Consultation Paper No. 1 of 2025 - Proposal for Periodic Fund Reporting Requirements

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CONSULTATION PAPER
NO. 1 OF 2025
PROPOSAL FOR PERIODIC FUND
REPORTING REQUIREMENTS
18 MARCH 2025

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Table of Contents
Introduction.................................................................................................................... 3
Background .................................................................................................................... 5
Section A: Overview of Proposed Reporting Requirements................................................ 5
Section B: Seeking feedback on Funds framework............................................................ 9
Attachments and appendices........................................................................................ 10

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Why we are issuing this consultation paper

1. The Financial Services Regulatory Authority ("FSRA") of the Abu Dhabi Global Market
   ("ADGM") has issued this consultation paper to invite public feedback and comments on its proposed introduction of periodic reporting requirements, which will apply to all Authorised Fund Managers, in respect of each Fund that they manage. The consultation paper also seeks general feedback on several topics to inform its upcoming review of its Funds framework. Capitalised terms contained in this consultation paper have the meanings attributed to them in the FSRA’s Glossary Rulebook (“GLO”), unless otherwise defined in this consultation paper. Who should read this consultation paper
2. This Consultation Paper should be of particular interest to Authorised Fund
   Managers, potential applicants seeking to operate as Fund Managers within ADGM, as well as individuals and organisations active in the funds industry, and their respective professional advisors. How to provide comments
3. All comments should be made in writing and sent to the mail address or email
   address specified below. If sending your comments by email, please put the consultation paper number in the subject line. If relevant, please identify the organisation you represent in providing your comments. The FSRA reserves the right to publish, including on its website, any comments you provide, unless you expressly request otherwise at the time of making any comments. Comments supported by reasoning and evidence will be given more weight by the FSRA. What happens next
4. The deadline for providing comments on these proposals is 29 April 2025. When we
   receive your comments, we will consider whether any modifications to the proposals are required. We will then proceed to enact the proposals in their final form. You should not act on the proposals described in this consultation paper until the final rules are issued, we will issue a notice on our website when that happens. Introduction

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Comments to be addressed to:
Consultation Paper No. 1 of 2025
Financial Services Regulatory Authority
Abu Dhabi Global Market
ADGM Square
Al Maryah Island
PO Box 111999
Abu Dhabi, UAE
Email: fsra.consultation@adgm.com

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1. The FSRA has a statutory mandate to promote and enhance the integrity of the ADGM
   Financial System, to ensure a fair, transparent and efficient market with appropriate investor protection, to promote the safety and soundness of Authorised Persons and to maintain financial stability in ADGM. Since its inception, ADGM has been successful in attracting Fund Managers and a significant number of Domestic Funds have also been established in ADGM, such that the fund management sector forms an important part of the ADGM Financial System.
2. Currently, the data which the FSRA receives in relation to Funds post-launch is
   fragmented and often not in a format that facilitates supervisory analysis. The FSRA is therefore proposing to introduce a periodic reporting requirement for Funds. The proposed reporting requirement is intended to support the application of a risk-based supervisory approach in the fund management sector, by providing the FSRA with additional, timely, data on Funds’ activities throughout their life cycle, including information on portfolio holdings, leverage, and liquidity-related data.
3. The proposed reporting requirement would also enable the FRSA to identify relevant
   trends and risks that may be emerging within the fund management sector in ADGM and enhance its ability to further develop its regulatory framework for Fund management in a proportionate, evidence-based manner. The proposals are aligned with international best practices from peer regulators and international standard￾setting bodies.
4. It is proposed that Fund Managers will be required to submit a new regulatory return
   to the FSRA for each Fund that they manage (the “Periodic Fund Return”), which will be considered to be a Regulatory Filing and be subject to a late filing fee should a submission date be missed. The proposed amendments to FUNDS and GLO required to give effect to this reporting requirement are included in Appendix 1 and
   Appendix 2 respectively.
5. Submission of a Periodic Fund Return would be required for:
   a. each Domestic Fund; and b. each Foreign Fund managed by an Authorised Fund Manager (together, “In￾Scope Funds”). Background
   Section A: Overview of Proposed Reporting Requirements

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6. However, certain sections of the Periodic Fund Return are relevant only to a sub￾set of In-Scope Funds (see Attachment 1 for further detail).
7. For Domestic Funds, the proposed reporting requirement builds upon existing
reporting obligations under Chapter 16 of FUNDS. Currently, Foreign Funds managed by Authorised Fund Managers do not fall within the scope of Chapter 16 of FUNDS. However, given the potential reputational impact to ADGM should a significant risk event materialise within such a Fund, the FSRA considers it prudent to have greater insight into such Funds’ activities and risk exposures. The Periodic Fund Return Template
8. Attachment 1 outlines the categories of data proposed to be included in the
Periodic Fund Return template, the general rationale for requiring such information and the scope of application of each category of data. Attachment 2 outlines the individual data points proposed to be included in the Periodic Fund Return template in respect of each category of In-Scope Fund. It is likely that the contents of the Periodic Fund Return template will be refined over time, e.g., to align with changes to the regulatory framework for Funds. Question 1 Do you agree with the proposal to introduce a new periodic reporting requirement for Funds? Question 2 Do you agree with the scope of the information proposed to be included in the Periodic Fund Return? If not, what information should be removed or added, and why? Question 3 Should the approach to reporting portfolio holdings differ as between Public Funds and other In-Scope Funds (see Attachment 2 for proposed difference in approach)? Question 4 Should the requirement to provide Gross Notional Exposure data apply to all In￾Scope Funds? If not, which type of Funds should be removed from scope?

