European Overview

United Kingdom

The Blackstone Group International Partners LLP

The Blackstone Group International Partners LLP (“BGIP”) is a limited liability partnership registered in England and Wales under number OC352581 and is authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom (firm reference number 520839). BGIP is an indirect subsidiary of Blackstone Inc. (“Blackstone”), a publicly held U.S. investment and advisory firm. BGIP acts as a sub-advisor to its Blackstone US affiliates in relation to the investment and re-investment of EMEA based assets of Blackstone funds as well as arranging transactions to be entered into by or on behalf of Blackstone funds. BGIP also acts as a distributor of Blackstone funds in certain EMEA jurisdictions. BGIP’s principal place of business is in London and it has a Representative Office in Abu Dhabi Global Market and Paris. BGIP has its registered office at 40 Berkeley Square, London, W1J 5AL.

Financial Ombudsman Service

If you are an eligible complainant under the FCA Rules, you may be entitled to refer a complaint against BGIP to the Financial Ombudsman Service (“FOS”). Details about FOS are available on its website at: http://www.financial-ombudsman.org.uk/.  FOS may be contacted by telephone on 0800 023 4567 or on +44 20 7964 0500 (for calls from outside the UK), by email at [email protected], or by post at The Financial Ombudsman Service, Exchange Tower, London, E14 9SR.

Complaints Handling Policy

The Complaints Handling Policy for BGIP is available on the link below:

BGIP Complaints Handling Policy

UK Modern Slavery Act

BGIP’s UK Modern Slavery Act Transparency Statement for the financial year ending 31 March 2022 is available on the link below::

Modern Slavery Act Transparency Statement

UK Gender Pay Gap Reports

BGIP’s UK Gender Pay Gap Report disclosures are available on the links below:

2021 Gender Pay Gap Report

2020 Gender Pay Gap Report

2019 Gender Pay Gap Report

2018 Gender Pay Gap Report

UK Tax Strategy

Pursuant to UK legislation introduced as part of Schedule 19 of the Finance Act 2016, we are required to publish our UK business’s tax strategy. The tax strategy described in this publication relates to the year ended 31 December 2022 and applies to all UK entities which are consolidated for financial reporting purposes with Blackstone.

Blackstone UK Tax Strategy

Investment Firms Prudential Regime Disclosures (“IFPR”)

BGIP’s Investment Firms Prudential Regime disclosures are available on the link below:

2022 IFPR Disclosures

Ireland

Blackstone Ireland Limited

Blackstone Ireland Limited (“BIL”), is authorized as an investment firm under MiFID and regulated by the Central Bank of Ireland (“CBI”). BIL’s principal activity is the provision of management and advisory services to certain collateralized loan obligations and sub-advisory services to certain affiliates. BIL, its 100% subsidiary, Blackstone Ireland Fund Management Limited (“BIFM”), and its EU parent financial holding company, Blackstone / GSO Debt Funds Europe (Luxembourg) S.à.r.l (together with BIL and BIFM, the “DFE Group”), are ultimately owned by Blackstone.

European Union Sustainable Finance Disclosure Regulation

The European Union Sustainable Finance Disclosure Regulation (“SFDR”) defines “sustainability risks” as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment. Blackstone Ireland Limited (the “firm”) (and/or its delegate) has integrated sustainability risks, as a sub-set of risks generally that could cause an actual or potential material negative impact on the value of an investment, as part of its investment decision-making process for it clients.  If appropriate for an investment, the firm (or its delegate) may conduct sustainability risk-related due diligence and/or take steps to mitigate sustainability risks and preserve the value of the investment. Further information on the manner in which sustainability risks are integrated into investment decisions, including any relevant policies, is available to clients upon request from the firm.  Notwithstanding the foregoing, sustainability risks will not be relevant to certain non-core activities undertaken by the firm (for example, hedging).

The firm’s remuneration policy takes into account compliance with its policies/procedures related to the integration of sustainability risks in its investment decision making process.

No consideration of adverse impacts of investment decisions on sustainability factors

BIL does not consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the Sustainable Finance Disclosure Regulation (“SFDR”). BIL does not currently do so because, among other reasons, the European Commission has requested advice from the European Supervisory Authorities (“ESAs”) on (1) streamlining and developing further the regulatory framework, (2) potentially extending the lists of universal indicators for PAIs, and (3) refining the content of all the PAI indicators and their respective definitions, applicable methodologies, metrics and presentation. In addition, the ESAs have sought legal guidance from the European Commission on what it means to ‘consider’ PAIs. BIL will re-consider the approach once there is more regulatory certainty.

