether it wants to pursue the transaction, avoiding material fund abort risk exposure because material diligence spend is only sanctioned at AIP stage. Post investment. Once an investment is completed the identified risks are input into the Fund risk register as part of the handover to the asset management/energy transition/development teams. From the point of handover these teams are responsible for owning and managing risk activities in relation to an investment. For construction or operational portfolio assets, each asset has a dedicated asset manager supported by specialist internal teams including, technical, legal, health and safety and finance. These teams are further supported by external consultants as necessary. Risk management Risk management is fully integrated into the full asset life cycle, from pre-investment screening, throughout the investment process and the day-to-day management post acquisition. The product heads are required to review and provide an opinion on every new investment paper submitted for their fund to IC. To manage risk, OEGEN applies one, or more, of four key principles: • • •

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Avoid: an informed decision not to become involved with a risk. e.g. implement fixed price power purchase agreements or decline investments with significant risks identified during due diligence Transfer: shift the risk to someone else, e.g. insuring, extended warranties, contractual guarantees and liquidated damages Mitigate: appropriate policies, processes, procedures to reduce either the likelihood of an occurrence or its consequence or both e.g. HSE, maintenance / testing of plant equipment, Power Purchase Agreements, protection in transaction documents via hold backs or deferred consideration, and Accept: an informed decision to accept risk, or the residual risk, having considered and/or implemented the aforementioned mitigants.

Risk of Loss An investment in any of the Funds managed by OEGEN involves a substantial degree of risk and should be considered only by prospective investors whose financial resources are sufficient to enable them to assume such risk (and the possible loss of some or all of their investment) and who have no immediate need for liquidity in their investment. Prospective investors should carefully evaluate the following risk factors associated with an investment in the Fund. These are not an exhaustive list of risks and prospective investors should make their own assessment of the risks and rewards of an investment in the Funds.

Concentration Risk

The Funds will concentrate the investments made by them in equity and/or debt instruments of companies or assets in the renewable energy industry and the investments are not broadly diversified. The investments may be subject to a variety of risks, not all of which can be foreseen or quantified, including operating, economic, environmental, commercial, regulatory, political and financial risks, and may be more susceptible to risks resulting from changes imposed by regulatory initiatives than investments of a more broadly diversified fund. Furthermore, to the extent that the capital raised is less than the targeted amount, the Funds may invest in fewer investments and thus be less diversified.

Leverage Risk

The use of debt to leverage the investments may increase exposure to adverse general economic conditions, significant increase in interest rates or a deterioration in the condition/performance of the investments that means that the Funds are unable to service its debt repayments when due. Although the use of leverage may enhance returns on equity, leverage also increases the risk of loss since borrowings represent a prior claim on assets and require fixed payments, regardless of the profitability of particular investments encumbered by such borrowings. In the case of default under any borrowing, some or all of the assets of the borrower could be taken by lenders in payment of their claims. As a general matter, the presence of leverage can accelerate losses.

Availability and The ability of the Funds to make an investment or to refinance an investment Pricing of Debt may be dependent upon the availability and pricing of debt finance from thirdFinance party lenders. There can be no assurance that such debt finance will be available or available on terms that will enable the Funds to generate expected rates of return. Senior debt will typically be secured on the assets of a project or an investment and will contain covenants and other restrictions related to payment and default and which may give senior lenders preferred rights over those of the Funds. Currency Risk

The Funds are denominated in and the base currency of the Funds are either GBP or EUR. The revenues of some Investments may be denominated in other local currencies, such that the Fund may be exposed to currency rate movements. Whilst OEGEN may enter into hedging arrangements to mitigate this risk to some extent, it is not obliged to do so and there can be no assurance that such arrangements can or will be entered into or that they will be sufficient to cover such risk.