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Question 5
Do you anticipate any issues with identifying or collating the information required to be included in the Periodic Fund Return? If so, please outline any such anticipated issues. Guidance
9. The FSRA intends to publish guidance in 2025 to assist Fund Managers in
completing the Periodic Fund Return. It is anticipated that this guidance will be updated over time to reflect commonly received queries or changes to the specific data requested. Question 6 What additional guidance would be useful to assist Fund Managers in completing the Periodic Fund Return? Assurance requirement for Public Funds
10. For Public Funds, it is proposed that the Person providing the oversight function for
that Fund, i.e. the Oversight Committee or the Eligible Custodian/Trustee, as applicable, would be required to provide assurance that the Periodic Fund Return has been accurately and appropriately completed by the Fund Manager. Question 7 Do you agree with the proposed assurance requirement? If not, do you have any suggestions on alternative means of obtaining such assurance or confirmation? Reporting Frequency and Means of Submission
11. It is proposed that submission of the Periodic Fund Return would be required on
either a 3 monthly or 6 monthly basis, depending on the Fund type and whether it is open-ended or closed-ended in nature. The below table outlines the proposed reporting periods and reporting deadlines for each category of Fund.
12. The FSRA would have the discretion to direct a Fund Manager to submit a Periodic
Fund Return for a different reporting period than those specified below. Fund Type Reporting Period Reporting Deadline Public Fund Every 3 months Within 1 month of the end of each reporting period Exempt Fund – Open-Ended Every 3 months Within 1 month of the end of each reporting period

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Exempt Fund – Closed-Ended Every 6 months Within 6 months of the end of each reporting period Qualified Investor Fund (QIF) Every 6 months Within 6 months of the end of each reporting period Foreign Fund Every 6 months Within 6 months of the end of each reporting period
13. A reporting period of 3 months is proposed for Public Funds and open-ended
Exempt Funds, given the higher liquidity risk associated with open-ended Funds and the heightened degree of supervisory oversight appropriate for Public Funds. Semi-annual reporting is considered suitable for closed-ended funds and for QIFs, given the lower liquidity risk and the more sophisticated Unitholder profile.
14. The FSRA will notify Fund Managers of the required means of submission for the
Periodic Fund Return in advance of the first reporting deadline. Transition period
15. It is proposed that the first reporting period would end on 31 December 2025, with
the first set of returns to be submitted by either 31 January 2026 or 30 June 2026. Question 8 Do you have any comments on the proposed reporting periods and reporting deadlines and the timeline for first submission of the Periodic Fund Return? Question 9 Do you have any comments on preferred format for submission of the Periodic Fund Return? Conclusion
16. As ADGM continues to develop as a jurisdiction, it is important that the FSRA has
access to timely data on Funds’ activities to deliver on its statutory mandate, to support its risk-based supervisory approach and to facilitate further enhancement of its regulatory framework. The FSRA considers that the proposals outlined in this paper will support the continuing growth of the Fund management sector in ADGM, while also ensuring alignment with international standards. Question 10 Do you have any broader feedback on the proposals outlined in the paper that is not covered by the questions set out above?

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17. The FSRA intends to conduct a holistic review of its regulatory framework for Funds
and Fund Managers over the coming months, with a view to consulting on proposed changes later this year. The overall objectives of this review are as follows:
(1) to ensure that the framework takes account of developments in regulatory requirements elsewhere, including international best practices, to the extent appropriate to the nature of ADGM’s Fund management sector, and is clear and user-friendly; (2) to reflect insights gained from the FSRA’s significant experience of supervising Fund Managers; and (3) to ensure that the framework remains relevant in relation to developments in the Funds industry and continues to support the development and growth of ADGM as a fund management jurisdiction.
18. With the above objectives in mind, the FSRA would like to seek general feedback on
its current Funds framework, including any areas which could benefit from clarification and suggestions as to how the framework could be updated to reflect industry developments and continue to support the growth of the Funds sector in ADGM. Question 11 Do you have any observations on the FSRA’s current Funds framework? In your view, are there any aspects of the framework that could benefit from clarification? Question 12 Do you have any suggestions as to how the Funds framework could be updated to reflect industry developments?
Section B: Seeking feedback on Funds framework

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Attachment 1: Scope of application of each section of the Periodic Fund Return template and general rationale for requiring such information Attachment 2: Data points proposed to be included in the Periodic Fund Return template
Appendix 1: Proposed amendments to FUNDS
Appendix 2: Proposed amendments to GLO
Attachments and appendices

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Attachment 1: Scope of application of each section of the Periodic Fund Return template and rationale for requiring such information
Section Rationale for requiring such information Scope of
Application
Section 1:
Confirmation
Data
Identifies the individual submitting the Periodic Fund Return, allowing for swift follow up on the submission. All In-Scope Funds
Section 2:
Static Data
Receipt of this data would allow the FSRA to:
(a) determine which questions in the following sections of the submission are applicable (e.g., those sections applicable to Public Funds or open-ended Funds only); and (b) collate key data about Funds, which may be used for supervisory and general sector profiling purposes. Due to the increased risk profile of host Fund Managers, this section also asks whether the Fund Manager is acting as a host Fund Manager in relation to the Fund. All In-Scope Funds
Section 3:
Fees and
Expenses
Receipt of fee data would enable the FSRA to better assess risk and understand the norms of its ecosystem. Fees may vary over time which means the FSRA cannot rely on data submitted at Fund launch. For Public Funds, a breakdown of fees across individual fee categories is proposed, given the higher degree of supervisory oversight appropriate for such Funds. For Exempt Funds, the Total Expense Ratio is considered sufficient, given the more sophisticated Unitholder profile of such Funds. Breakdown of fees across individual fee categories required for Public Funds only. Total Expense Ratio required for Public

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Section Rationale for requiring such information Scope of
Application
Funds and Exempt
Funds.
Section 4:
Portfolio holdings and exposures
(including leverage data)
Receipt of portfolio holdings data would enable the FSRA to better identify sources of risk, including breach of applicable Rules on eligible assets, use of leverage, exposure to liquidity risks and exposure to idiosyncratic risks from particular geographies, indices, or individual assets. The large number of fields in this section of the template is reflective of the potential types of portfolio assets which Funds may hold. However, most fields will not be relevant to In-Scope Funds as they likely would not hold all the asset types in their portfolio. As leverage is a key risk indicator for funds, section 4 also includes several data fields specific to measuring leverage. In particular, the template requires information on Gross Notional Exposure (GNE), including GNE broken down by asset classes, and long and short exposures. IOSCO recommends that regulators use a two-step analysis in assessing and monitoring leverage, with Step 1 involving the use of GNE (broken down by asset class and by long and short exposures) as a baseline measure of leverage for funds that may present leverage-related risks. This baseline measure may then be used to identify a sub-set of funds that are more likely to present leverage-related risks, which may be analysed further in Step 2. In line with this two-step approach, the template does not require Net Notional Exposure (NNE) data to be provided. While NNE is identified by IOSCO as a complementary leverage measure to GNE and was considered for inclusion in the template, the IOSCO recommendations recognise that such complementary leverage measures are more relevant to the Step 2 analysis. In line with this approach, the FSRA may seek additional leverage-related data for individual Funds as part of supervisory engagement, if considered necessary based on analysis of GNE and other data. Based on consultation feedback, it may also consider de-scoping certain Funds from the obligation to report GNE based on size or other considerations. All In-Scope Funds, other than sections relating to ADGM Green Funds and ADGM Climate Transition Funds respectively, which apply only to Domestic Funds having those designations.