Although BIL does not consider the PAIs within the meaning of Article 4(1)(a) SFDR, the PAI regime identifies numerous metrics such as green-house gas emissions, carbon footprint and board gender diversity. Where relevant to a strategy and product, BIL may choose to provide to its investors reporting against similar or certain of these metrics.

Blackstone’s approach to ESG. Blackstone Inc. (together with its affiliates, “Blackstone”) views ESG principles as crucial to developing strong, resilient companies that deliver value for our investors and has long sought to lead by example, such as by increasing the use of clean energy across our corporate offices and recruiting and fostering diverse talent through active affinity networks such as the Women’s Initiative, Diverse Professionals Network, Veterans Network and OUT Blackstone.

Blackstone considers its existing due diligence process and wider environmental, social and governance (“ESG”) framework to be appropriate and proportionate to its investment strategy, and that of the underlying products. We maintain an ESG policy which governs our approach to integrating ESG into our investment process. As part of the firmwide ESG policy, we have identified three priority areas that we believe can most affect our ability to build strong companies of enduring value: climate change mitigation, resilience and adaption; diversity, equity and inclusion and good governance. Blackstone’s ESG policy sets out how these areas are integrated into our investment decisions. Where appropriate, our business units also maintain their own individual ESG policies, which are aligned with the firmwide policy and reflect the unique factors applicable to their respective investment strategies. For more information, see the firmwide ESG policy.

Complaints Handling Policy

The Complaints Handling Policy for BIL and BIFM is available on the link below:

Ireland Complaints Handling Policy

BIL RTS-28 Best Execution Reports

BIL MIFID II – RTS 28 Article 3(1) Report – 2021

BIL MIFD II_RTS 28 Article 3(3) Report 2021_Currency Derivatives

BIL MIFD II_RTS 28 Article 3(3) Report 2021_Debt Instruments

BIL MIFD II_RTS 28 Article 3(3) Report 2021_Structured Finance Instruments

BIL MIFID II – RTS 28 Article 3(1) Report – 2020

BIL MIFD II_RTS 28 Article 3(3) Report 2020_Currency Derivatives

BIL MIFD II_RTS 28 Article 3(3) Report 2020_Debt Instruments

BIL MIFD II_RTS 28 Article 3(3) Report 2020_Structured Finance Instruments

Blackstone Ireland Fund Management Limited

BIFM is an approved Alternative Investment Fund Manager under the European Alternative Investment Fund Managers Directive (the “AIFMD”). BIFM provides investment management functions including portfolio management, risk management, administration, marketing and related activities to its alternative investment funds in accordance with AIFMD and the conditions imposed by the CBI as set out in the CBI’s alternative investment fund rulebook.

European Union Sustainable Finance Disclosure Regulation

The European Union Sustainable Finance Disclosure Regulation (“SFDR”) defines “sustainability risks” as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment. BIFM (and/or its delegate) has integrated sustainability risks, as a sub-set of risks generally that could cause an actual or potential material negative impact on the value of an investment, as part of its investment decision-making process for funds. If appropriate for an investment, BIFM (or its delegate) may conduct sustainability risk-related due diligence and/or take steps to mitigate sustainability risks and preserve the value of the investment. Further information on the manner in which sustainability risks are integrated into investment decisions, including any relevant policies, is available to investors upon request from BIFM. Notwithstanding the foregoing, sustainability risks will not be relevant to certain non-core activities undertaken by funds (for example, hedging).

BIFM’s remuneration policy takes into account compliance with its policies/procedures related to the integration of sustainability risks in its investment decision making process.

No consideration of adverse impacts of investment decisions on sustainability factors

BIFM does not consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the Sustainable Finance Disclosure Regulation (“SFDR”). BIFM does not currently do so because, among other reasons, the European Commission has requested advice from the European Supervisory Authorities (“ESAs”) on (1) streamlining and developing further the regulatory framework, (2) potentially extending the lists of universal indicators for PAIs, and (3) refining the content of all the PAI indicators and their respective definitions, applicable methodologies, metrics and presentation. In addition, the ESAs have sought legal guidance from the European Commission on what it means to ‘consider’ PAIs. BIFM will re-consider the approach once there is more regulatory certainty.

Although BIFM does not consider the PAIs within the meaning of Article 4(1)(a) SFDR, the PAI regime identifies numerous metrics such as green-house gas emissions, carbon footprint and board gender diversity. Where relevant to a strategy and product, BIFM may choose to provide to its investors reporting against similar or certain of these metrics.