Valuation Risks

The Funds rely upon OEGEN on a quarterly basis for valuation of the investments and the determination of the Net Asset Value (“NAV”, calculated as the aggregate fair market value of the investments less the Funds’ indebtedness and other liabilities) which will be reviewed by OEGEN’s valuation committee in accordance with the Fund's Valuation Policy. The Investments in many cases will be difficult to value due to various factors, including the nature of infrastructure assets, the absence of readily ascertainable market values and comparables, and limited sources of useful valuation information. In addition, the valuation of an investment may not always be consistent with, and therefore may be higher than, the price at which the Investment could be sold on any particular valuation date. Such valuations will be subject to inherent uncertainty, and will be made under a number of assumptions which may not ultimately be realised. There can be no assurance that the valuations will in fact represent the actual value of the Investments or

the amounts that could at such time or may ultimately be realised with respect to the Investments. Counterparty Risk

There is a risk, particularly given the current economic instability that counterparties may default on their contractual obligations to the Funds or the investments. Any such counterparty default would likely have an adverse effect on the value of the Investments and on the returns to the investors.

Inflation

Depending on the inflation assumptions relating to anticipated cash flows from assets, returns from the Investment may vary from those projected as a result of changes in the rate of inflation. Unanticipated inflation in the cost of labour, resources and other inputs can also adversely affect the returns associated with the Investment. Movements in interest rates may also affect the appropriate discount rate to be used to value the Investment resulting in fluctuations in valuations. While inflation risk can generally be reduced through hedging, there is a risk of residual exposure. There is no certainty that any hedging techniques employed will successfully mitigate against the risk of inflation (or that hedging will be available on acceptable terms).

Renewable Energy Projects

Investments in renewable energy projects and infrastructure expose the Fund to numerous risks, including but not limited to construction, technical environmental, regulatory, permitting, commissioning, start-up, operating, economic, commercial, political, electricity grid, power market and financial risks. This will involve risks of failure to obtain or substantial delays in obtaining: (i) regulatory, environmental or other approvals, permits or land rights; (ii) financing and refinancing; (iii) suitable equipment supply, operating and power off-take contracts; and (iv) grid connections and available grid capacity. Moreover, renewable energy assets are subject to energy regulation and require governmental licenses and approvals for their operation as well as operating in highly regulated power markets, which are subject to periodic regulatory changes. The failure to obtain, maintain or comply with the approvals and permits relating to the Investments, and the resulting inability to complete the projects, or be able to general power from them, in addition to the risk of additional costs, fines and penalties, could materially and adversely affect the investee companies' return from the assets. Renewable energy projects also require significant expenditure to develop, build and commission the projects before the assets begin to generate income, as well as on-going, long-term expenditure on operating and maintenance to enable projects to reliably generate expected levels of income.

Decommissioning Risks

After completion of the operational phase, a renewable energy asset may be dismantled and the land restored to its original condition. So far, there is limited information and experience with respect to the decommissioning and dismantling of power plants, facilities and/or infrastructures, especially for renewable energy. In addition, such dismantling, disposal and restoration may result in additional unforeseen costs to be borne by the renewable energy asset. If any of these risks materialise, the performance of the relevant renewable energy asset may be adversely affected which in turn may have a material adverse effect on the Fund's return.

Risks Related to An investment in the Fund is subject to certain risks associated with the the Ownership of ownership of renewable energy infrastructure and renewable energy Renewable infrastructure related assets in general, including: the burdens of ownership of renewable energy infrastructure; local, national and international economic conditions; the supply and demand for services from and access to renewable

Energy Infrastructure

energy infrastructure; the financial condition of users and suppliers of renewable energy infrastructure assets; changes in interest rates and the availability of funds which may render the purchase, sale or refinancing of renewable energy infrastructure assets difficult or impracticable; changes in laws, including environmental law, and regulations, and planning laws and other governmental rules; environmental claims arising in respect of renewable energy infrastructure acquired with undisclosed or unknown environmental problems or as to which inadequate reserves have been established; changes in energy prices; changes in fiscal and monetary policies; uninsured casualties; under-insured or uninsurable losses, such as force majeure events and terrorist acts; and other factors which are beyond the reasonable control of the Fund. Many of these factors could cause fluctuations in usage, expenses and revenues, causing the value of the Investments to decline and to affect the Fund’s returns negatively.