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Section Rationale for requiring such information Scope of
Application
Section 5:
Liquidity
Receipt of liquidity data in respect of open-ended funds would enable the FSRA to identify those open-ended Funds which are potentially more prone to suffer liquidity risk and focus its supervision accordingly. Section 5 also includes questions regarding open-ended Funds which have put in place special liquidity measures, which is data not currently collected by the FSRA via any other means. Open-ended Funds
Section 6:
Performance
Receipt of performance data would enable the FSRA to identify Funds experiencing unusually high or low performance, which is a risk indicator. For the first reporting period, it is proposed that Fund Managers would be required to submit performance data for the relevant Fund for the three previous financial years. This baseline will enable FSRA to more accurately track trends, identify potential risks through performance anomalies, and ensure efficient oversight. This data would not be required for subsequent reporting periods. All In-Scope Funds
Section 7:
Unitholders
Receipt of unitholder information would assist the FSRA in identifying:
(a) Funds experiencing particularly high inflows or outflows, which could be a risk indicator or risk driver; and (b) Funds with a particularly undiversified investor base, which is relevant to liquidity risk. All In-Scope Funds
Section 8:
Declaration
Certifies the correctness of the data provided, in line with the approach adopted by the FSRA for other regulatory submissions. All In-Scope Funds

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Appendix 1 - Proposed amendments to FUNDS

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Fund Rulebook (FUNDS)
*In this attachment underlining indicates new text and striking through indicates deleted text.

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…
7.2 Authorisation Requirements for Authorised Fund Managers of Foreign Funds
Regulator Notification
7.2.1 An Authorised Fund Manager to which this Chapter applies must give notice to the
Regulator of its intention to manage a Foreign Fund by submitting a notification to the Regulator as soon as reasonably practicable before launch in accordance with the requirements of this Chapter. … Guidance

1. For the purposes of Rule 0, "as soon as reasonably practicable before launch"
   requires, at a minimum, at least seven calendar days' notice to be given before the commencement of management functions by the Authorised Fund Manager.
2. An Authorised Fund Manager must submit a Periodic Fund Return to the Regulator
   in respect of each Foreign Fund it manages in accordance with Rule 16.6. … General oversight duties
   13.3.5 The Fund Manager shall ensure that each person undertaking the oversight function
   for the Fund is appointed with the necessary powers and resources to discharge its duties and functions and is required to:
   (a) monitor whether the Fund Manager:
   (i) is managing the Fund in accordance with the Constitution and the most recent Prospectus of the Fund, including in particular, any investment and borrowing limitations, requirements relating to the valuation of Fund Property and any other requirements or restrictions imposed on the Fund under FSMR or these Rules; and (ii) if it is a Foreign Fund Manager, is complying with the specific requirements that apply to such a Person by virtue of being a Foreign Fund Manager; … (d) report to the Regulator if:
   (i) the Fund Manager has failed, or is reasonably likely to fail, to take appropriate action to rectify or remedy a matter reported to it within 30 days of that matter being so reported; and

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(ii) that Person believes on reasonable grounds that the matter has had, or is likely to have, a materially adverse impact on the interests of the Unitholders of the Fund.; (e) provide such assurance as the Regulator requires as to the accuracy and completeness of the Fund’s Periodic Fund Return. …
16. ACCOUNTING, AUDIT AND PERIODIC REPORTING OF A FUND
16.1 Application
16.1.1 (1) This Chapter applies in its entirety to a Fund Manager and a Trustee of a Domestic
Fund.
(2) In this Chapter, references to a "Fund" mean a "Domestic Rules 16.6.1 to 16.6.6 apply to the Authorised Fund Manager of a Foreign Fund". …
16.3 Auditors of a Fund
Guidance

1. Rule Error! Reference source not found. requires every Domestic Fund to
   have an auditor appointed to it in accordance with Section 189 of FSMR and any Rules made for the purposes of that Part.
2. Section 189 of FSMR sets out how an Auditor must be appointed to each
   Domestic Fund and Part 15 of FSMR sets out the main duties and functions of the Auditor. This Chapter sets out additional requirements that apply in relation to auditors of a Domestic Fund. …
   16.6 Periodic Fund Return
   16.6.1 A Fund Manager must complete and submit a Periodic Fund Return to the Regulator in
   respect of:
   (a) each Domestic Fund that it manages; and (b) each Foreign Fund that it manages, where that Fund Manager is an Authorised Fund Manager.
   16.6.2 A Periodic Fund Return must be submitted in the form and manner prescribed by the
   Regulator.
   16.6.3 The reporting dates for the Periodic Fund Return are as follows:

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(a) 31 March, 30 June, 30 September and 31 December each calendar year in respect of:
(i) a Public Fund; or
(ii) an Exempt Fund that is an open-ended Fund; (b) 30 June and 31 December each calendar year in respect of:
(i) an Exempt Fund that is a closed-ended Fund; (ii) a Qualified Investor Fund; or (iii) a Foreign Fund.
16.6.4 For those Funds referred to in Rule 16.6.3(a), the Fund Manager must submit the
Periodic Fund Return within one month of each reporting date.
16.6.5 For those Funds referred to in Rule 16.6.3(b), the Fund Manager must submit the
Periodic Fund Return within six months of each reporting date.
16.6.6 The Regulator may require a Fund Manager to complete and submit a Periodic Fund
Return in respect of different reporting dates than those specified in Rule 16.6.3.
16.6.7 The Regulator may require a Fund Manager to provide information supplemental to
that described in the Periodic Fund Return.
…

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Appendix 2 - Proposed amendments to GLO

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Glossary Rulebook (GLO)
*In this attachment underlining indicates new text and striking through indicates deleted text.