Blackstone’s approach to ESG. Blackstone Inc. (together with its affiliates, “Blackstone”) views ESG principles as crucial to developing strong, resilient companies that deliver value for our investors and has long sought to lead by example, such as by increasing the use of clean energy across our corporate offices and recruiting and fostering diverse talent through active affinity networks such as the Women’s Initiative, Diverse Professionals Network, Veterans Network and OUT Blackstone.

Blackstone considers its existing due diligence process and wider environmental, social and governance (“ESG”) framework to be appropriate and proportionate to its investment strategy, and that of the underlying products. We maintain an ESG policy which governs our approach to integrating ESG into our investment process. As part of the firmwide ESG policy, we have identified three priority areas that we believe can most affect our ability to build strong companies of enduring value: climate change mitigation, resilience and adaption; diversity, equity and inclusion and good governance. Blackstone’s ESG policy sets out how these areas are integrated into our investment decisions. Where appropriate, our business units also maintain their own individual ESG policies, which are aligned with the firmwide policy and reflect the unique factors applicable to their respective investment strategies. For more information, see the firmwide ESG policy.

For further details regarding DCI – SCS Enhanced High Yield Corporate Credit Fund and DCI – SCS Enhanced High Yield Corporate Credit Feeder Fund please refer to https://www.bxaccess.com/

DFE Group Pillar 3 Disclosure

The Pillar 3 disclosure for the DFE Group is available on the link below:

DFE Group – Pillar 3 disclosure

Shareholders Rights Directive II Disclosure

Article 3(g) of Directive 2007/36/EC as amended by Directive (EU) 2017/828 (together with the relevant national implementing regulations, the “SRD”) requires asset managers to adopt on a “comply or explain” basis an engagement policy describing how an asset manager integrates in its investment strategy shareholder engagement relating to companies that have a registered office in the EU and are listed on EU regulated markets (“EU investee companies”). BIL and BIFM are asset managers for the purposes of the SRD. Neither asset manager actively invests as a material part of its investment strategy in the shares of EU investee companies. Generally, shares in EU investee companies are expected to be held as an investment ancillary to, or as a result of, a credit investment. On this basis, each asset manager has determined that it is not appropriate to adopt an engagement policy for the purposes of the SRD. However, you may wish to refer to Part 2A of the Form ADV applicable to the asset managers and certain of their affiliates which provides an overview of their business, certain practices of the asset managers, potential material conflicts that may arise and key potential investment risks:

https://www.adviserinfo.sec.gov/IAPD/Content/Common/crd_iapd_Brochure.aspx?BRCHR_VRSN_ID=583653

Luxembourg

Blackstone Europe Fund Management S.à r.l.

Blackstone Europe Fund Management S.à r.l. (“BEFM”) is an approved Alternative Investment Fund Manager under AIFMD. BEFM provides investment management functions including portfolio management, risk management, administration, marketing and related activities to its alternative investment funds in accordance with AIFMD and the conditions imposed by the Commission de Surveillance du Secteur Financier (“CSSF”). BEFM also provides the services of (a) management of portfolios of investments on a discretionary client-by-client basis, (b) investment advice and (c) reception and transmission of orders in relation to financial instruments in accordance with AIFMD, applicable MiFID rules and the conditions imposed by the CSSF. BEFM may rely on some of these services to promote Blackstone funds to professional clients as defined under MiFID in certain EEA countries.

European Union Sustainable Finance Disclosure Regulation

The European Union Sustainable Finance Disclosure Regulation (“SFDR”) defines “sustainability risks” as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment. BEFM (and/or its delegate) has integrated sustainability risks, as a sub-set of risks generally that could cause an actual or potential material negative impact on the value of an investment, as part of its investment decision-making process for funds. If appropriate for an investment, BEFM (or its delegate) may conduct sustainability risk-related due diligence and/or take steps to mitigate sustainability risks and preserve the value of the investment. Further information on the manner in which sustainability risks are integrated into investment decisions, including any relevant policies, is available to investors at BEFM’s registered office. Notwithstanding the foregoing, sustainability risks will not be relevant to certain non-core activities undertaken by funds (for example, hedging).

BEFM’s remuneration policy takes into account compliance with its policies/procedures related to the integration of sustainability risks in its investment decision making process.

No consideration of adverse impacts of investment decisions on sustainability factors

BEFM does not consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the Sustainable Finance Disclosure Regulation (“SFDR”). BEFM does not currently do so because, among other reasons, the European Commission has requested advice from the European Supervisory Authorities (“ESAs”) on (1) streamlining and developing further the regulatory framework, (2) potentially extending the lists of universal indicators for PAIs, and (3) refining the content of all the PAI indicators and their respective definitions, applicable methodologies, metrics and presentation. In addition, the ESAs have sought legal guidance from the European Commission on what it means to ‘consider’ PAIs.  BEFM will re-consider the approach once there is more regulatory certainty.