Power Purchase Companies engaging in renewable energy projects will often enter into PPAs Agreement for electricity offtake. Payments by power purchasers to such projects ("PPA") Risk pursuant to their respective PPAs may provide the majority of such companies' or projects' cash flows. There can be no assurance that any or all of the power purchasers will fulfil their obligations under their PPAs or that a power purchaser will not become bankrupt, or that upon any such bankruptcy its obligations under its respective PPA will not be rejected by a bankruptcy trustee. There are additional risks relating to the PPAs, including the occurrence of events beyond the control of a power purchaser that may excuse it from its obligation to accept and pay for delivery of energy generated by a company or project. The failure of a power purchaser to fulfil its obligations under any PPA or the termination of any PPA may have a material adverse effect on an investee company or project. Environmental Risks

Large scale infrastructure projects in which the Fund intends to invest will be major factors in their local environments and may have a significant impact on those environments, or be particularly susceptible to events or changes in those environments or to requirements of political or administrative authorities in respect of their environmental impact. An owner or operator of an infrastructure asset may be liable for past, present and future damages (whenever caused) by environmental pollutants located on or emitted from or otherwise attributable to the asset, as well as for the costs of remediation and, in some circumstances, fines or other penalties. These liabilities may exceed the value of the infrastructure asset and may result in claims against the owner or operator that would result in the loss of other assets of the owner or operator, or loss of a licence, concession or contract on which an investee company is dependent. Environmental liabilities may arise as a result of a large number of factors, including changes in laws or regulations and the existence of conditions that were unknown or unanticipated at the time of acquisition or operation.

Operational and Investments in infrastructure assets may be subject to operating and technical Technical Risks risks, including the risk of mechanical breakdown, spare parts shortages, failure to perform according to design specifications, labour strikes, labour disputes, work stoppages, grid outages and other work interruptions, and other unanticipated events which adversely affect operations. While the Fund generally expects to seek investments in which creditworthy and appropriately bonded and insured third parties bear most of these risks, there can be no assurance that any or all such risks can be mitigated or that such parties, if present, will perform their obligations or that insurance will be

available on commercially reasonable terms. An operating failure may lead to fines, expropriation, termination or loss of a licence, concession or contract on which an investee company is dependent. In addition, the long-term profitability of infrastructure assets is partly dependent upon the efficient operation and maintenance of the assets. Inefficient operations and maintenance, or limitations in the skills, experience or resources of operating companies may reduce returns to Investors. While the OEGEN may seek to influence the strategic management of such companies, it is not expected to be in a position to control outcomes and, as a result, the operational capacity of the management of an investee company may impact the value or returns from the Fund. Health and Safety The physical location, construction, maintenance and operation of renewable Risks energy assets pose health and safety risks to those involved or in the vicinity of the asset. Construction and maintenance of renewable energy assets may result in bodily injury, industrial accidents, and even death. If an accident were to occur in relation to one or more of the Fund's portfolio of renewable energy assets, the Fund could be liable for damages or compensation to the extent such loss is not covered under existing insurance policies. Health and safety concerns and/or accidents could also result in the suspension (either temporary or long-term) of operations of a renewable energy asset which will reduce the revenue of the Fund from that renewable energy asset. Liability for damages or compensation in relation to accidents and/or suspension of operations could have a material adverse effect on the Fund. Furthermore, the renewables sector is, as all other sectors, subject to human rights abuse that needs to be mitigated. This exposes the Fund to reputational risks as well as risks of being subject to fines if supply chains are unable to meet labour standards. Technology

There are a variety of technology risks in renewable power, projects, including the risk of new technology failing to work reliably, not being available for the entire forecast period for their intended use or not achieving or maintaining the predicted efficiency, as well as the risk that subsequent projects will be more efficient and place existing projects at a competitive disadvantage. A notable feature of the renewables market has been the economic weakness of technology suppliers, particularly in the solar panel market, such that they may be poor credit risks and may not be able to satisfy claims on equipment warranties. A key feature of the renewables market has been rapidly declining equipment costs but there is no guarantee that this will continue. Whilst the Fund will seek to mainly invest in proven technologies, there is a risk that there may be manufacturing or other defects in the technology or that the technology when applied to the specific renewable resource may not be adequate.