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1. INTRODUCTION
   1.1 Application
   1.1.1 This Rulebook ("GLO") applies to every Person to whom any of the Rulebooks apply.
   1.2 Defined Terms
   1.2.1 In the Rulebooks:
   (1) a word or phrase which is defined in GLO is a defined term and has the meaning given in GLO; and (2) a word or phrase which relates to a defined term must be interpreted accordingly. … Defined Terms Definitions Periodic Fund Return Means the return required to be submitted by a Fund Manager in accordance with FUNDS 16.6 Regulatory Filings Means the return or report to be submitted to the Regulator, in relation to:
   (a) AML, in accordance with Rule 4.6.1;
   (b) CIB, in accordance with Rules 2.3.5(3), (4) and (5), 2.3.7, 2.3.8, 7.2.3, 7.3.2, 7.3.3, and 7.3.5; (c) FUNDS, in accordance with Rule 16.6; (cd) GEN, in accordance with Rules 6.6.1, and 8.8.12; (de) PIN, in accordance with Rules 6.6.1, 6.6.7, 6.7.2(1), 7.2.3 and 7.3.5; (ef) PRU, in accordance with Rules 2.3.7, 3.21.1, 10.3.2(3) and 10.4.2(3). …

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Attachment 2 - Funds Reporting Template

FSRA Funds Reporting Template - Public Fund 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of Fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager a Foreign Fund Manager?
11 Is the Fund Manager acting as host Fund manager in relation to this Fund? 12 Identification code type 13 Identification code 14 Has the Fund been launched? 15 Inception date 16 Portfolio valuation frequency 17 Regulator (where a Foreign Fund) 18 Fund type 19 Legal Structure 20 Predominant Fund type Mutual Fund /Sharia-compliant / Sustainability / ESG / REIT 21 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 22 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 23 Is this a Fund a feeder Fund? 24 If this Fund is a feeder Fund, in which jurisdiction is the Master Fund located? 25 Is the product marketed as Shariah compliant ? 26 Base Currency 27 AuM (Assets under management) of Fund ('000) 28 Is a minimum investment required? 29 Amount of the minimum investment (in Fund base currency) if required 30 Does the Fund utilise an Eligible Custodian? 31 Name of custodian (as indicated in the prospectus) 32 Which jurisdiction is the Eligible Custodian located in? 33 Name of Fund Administrator (as indicated in the prospectus) 34 Open or Closed Ended 35 Is the Fund listed on an exchange? 36 If listed, state which exchange
Section 3: Fees and expenses (% NAV)
37 Management fees
38 Subscription fees
39 Redemption fees
40 Performance fees (including carried interest) 41 Custody fees 42 Administrator fees 43 Other fees 44 Total Expense Ratio
Section 4: Portfolio holdings and exposures
Simplified exposure
45
46
46
47
47
48
48
49
49
50
50
51
51
52
52
53
53
54
54
55
55
56
56
57
57
58
58
59
59
60
60
61
61
62
62
63
Portfolio holding name Portfolio holding type Market value ('000) exposure Long Short % of portfolio Long Short

FSRA Funds Reporting Template - Public Fund 63 64 64 65 65 66 66 67 67 68 68 69 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 Other information on derivatives 90 Mean total daily average number of derivatives positions opened during reporting period 91 Mean total daily average number of derivatives positions closed during reporting period 92 Mean total daily average value of derivatives positions opened during reporting period 93 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the Fund) Non base currency holdings 94 % of portfolio in non base currency holdings Total leverage of the Fund 95 As calculated under the Gross Notional Exposure Method Asset turnover 96 Total number of assets bought and sold during the period / average portfolio NAV Sharpe Ratio 97 Where calculated: portfolio sharpe ratio ADGM Green Funds 98 % of the Fund invested in Eligible Green Fund Property 99 % of the Fund invested in assets which are not Eligible Green Fund Property ADGM Climate Transition Funds 100 % of the Fund invested in Eligible Climate Transition Fund Property 101 % of the Fund invested in assets which are not Eligible Climate Transition Fund Property Amount of borrowing and cash financing available to the Fund 102 Drawn 103 Undrawn 104 Committed 105 Uncommitted 106 Term Financing 107 Are there any other sources of leverage available to this Fund not already captured or disclosed in this submission?
Section 5 – Liquidity
Potential investor redemptions
108
Contractual frequency of investor redemption (according to prospectus) (business days) 109 Notice period required by investors for redemptions (business days) 110 Investor ‘lock-up’ period (business days) Portfolio liquidity profile 111 Percentage of NAV capable of being liquidated within the following periods (irrespective of the need to maintaining overall liquidity profile):
112 1 business day
113 5 business days
114 20 business days
115 60 business days
116 120 business days
117 120+ business days
What percentage of the NAV can be liquidated in the below periods whilst ensuring the Fund continues to meet its investment policy and restrictions and is managed in accordance with the interests of all unitholders (including those remaining)? 118 1 business day 119 5 business days 120 20 business days 121 60 business days 122 120 business days 123 120+ business days Which of the following measures may be employed by the Fund Manager to address liquidity risks? 124 Side pockets 125 Gates 126 Suspension of dealing 127 Other arrangements (narrative) As at the reporting date, what percentage of the Fund's NAV is subject to the following arrangements? 128 Side pockets (in %) 129 Gates (in %) 130 Fund suspension (Y/N) 131 Other arrangements (in %) Dilution 132 Which anti dilution tools are capable of being used by the Fund Manager according to the prospectus? 133 Number of valuation days / dealing days anti dilution tools applied during period