Although BEFM does not consider the PAIs within the meaning of Article 4(1)(a) SFDR, the PAI regime identifies numerous metrics such as green-house gas emissions, carbon footprint and board gender diversity. Where relevant to a strategy and product, BEFM may choose to provide to its investors reporting against similar or certain of these metrics.

Blackstone’s approach to ESG. Blackstone Inc.(together with its affiliates, “Blackstone”)views ESG principles as crucial to developing strong, resilient companies that deliver value for our investors and has long sought to lead by example, such as by increasing the use of clean energy across our corporate offices and recruiting and fostering diverse talent through active affinity networks such as the Women’s Initiative, Diverse Professionals Network, Veterans Network and OUT Blackstone.

Blackstone considers its existing due diligence process and wider environmental, social and governance (“ESG”) framework to be appropriate and proportionate to its investment strategy, and that of the underlying products. We maintain an ESG policy which governs our approach to integrating ESG into our investment process. As part of the firmwide ESG policy, we have identified three priority areas that we believe can most affect our ability to build strong companies of enduring value: climate change mitigation, resilience and adaption; diversity, equity and inclusion and good governance. Blackstone’s ESG policy sets out how these areas are integrated into our investment decisions. Where appropriate, our business units also maintain their own individual ESG policies, which are aligned with the firmwide policy and reflect the unique factors applicable to their respective investment strategies. For more information, see the firmwide ESG policy.

Website disclosures are required for certain products under the Sustainable Finance Disclosure Regulation and these can be found at https://www.bxaccess.com/.

Complaints Handling Policy

A summary of the Complaints Handling Policy for BEFM is available on the link below:

Complaints Handling Policy

Proxy Voting Policy

BEFM fully delegates the portfolio management function to affiliates of The Blackstone Group Inc. (each a “Delegate”). BEFM deems that the Delegates are, in general, in the best position to exercise voting authority attached to relevant securities held by investment funds and accounts managed by a Delegate (each such fund or account, a “client”) and have access to appropriate information to do so. For this reason, BEFM’s operating model is to mandate the exercise of such voting authority to the Delegates.

BEFM will ensure that Delegates endeavor to identify any conflicts that exist between the Delegates and their clients. If a material conflict exists, each Delegate will determine the appropriate course of action that it believes is in the best interests of the clients in accordance with their governing policies and procedures.

Determinations on how to vote proxies will depend largely on the subject matter at issue and will be done, in the absence of specific voting guidelines from a client, in the best interests of the client.

Delegates generally vote in favor of routine proposals from management, including election of directors, selection of independent auditors and approval of financial statements, unless special circumstances (such as corporate governance issues) arise.

Delegates may engage the services of a proxy advisory firm to make recommendations to the Delegates on the voting of proxies based on established guidelines and practices. In such circumstances, Delegates will generally vote proxies in accordance with the proxy advisor’s recommendations, unless they believe that not doing so is in the best interests of their clients.

Further details on the voting right strategies of Delegates are available at the registered office of BEFM. Details on the actions taken on the basis of those strategies will be made available to investors upon request.

RTS-28 Best Execution Reports

BEFM – MIFD II – RTS 28 Article 3 – Report FY2021

Shareholders Rights Directive II Disclosure

Article 3(g) of Directive 2007/36/EC as amended by Directive (EU) 2017/828 (together with the relevant national implementing regulations, the “SRD II”) requires asset managers to adopt on a “comply or explain” basis an engagement policy describing how an asset manager integrates in its investment strategy shareholder engagement relating to companies which have their registered office in the EU and the shares of which are admitted to trading on an EU regulated market.

Although BEFM encourages long-term shareholder engagement and enhanced transparency between shareholders and its portfolio companies, it has not adopted an engagement policy pursuant to SRD II. BEFM (or its delegate) does not predominantly invest in equity securities of EU listed issuers. Where our investment strategies allow us to invest in equity holdings, any acquisition of shares of EU listed companies is generally residual and, as the case may be, short-term opportunistic.

As part of the investment process, BEFM (or its delegate) will exercise voting rights in investee companies as well as manage related conflicts of interest in accordance with existing policies. In view of its investment strategies and portfolios, BEFM considers that this approach remains in line with the objectives of SRD II. BEFM will periodically assess whether it becomes relevant for it to adopt an engagement policy and will update this disclosure accordingly.