Construction

The Fund will invest in renewable power projects prior to, at the time that they commence and during construction. Investing in construction-stage projects entails risks that the project may not be completed on time or on budget and to the agreed specifications. Delays in construction can result in increased costs for the renewable power projects and higher capitalised interest charges for interest accrued during construction.

Development Activities

The Fund may invest in development projects and companies. Such investments may involve more risk, including binary risks, than investments in which no development is required. Development projects do not generate

operating revenue but will incur costs during the period between acquisition of the asset and completion of the development and any delay in completing the development of the asset may result in increased interest and costs and the potential loss of previously identified income. If the Fund undertakes any development activities, it may hire skilled third-party contractors to provide planning and permitting, design, construction, engineering and various other services. Such contractors may become insolvent, causing cost overruns, program delays and/or the acceptance of riskier contractor covenants. Investee companies may also be in an early stage of development, may not have a proven operating history, may be reliant on developing unproven technology, may be operating at a loss or have significant variations in operating results, may be engaged in a rapidly changing business with products subject to a substantial risk of obsolescence, may require substantial additional capital to support their operations, to finance expansion or to maintain their competitive position, or may otherwise have a weak financial condition or weak management. In addition, these investee company may face intense competitive pressures, including competition from companies with greater financial resources, more extensive development, manufacturing, marketing and other capabilities, and a large number of qualified managerial and technical personnel. The investee company may also incur leverage that may have important adverse consequences. For example, Investee companies may be subject to restrictive financial and operating covenants, and leverage may impair their ability to respond to changing business and economic conditions and to business opportunities. Effects of Ongoing Changes in the Electricity Supply Industry

Certain Investments may be in projects and investee companies directly related to electric utilities and, in most cases, such utilities are the ultimate customers for purchasing electricity from renewable energy projects. The operation of renewable energy projects often takes place at sites that are remote from the electrical transmission and distribution system, frequently requiring grid interconnection and reinforcement. In many markets, the electricity supply industry is experiencing increasing competitive pressures, primarily in wholesale markets, as a result of consumer demands, technological advances, greater availability of natural gas and other factors. There can be no assurance that: (i) existing regulations applicable to electricity utilities will not be revised or reinterpreted, especially those imposing mandates upon them to purchase renewable electricity; (ii) new laws and regulations will not be adopted or become applicable to electricity utilities companies; (iii) the technology and equipment selected by such utilities to comply with current and future regulatory requirements will not change materially over time; (iv) the required grid interconnection and reinforcement to permit uninterrupted generation will be undertaken in a timely manner at reasonable cost; or (v) such utilities’ business and financial condition will not be materially and adversely affected by such future changes in, or reinterpretation of, laws and regulations (including the possible loss of exemptions from laws and regulations) or any failure to comply with such current and future laws and regulations.

Risks of Investing in New or Emerging Technologies

The Fund may make Investments into new and emerging technologies such as energy storage. These Investments, in addition to having increased technology risks, will also be exposed to several of the risk factors highlighted above, all of which could negatively impact the performance of an Investment. The potential risks that these types of Investments are exposed to include,

but are not limited to, grid, operating, power prices, ESG, construction and development. Risks of the The energy transition is characterised by rapid fundamental change and new Energy Transition technological developments. These characteristics create inherent uncertainty and volatility. There is a risk that new developments (for example, changes in regulation) may negatively impact the performance of existing Investments made by the Fund. Government Support

Renewable energy projects currently enjoy wide support from state and local governments and regulatory agencies but there is no assurance that such support will continue in the future and any reduction or elimination of governmental support will have an adverse effect. Certain companies operating in the climate change solutions sector are, to an extent, dependent upon governments continuing to support international and national commitments to reduce the level of greenhouse gas emissions, and to promote low carbon technology and environmental infrastructure development. Accordingly, the success of the Fund may be affected by changes in legislation, environmental policies and/or the removal or change of support measures for the sector, such as in relation to tariffs and subsidies, which may even have retroactive effect. The economic viability of a particular Investment may depend on certain taxation, financial and regulatory conditions in a particular jurisdiction. Changes in these conditions, and the imposition of additional restrictions on currency conversion and overseas remittances, may adversely affect the marketability and financial performance of these Investments, which in turn may affect the returns the Fund receives from such Investments. In addition, the Fund may invest in investee companies that are remunerated by government support schemes. Any agreement with governmental authorities may contain clauses more favourable to the governmental counterparty than a typical commercial contract and may restrict the Fund’s ability to operate the investee company in a way that maximises cash flows and profitability.