FSRA Funds Reporting Template - Public Fund 134 Mean average value of anti dilution tools applied during reporting period Counterparties 135 Identify the top five counterparties to which the Fund has the greatest mark-to-market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund
Section 6: Performance
136 Beginning Net Asset Value per Unit
137 Ending Net Asset Value per Unit
One year Fund performance for the following calendar years (Total return) (%) 138 2024 139 2023 140 2022
Section 7: Unitholders
141 Total subscriptions during the period (in Fund base currency) 143 Total redemptions during the period (in Fund base currency) 144 Total number of subscriptions during the period (absolute/units) 145 Total number of redemptions during the period (absolute/units) 146 Mean average investor holding period 147 Total number of Unitholders 148 Number of new Unitholders during this reporting period 149 Number of Unitholders who exited the Fund during this reporting period 150 Total number of Retail Client unitholders 151 Total number of Assessed Professional Clients 152 Total number of Deemed Professional Clients 153 Percentage of the Funds equity owned by the five beneficial owners that have the largest equity interest in the product/ Fund 154 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 8: Declaration
155 Declaration to be made by the Senior Executive Officer 156 Name of Senior Executive Officer 157 Date reviewed

FSRA Funds Reporting Template - Open Ended EF 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of Fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager a Foreign Fund Manager?
11 Is the Fund Manager acting as host Fund manager in relation to this Fund? 12 Identification code type 13 Identification code 14 Has the Fund been launched? 15 Inception date 16 Portfolio valuation frequency 17 Jurisdiction of incorporation 18 Regulator (where a Foreign Fund) 19 Fund type 20 Legal Structure 21 Predominant Fund type Hedge Fund /Venture Capital Fund /Private Equity /Private Credit Fund /Sharia-compliant / Sustainability / ESG / REIT 22 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 23 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 24 Is this a Fund a feeder Fund? 25 If this Fund is a feeder Fund, in which jurisdiction is the Master Fund located? 26 Is the product marketed as Shariah compliant ? 27 Base Currency 28 AuM (Assets under management) of Fund ('000) 29 Is a minimum investment required? 30 Amount of the minimum investment (in Fund base currency) if required 31 Does the Fund utilise an Eligible Custodian? 32 Name of custodian (as indicated in the prospectus) 33 Which jurisdiction is the Eligible Custodian located in? 34 Name of Fund Administrator (as indicated in the prospectus) 35 Is the Fund listed on an exchange? 36 If listed, state which exchange
Section 3: Fees and expenses (% NAV)
37 Total Expense Ratio
38
Simplified exposure
Securities
39 Cash and cash equivalents
40 Reverse repo
41 Listed equities
42 Unlisted equities
Corporate bonds
43 Investment grade
44 Non-investment grade / High yield
Sovereign and municipal bonds
54 Investment grade
55 Non-investment grade / High yield
56 % allocated to UAE
57 % allocated to non UAE GCC
58 All other sovereign exposure
59 Municipal and other public local debt
60 Convertible bonds
Loans
61 Collateralised debt obligation (CDO) / Collateralised loan obligations (CLO) 62 Other loans Structured/securitised products 63 ABS 64 RMBS 65 CMBS 66 Agency MBS 67 ABCP 68 Other Derivatives 69 Equity derivatives 70 Credit derivatives 71 Credit default derivatives 72 Single name CDS 73 Single name sovereign 74 Single name financial 75 Single name other 76 Index CDS 77 Exotic CDS 78 Other 79 Foreign exchange derivatives (for investment purposes) 80 Foreign exchange derivatives (for hedging purposes)
Section 4: Portfolio holdings and exposures Market value ('000)
exposure

FSRA Funds Reporting Template - Open Ended EF 81 Virtual asset derivatives 82 Interest rate derivatives (total gross notional without adjustments) 83 Interest rate derivatives (notional adjusted by the duration of a risk free 10-year bond equivalent) Commodity derivatives 84 Crude oil 85 Natural gas 86 Power 87 Gold 88 Other energy 89 Other precious metals 90 Agricultural products 91 Other commodity derivatives Other information on derivatives 92 Mean total daily average number of derivatives positions opened during reporting period 93 Mean total daily average number of derivatives positions closed during reporting period 94 Mean total daily average value of derivatives positions opened during reporting period 95 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the Fund) Physical (Real/Tangible) assets 96 Physical real estate 97 Residential real estate 98 Commercial real estate 99 Physical commodities 100 Physical transportation assets 101 Other physical assets Collective investment Funds 101 Investments in internal private Funds/operated by Fund manager 102 Investments in external private Funds/not-operated by Fund manager Digital assets 102 Virtual Assets 103 Fiat referenced tokens 104 Other Non base currency holdings 105 % of portfolio in non base currency holdings Total leverage of the Fund 106 As calculated under the Gross Notional Exposure Method Asset turnover 107 Total number of assets bought and sold during the period / average portfolio NAV Sharpe Ratio 108 Where calculated: portfolio sharpe ratio ADGM Green Funds 109 % of the Fund invested in Eligible Green Fund Property 110 % of the Fund invested in assets which are not Eligible Green Fund Property ADGM Climate Transition Funds 111 % of the Fund invested in Eligible Climate Transition Fund Property 112 % of the Fund invested in assets which are not Eligible Climate Transition Fund Property Amount of borrowing and cash financing available to the Fund 113 Drawn 114 Undrawn 115 Committed 116 Uncommitted 117 Term Financing 118 Are there any other sources of leverage available to this Fund not already captured or disclosed in this submission?
Section 5 – Liquidity
Potential investor redemptions
119
Contractual frequency of investor redemption (according to prospectus) (business days) 120 Notice period required by investors for redemptions (business days) 121 Investor ‘lock-up’ period (business days) Portfolio liquidity profile 122 Percentage of NAV capable of being liquidated within the following periods (irrespective of the need to maintaining overall liquidity profile):
123 1 business day
124 5 business days
125 20 business days
126 60 business days
127 120 business days
128 120+ business days
What percentage of the NAV can be liquidated in the below periods whilst ensuring the Fund continues to meet its investment policy and restrictions and is managed in accordance with the interests of all unitholders (including those remaining)? 129 1 business day 130 5 business days 131 20 business days 132 60 business days 133 120 business days 134 120+ business days Which of the following measures may be employed by the Fund Manager to address liquidity risks? 135 Side pockets 136 Gates 137 Suspension of dealing 138 Other arrangements (narrative) As at the reporting date, what percentage of the Fund's NAV is subject to the following arrangements? 139 Side pockets (in %) 140 Gates (in %) 141 Fund suspension (Y/N) 142 Other arrangements (in %) Dilution 143 Which anti dilution tools are capable of being used by the Fund Manager according to the prospectus? 144 Number of valuation days / dealing days anti dilution tools applied during period 145 Mean average value of anti dilution tools applied during reporting period Counterparties 146 Identify the top five counterparties to which the Fund has the greatest mark-to￾market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund

