SFDR Compliance Statement

Media Development Investment Fund, Inc. – SFDR Compliance Statement pursuant to Article 3, 4 and 5

Media Development Investment Fund, Inc. (“MDIF“) is a New York Not-for-Profit Corporation registered as an alternative investment fund manager (“AIFM“) in Belgium and The Netherlands. As such, MDIF is subject to the disclosure and reporting obligations set out in the Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR“).

SFDR, requires, amongst other things, AIFMs to disclose how sustainability risks are integrated into investment decisions, whether and how principal adverse impacts of investment decisions are considered, and how remuneration policies are consistent with the integration of sustainability risks in investment decisions.

Integration of sustainability risk into investment decision-making processes

SDFR defines “sustainability risk” as 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 investments (Article 2 (22) of SFDR). MDIF integrates sustainability risk in the investment decision-making process.

MDIF’s Mission (the “Mission“) is to invest in independent media around the world providing the news, information and debate that people need to build free, thriving societies, and provides affordable debt and equity financing as well as tailored technical assistance and advisory services to help independent media thrive and safeguard their editorial independence (the “Clients“). MDIF believes that corporate sustainability starts with a company’s value system and a principled approach to doing business. This means operating in ways that, at a minimum, meet fundamental responsibilities in the areas of human rights, labor, environment and anti-corruption wherever MDIF has a presence.

MDIF places rigorous demands on the Clients, including that such Clients have a record of consistent with the fostering of democratic practices and institutions, political pluralism, transparency, human rights, and dignity and equal rights for all, regardless of race, ethnicity, national origin, gender, sexual orientation, religion and other subjects of discrimination; that they are legally registered according to all applicable laws and must have licenses required by local laws for media of its kind; that they have capable and responsible management and apply for MDIF financing with a detailed business plan demonstrating strong prospects that the invested capital will be repaid and/or recovered.

Before any investment decisions are made, the relevant investment team will complete a process that identifies the material risks associated with each proposed investment; these will include relevant and material sustainability risks. MDIF considers such risks as part of its risk management process, starting with an overall assessment of the likely risks associated with investments pursuant to MDIF’s investment policy and mission, and leading to specific investment proposals submitted to the MDIF’s Investment Committee.

MDIF’s Investment Committee assesses all the identified risks, including sustainability risks alongside other relevant factors set out in the proposal. Following its assessment, the Investment Committee makes investment decisions having regard to the Mission, MDIF’s investment policy and objectives. Throughout the entire process, relevant sustainability risks are identified and assessed using the same process as is applied to other relevant risks affecting investments. Thereafter, the Clients are rigorously monitored, including for any sustainability risks.

No consideration of adverse sustainability impacts

MDIF currently does not consider adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4(1)(a) of the SFDR and currently applies Article 4(1)(b).

MDIF has strong internal processes in place to actively monitor the ESG performance of its Clients and rigorously implements a Corporate Social Responsibility (CSR) Policy, including environmental and diversity policy, pursuant to which it systematically encourages the Clients to adopts sustainable environmental, social and governance processes.

Given the nature of MDIF’s Clients (media undertakings), the not-for-profit nature of its operations which are largely financed by grants and socially responsible investors and the limited nature of its resources, MDIF considers the risk of adverse impacts of its investment decisions on sustainability factors is low and does not justify the resources required for detailed reporting on the stipulated indicators in Table 1 of Annex 1 of the draft Regulatory Technical Standards supplementing Article 4 of the SFDR.

MDIF will review our readiness to comply annually.

Remuneration policies

As an authorized alternative investment fund manager, MDIF has adopted a remuneration policy in accordance with the Alternative Investment Fund Managers Directive (AIFMD). Remuneration takes into account the relevant employee’s compliance with MDIF’s policies and procedures, including our CSR policy and the particular ethical guidelines for investment activities. MDIF does not provide variable performance-based remuneration and its remuneration policies do not encourage excessive risk‐taking, whether with respect to sustainability risks or otherwise.