Uncertain Political Environment

The current global political climate is one of uncertainty. Prior acts of terrorism, the threat of additional terrorist strikes and the fear of prolonged global conflict have exacerbated volatility in the financial markets and can cause consumer, corporate and financial confidence to weaken, increasing the risk of a "selfreinforcing" economic downturn. A climate of uncertainty may reduce the availability of potential investment opportunities for the Fund and increases the difficulty of modelling market conditions, reducing the accuracy of the financial projections. Furthermore, such uncertainty may have an adverse effect upon the value of the Investments.

Interest Rates, Inflation and Other Financial Risks

General movements in local and international stock markets, prevailing economic conditions, investor sentiment, inflation rates, monetary policy and interest rates could have a substantial negative impact on the value of the Investments and investment opportunities in general. If an Investment is incorrectly valued by the financial markets, the disposal opportunities available for that Investment may, in the case of an undervaluation, be unattractive or, in the case of an overvaluation, be limited.

Climate Change

Climate change presents significant challenges for society and the global economy. Climate change could have a financial impact on real estate assets as a result of both physical and transitional risks. Physical risks, such as extreme weather events, can lead to a devaluation of assets and reduced opportunities for sale of such assets. They can result in an increase in the costs of owning or

operating assets including higher insurance premiums, financing costs and capital expenditure. Transitional risks could mean that certain geographic locations or markets become less attractive as a result of climate change.

Cybersecurity With the increasing use of technology in connection with the Fund’s operations, Risk the Fund will face greater operational, information security and related risks through cybersecurity breaches. A breach in cybersecurity refers to either an intentional or unintentional event that may cause the Fund to lose proprietary information, suffer data corruption, and/or lose operational capacity. Such events could cause the Fund to incur regulatory penalties, additional compliance costs associated with corrective measures, and/or financial loss. Such events also may cause disruptions to the Fund’s business operations, potentially resulting in impediments to trading and the inability of Investors to transact business, among other things. Cybersecurity threats may result from unauthorized access to the Fund's digital information systems (e.g., through "hacking" or malicious software coding), and may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users). In addition, because the Fund works closely with third-party service providers (e.g., the Fund’s administrator), cybersecurity breaches at such third-party service providers may subject the Fund to the same risks associated with direct cybersecurity breaches. The Fund may experience investment losses in the event of cybersecurity breaches at any of the Investments. While the Fund has established business continuity plans in the event of, and implemented risk management and information security systems and software designed to prevent, a cybersecurity breach, there are inherent limitations in such plans and systems and there can be no assurance that such measures will succeed. Renewable Energy Sources

Renewable energy sources tend to be a more expensive means of electricity production than fossil fuel based production methods and often depend on supportive legal and regulatory environment to remain competitive with these conventional methods. Any change to the legal or regulatory environments in countries in which the Fund’s energy assets are situated may affect the Fund’s returns from these assets.

Permits

The Fund may invest in jurisdictions which require authorisation for environmental aspects of renewable energy and environmental infrastructure projects. It may not be possible to construct and operate renewable energy and environmental infrastructure projects without receiving the environmental authorisations required by local legislation. OEGEN will look to secure all necessary environmental authorizations, but it can make no guarantee that it will successfully do so. In some jurisdictions, retroactive changes to legislation of this type may be enforced, diminishing the ability of a project to continue operating at projected capacity. Interruptions of, or changes to, projected operations may negatively affect the value of an Investment and consequently the returns of the Fund.