FSRA Funds Reporting Template - Open Ended EF
Section 6: Performance
147 Beginning Net Asset Value per Unit
148 Ending Net Asset Value per Unit
One year Fund performance for the following calendar years (Total return) (%) 149 2024 150 2023 151 2022
Section 7: Unitholders
152 Total subscriptions during the period (in Fund base currency) 153 Total redemptions during the period (in Fund base currency) 154 Total number of subscriptions during the period (absolute/units) 155 Total number of redemptions during the period (absolute/units) 156 Mean average investor holding period 157 Total number of Unitholders 158 Number of new Unitholders during this reporting period 159 Number of Unitholders who exited the Fund during this reporting period 160 Total number of Assessed Professional Clients 161 Total number of Deemed Professional Clients 162 Percentage of the Funds equity owned by the five beneficial owners that have the largest equity interest in the product/ Fund 163 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 8: Declaration
164 Declaration to be made by the Senior Executive Officer 165 Name of Senior Executive Officer 166 Date reviewed

FSRA Funds Reporting Template - Closed Ended EF 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of Fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager a Foreign Fund Manager?
11 Is the Fund Manager acting as host Fund manager in relation to this Fund? 12 Identification code type 13 Identification code 14 Has the Fund been launched? 15 Inception date 16 Portfolio valuation frequency 17 Jurisdiction of incorporation 18 Regulator (where a Foreign Fund) 19 Fund type 20 Legal Structure 21 Predominant Fund type Hedge Fund /Venture Capital Fund /Private Equity /Private Credit Fund /Sharia-compliant / Sustainability / ESG / REIT 22 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 23 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 24 Is this a Fund a feeder Fund? 25 If this Fund is a feeder Fund, in which jurisdiction is the Master Fund located? 26 Is the product marketed as Shariah compliant ? 27 Base Currency 28 AuM (Assets under management) of Fund ('000) 29 Is a minimum investment required? 30 Amount of the minimum investment (in Fund base currency) if required 31 Does the Fund utilise an Eligible Custodian? 32 Name of custodian (as indicated in the prospectus) 33 Which jurisdiction is the Eligible Custodian located in? 34 Name of Fund Administrator (as indicated in the prospectus) 35 Is the Fund listed on an exchange? 36 If listed, state which exchange
Section 3: Fees and expenses (% NAV)
37 Total Expense Ratio
Section 4: Portfolio holdings and exposures
Simplified exposure
Securities
38 Cash and cash equivalents
39 Reverse repo
40 Listed equities
41 Unlisted equities
Corporate bonds
42 Investment grade
43 Non-investment grade / High yield
Sovereign and municipal bonds
53 Investment grade
54 Non-investment grade / High yield
55 % allocated to UAE
56 % allocated to non UAE GCC
57 All other sovereign exposure
58 Municipal and other public local debt
59 Convertible bonds
Loans
60 Collateralised debt obligation (CDO) / Collateralised loan obligations (CLO) 61 Other loans Structured/securitised products 62 ABS 63 RMBS 64 CMBS 65 Agency MBS 66 ABCP 67 Other Derivatives 68 Equity derivatives 69 Credit derivatives 70 Credit default derivatives 71 Single name CDS 72 Single name sovereign 73 Single name financial 74 Single name other 75 Index CDS 76 Exotic CDS 77 Other 78 Foreign exchange derivatives (for investment purposes) 79 Foreign exchange derivatives (for hedging purposes) 80 Virtual asset derivatives Market value ('000) exposure

FSRA Funds Reporting Template - Closed Ended EF 81 Interest rate derivatives (total gross notional without adjustments) 82 Interest rate derivatives (notional adjusted by the duration of a risk free 10-year bond equivalent) Commodity derivatives 83 Crude oil 84 Natural gas 85 Power 86 Gold 87 Other energy 88 Other precious metals 89 Agricultural products 90 Other commodity derivatives Other information on derivatives 91 Mean total daily average number of derivatives positions opened during reporting period 92 Mean total daily average number of derivatives positions closed during reporting period 93 Mean total daily average value of derivatives positions opened during reporting period 94 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the Fund) Physical (Real/Tangible) assets 95 Physical real estate 96 Residential real estate 97 Commercial real estate 98 Physical commodities 99 Physical transportation assets 100 Other physical assets Collective investment Funds 101 Investments in internal private Funds/operated by Fund manager 102 Investments in external private Funds/not-operated by Fund manager Digital assets 103 Virtual Assets 104 Fiat referenced tokens 105 Other Non base currency holdings 106 % of portfolio in non base currency holdings Total leverage of the Fund 107 As calculated under the Gross Notional Exposure Method Asset turnover 108 Total number of assets bought and sold during the period / average portfolio NAV Sharpe Ratio 109 Where calculated: portfolio sharpe ratio ADGM Green Funds 110 % of the Fund invested in Eligible Green Fund Property 111 % of the Fund invested in assets which are not Eligible Green Fund Property ADGM Climate Transition Funds 112 % of the Fund invested in Eligible Climate Transition Fund Property 113 % of the Fund invested in assets which are not Eligible Climate Transition Fund Property Amount of borrowing and cash financing available to the Fund 114 Drawn 115 Undrawn 116 Committed 117 Uncommitted 118 Term Financing 119 Are there any other sources of leverage available to this Fund not already captured or disclosed in this submission? Counterparties 120 Identify the top five counterparties to which the Fund has the greatest mark-to￾market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund
Section 5: Performance
121 Beginning Net Asset Value per Unit
Ending Net Asset Value per Unit
One year Fund performance for the following calendar years (Total return) (%) 122 2024 123 2023 124 2022
Section 6: Unitholders
125 Total subscriptions during the period (in Fund base currency) 126 Total redemptions during the period (in Fund base currency) 127 Total number of subscriptions during the period (absolute/units) 128 Total number of redemptions during the period (absolute/units) 129 Total number of Unitholders 130 Number of new Unitholders during this reporting period 131 Number of Unitholders who exited the Fund during this reporting period 132 Total number of Assessed Professional Clients 133 Total number of Deemed Professional Clients 134 Percentage of the Funds equity owned by the five beneficial owners that have the largest equity interest in the product/ Fund 135 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 7: Declaration
136 Declaration to be made by the Senior Executive Officer 137 Name of Senior Executive Officer 138 Date reviewed

FSRA Funds Reporting Template - Open Ended QIF 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of Fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager a Foreign Fund Manager?
11 Is the Fund Manager acting as host Fund manager in relation to this Fund? 12 Identification code type 13 Identification code 14 Has the Fund been launched? 15 Inception date 16 Portfolio valuation frequency 17 Jurisdiction of incorporation 18 Regulator (where a Foreign Fund) 19 Fund type 20 Legal Structure 21 Predominant Fund type Hedge Fund /Venture Capital Fund /Private Equity /Private Credit Fund /Sharia-compliant / Sustainability / ESG / REIT 22 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 23 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 24 Is this a Fund a feeder Fund? 25 If this Fund is a feeder Fund, in which jurisdiction is the Master Fund located? 26 Is the product marketed as Shariah compliant ? 27 Base Currency 28 AuM (Assets under management) of Fund ('000) 29 Is a minimum investment required? 30 Amount of the minimum investment (in Fund base currency) if required 31 Does the Fund utilise an Eligible Custodian? 32 Name of custodian (as indicated in the prospectus) 33 Which jurisdiction is the Eligible Custodian located in? 34 Name of Fund Administrator (as indicated in the prospectus) 35 Is the Fund listed on an exchange? 36 If listed, state which exchange
Section 3: Portfolio holdings and exposures
Simplified exposure
Securities
37 Cash and cash equivalents
38 Reverse repo
39 Listed equities
40 Unlisted equities
Corporate bonds
41 Investment grade
42 Non-investment grade / High yield
Sovereign and municipal bonds
43 Investment grade
53 Non-investment grade / High yield
54 % allocated to UAE
55 % allocated to non UAE GCC
56 All other sovereign exposure
57 Municipal and other public local debt
58 Convertible bonds
Loans
59 Collateralised debt obligation (CDO) / Collateralised loan obligations (CLO) 60 Other loans Structured/securitised products 61 ABS 62 RMBS 63 CMBS 64 Agency MBS 65 ABCP 66 Other Derivatives 67 Equity derivatives 68 Credit derivatives 69 Credit default derivatives 70 Single name CDS 71 Single name sovereign 72 Single name financial 73 Single name other 74 Index CDS Market value ('000) exposure

FSRA Funds Reporting Template - Open Ended QIF 75 Exotic CDS 76 Other 77 Foreign exchange derivatives (for investment purposes) 78 Foreign exchange derivatives (for hedging purposes) 79 Virtual asset derivatives 80 Interest rate derivatives (total gross notional without adjustments) 81 Interest rate derivatives (notional adjusted by the duration of a risk free 10-year bond equivalent) Commodity derivatives 82 Crude oil 83 Natural gas 84 Power 85 Gold 86 Other energy 87 Other precious metals 88 Agricultural products 89 Other commodity derivatives Other information on derivatives 90 Mean total daily average number of derivatives positions opened during reporting period 91 Mean total daily average number of derivatives positions closed during reporting period 92 Mean total daily average value of derivatives positions opened during reporting period 93 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the Fund) Physical (Real/Tangible) assets 94 Physical real estate 95 Residential real estate 96 Commercial real estate 97 Physical commodities 98 Physical transportation assets 99 Other physical assets Collective investment Funds 100 Investments in internal private Funds/operated by Fund manager 101 Investments in external private Funds/not-operated by Fund manager Digital assets 102 Virtual Assets 103 Fiat referenced tokens 104 Other Non base currency holdings 105 % of portfolio in non base currency holdings Total leverage of the Fund 106 As calculated under the Gross Notional Exposure Method Asset turnover 107 Total number of assets bought and sold during the period / average portfolio NAV Sharpe Ratio 108 Where calculated: portfolio sharpe ratio ADGM Green Funds 109 % of the Fund invested in Eligible Green Fund Property 110 % of the Fund invested in assets which are not Eligible Green Fund Property ADGM Climate Transition Funds 111 % of the Fund invested in Eligible Climate Transition Fund Property 112 % of the Fund invested in assets which are not Eligible Climate Transition Fund Property Amount of borrowing and cash financing available to the Fund 113 Drawn 114 Undrawn 115 Committed 116 Uncommitted 117 Term Financing 118 Are there any other sources of leverage available to this Fund not already captured or disclosed in this submission?
Section 4 – Liquidity
Potential investor redemptions
119
Contractual frequency of investor redemption (according to prospectus) (business days) 120 Notice period required by investors for redemptions (business days) 121 Investor ‘lock-up’ period (business days) Portfolio liquidity profile 122 Percentage of NAV capable of being liquidated within the following periods (irrespective of the need to maintaining overall liquidity profile):
123 1 business day
124 5 business days
125 20 business days
126 60 business days
127 120 business days
128 120+ business days
What percentage of the NAV can be liquidated in the below periods whilst ensuring the Fund continues to meet its investment policy and restrictions and is managed in accordance with the interests of all unitholders (including those remaining)? 129 1 business day 130 5 business days 131 20 business days 132 60 business days 133 120 business days 134 120+ business days Which of the following measures may be employed by the Fund Manager to address liquidity risks? 135 Side pockets 136 Gates 137 Suspension of dealing 138 Other arrangements (narrative) As at the reporting date, what percentage of the Fund's NAV is subject to the following arrangements? 139 Side pockets (in %) 140 Gates (in %) 141 Fund suspension (Y/N)