Regulatory Risk

The energy sector is highly regulated. Companies operating in the energy sector are subject to significant regulation of nearly every aspect of their operations by national and local governmental agencies. Examples of government regulations which impact companies operating in the energy sector include planning laws, regulation of the maintenance and operation of facilities, environmental regulation, safety regulation, labour regulation, trade regulation and the regulation of the prices charged for products and services. Compliance with these

regulations is enforced by numerous governmental agencies and authorities through administrative, civil and criminal penalties. Stricter laws and regulations or stricter enforcement policies with respect to existing regulations will likely increase the costs of regulatory compliance and could have an adverse effect on the financial performance of companies operating in the energy sector. Companies operating in the energy sector may be adversely affected by additional regulatory requirements enacted in response to environmental disasters, which may impose additional costs or limit certain operations by companies operating in various sectors. There can be no guarantee that all costs and risks regarding compliance with environmental laws and regulations can be identified. Regulatory Changes

An investee company could be materially and adversely affected as a result of statutory or regulatory changes or changes in judicial or administrative interpretations of existing laws and regulations that impose more comprehensive or stringent requirements on such company or such company's industry generally. For example, environmental laws regulating infrastructure projects could become more restrictive, as governments aim to limit the impact of infrastructure on local wildlife and natural resources and reduce the emissions of greenhouse gases or other pollutants including but not limited to particulate matter, SO2 and NOx. Such changes could adversely affect the performance of one or more of the Investments. Moreover, additional regulatory approvals, including without limitation, renewals, extensions, transfers, assignments, reissuances or similar actions, may become applicable in the future due to a change in laws and regulations, a change in the companies' customer(s), or for other reasons. Changes in laws and regulations could result in increased compliance costs, additional capital expenditures or additional potential liabilities and such revisions could alter the competitive landscape and/or the nature of the markets in which the investee company operates in a material and adverse manner to such investee company.

OEGEN has policies and procedures reasonable designed to prevent, limit or mitigate conflicts of interest that can arise with our relationships with related persons. Pooled investment vehicles: OEGEN is affiliated to the General Partners of the Funds. These are wholly owned subsidiaries of OEGEN. We do not generally receive duplicative advisory fees for investment advisory services provided to the Funds and the activities of the General Partners. Management persons: OEGEN may have common management and officers with related persons. Other considerations: We also share office facilities with our related persons and rely on them for certain corporate functions, including finance, information technology, human resources and general administrative support. Conflicts of interest: Arrangements between OEGEN and related persons can present or appear to present a conflict of interest with our clients. Policies and procedures have been adopted to appropriately manage such conflicts of interest. This include discussing the conflict with clients if we feel it is in their interest to proceed with a matter despite the conflict of interest.

In order to achieve the best possible result on a consistent basis, we will take into consideration a range of different factors to determine the manner in which an order will be executed, including: • Price • Size and nature of the asset/instrument • Likelihood of execution • Speed, meaning the time taken to execute an order • Likelihood of settlement, meaning likelihood of the completion of the transaction • Costs, such as fees, commissions • Any other factors relevant to the efficient execution of the transaction.

The asset level valuations are approved by the Octopus AIF Management Valuations Committee, all members of which are independent of OEGEN. On a quarterly basis, the Fund administrator will determine the fair value of the investments held by the Fund, the NAV of the Fund, and where relevant the NAV per unit/share, the number of units/shares held by the relevant investor and the aggregate value of the relevant investor's units, based on such NAV per unit/share, in each in accordance with the Fund’s valuation policy as set out in detail in the Fund documents. Unless stated otherwise in the fund documents, every 12 months, a third-party valuator will review the valuation provided and offer an independent opinion on the value of the Fund's investments. Investor reports. A quarterly investor report will be provided usually within forty-five (45) business days of each valuation date. These are provided digitally through our customer portal, where investors can find the published reports and fund documents. Investor reports typically contain a manager statement, market outlook, fund metrics, valuations, asset information, operational performance, health and safety data, environmental and social governance (“ESG”) matters and information on offtake arrangements. In addition, the Fund administrator will provide investors with an unaudited report of the performance of Fund such quarter. An annual report is provided usually within 120 calendar days of the Fund's year end which includes a set of audited accounts and a report of the auditors in respect of the previous financial year. Annual reports usually focus on impact case studies to bring to life investments.

A corporation, partnership, trust, or other legal entity may need to provide other information such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement. We may be required to disclose this information pursuant to applicable laws,

rules, or regulations, but it will otherwise be retained in confidence according to our privacy policy. Privacy policy. OEGEN’s Privacy Policy is available upon request and on our website.