FSRA Funds Reporting Template - Open Ended QIF 142 Other arrangements (in %) Dilution 143 Which anti dilution tools are capable of being used by the Fund Manager according to the prospectus? 144 Number of valuation days / dealing days anti dilution tools applied during period 145 Mean average value of anti dilution tools applied during reporting period Counterparties 146 Identify the top five counterparties to which the Fund has the greatest mark-to-market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund
Section 5: Performance
147 Beginning Net Asset Value per Unit
148 Ending Net Asset Value per Unit
One year Fund performance for the following calendar years (Total return) (%) 149 2024 150 2023 151 2022
Section 6: Unitholders
152 Total subscriptions during the period (in Fund base currency) 153 Total redemptions during the period (in Fund base currency) 154 Total number of subscriptions during the period (absolute/units) 155 Total number of redemptions during the period (absolute/units) 156 Mean average investor holding period 157 Total number of Unitholders 158 Number of new Unitholders during this reporting period 159 Number of Unitholders who exited the Fund during this reporting period 160 Total number of Assessed Professional Clients 161 Total number of Deemed Professional Clients 162 Percentage of the Funds equity owned by the five beneficial owners that have the largest equity interest in the product/ Fund 163 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 7: Declaration
164 Declaration to be made by the Senior Executive Officer 165 Name of Senior Executive Officer 166 Date reviewed

FSRA Funds Reporting Template - Closed Ended QIF 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of Fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager a Foreign Fund Manager?
11 Is the Fund Manager acting as host Fund manager in relation to this Fund? 12 Identification code type 13 Identification code 14 Has the Fund been launched? 15 Inception date 16 Portfolio valuation frequency 17 Jurisdiction of incorporation 18 Regulator (where a Foreign Fund) 19 Fund type 20 Legal Structure 21 Predominant Fund type Hedge Fund /Venture Capital Fund /Private Equity /Private Credit Fund /Sharia-compliant / Sustainability / ESG / REIT 22 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 23 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 24 Is this a Fund a feeder Fund? 25 If this Fund is a feeder Fund, in which jurisdiction is the Master Fund located? 26 Is the product marketed as Shariah compliant ? 27 Base Currency 28 AuM (Assets under management) of Fund ('000) 29 Is a minimum investment required? 30 Amount of the minimum investment (in Fund base currency) if required 31 Does the Fund utilise an Eligible Custodian? 32 Name of custodian (as indicated in the prospectus) 33 Which jurisdiction is the Eligible Custodian located in? 34 Name of Fund Administrator (as indicated in the prospectus) 35 Is the Fund listed on an exchange? 36 If listed, state which exchange
Section 3: Portfolio holdings and exposures
Simplified exposure
Securities
37 Cash and cash equivalents
38 Reverse repo
39 Listed equities
40 Unlisted equities
Corporate bonds
41 Investment grade
42 Non-investment grade / High yield
Sovereign and municipal bonds
43 Investment grade
53 Non-investment grade / High yield
54 % allocated to UAE
55 % allocated to non UAE GCC
56 All other sovereign exposure
57 Municipal and other public local debt
58 Convertible bonds
Loans
59 Collateralised debt obligation (CDO) / Collateralised loan obligations (CLO) 60 Other loans Structured/securitised products 61 ABS 62 RMBS 63 CMBS 64 Agency MBS 65 ABCP 66 Other Derivatives 67 Equity derivatives 68 Credit derivatives 69 Credit default derivatives 70 Single name CDS 71 Single name sovereign 72 Single name financial 73 Single name other 74 Index CDS 75 Exotic CDS Market value ('000) exposure

FSRA Funds Reporting Template - Closed Ended QIF 76 Other 77 Foreign exchange derivatives (for investment purposes) 78 Foreign exchange derivatives (for hedging purposes) 79 Virtual asset derivatives 80 Interest rate derivatives (total gross notional without adjustments) 81 Interest rate derivatives (notional adjusted by the duration of a risk free 10-year bond equivalent) Commodity derivatives 82 Crude oil 83 Natural gas 84 Power 85 Gold 86 Other energy 87 Other precious metals 88 Agricultural products 89 Other commodity derivatives Other information on derivatives 90 Mean total daily average number of derivatives positions opened during reporting period 91 Mean total daily average number of derivatives positions closed during reporting period 92 Mean total daily average value of derivatives positions opened during reporting period 93 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the Fund) Physical (Real/Tangible) assets 94 Physical real estate 95 Residential real estate 96 Commercial real estate 97 Physical commodities 98 Physical transportation assets 99 Other physical assets Collective investment Funds 100 Investments in internal private Funds/operated by Fund manager 101 Investments in external private Funds/not-operated by Fund manager Digital assets 102 Virtual Assets 103 Fiat referenced tokens 104 Other Non base currency holdings 105 % of portfolio in non base currency holdings Total leverage of the Fund 106 As calculated under the Gross Notional Exposure Method Asset turnover 107 Total number of assets bought and sold during the period / average portfolio NAV Sharpe Ratio 108 Where calculated: portfolio sharpe ratio ADGM Green Funds 109 % of the Fund invested in Eligible Green Fund Property 110 % of the Fund invested in assets which are not Eligible Green Fund Property ADGM Climate Transition Funds 111 % of the Fund invested in Eligible Climate Transition Fund Property 112 % of the Fund invested in assets which are not Eligible Climate Transition Fund Property Amount of borrowing and cash financing available to the Fund 113 Drawn 114 Undrawn 115 Committed 116 Uncommitted 117 Term Financing 118 Are there any other sources of leverage available to this Fund not already captured or disclosed in this submission? Counterparties 119 Identify the top five counterparties to which the Fund has the greatest mark-to-market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund
Section 6: Performance
120 Beginning Net Asset Value per Unit
121 Ending Net Asset Value per Unit
One year Fund performance for the following calendar years (Total return) (%) 122 2024 123 2023 124 2022
Section 7: Unitholders
125 Total subscriptions during the period (in Fund base currency) 126 Total redemptions during the period (in Fund base currency) 127 Total number of subscriptions during the period (absolute/units) 128 Total number of redemptions during the period (absolute/units) 129 Total number of Unitholders 130 Number of new Unitholders during this reporting period 131 Number of Unitholders who exited the Fund during this reporting period 132 Total number of Assessed Professional Clients 133 Total number of Deemed Professional Clients 134 Percentage of the Funds equity owned by the five beneficial owners that have the largest equity interest in the product/ Fund 135 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 7: Declaration
136 Declaration to be made by the Senior Executive Officer 137 Name of Senior Executive Officer 138 Date reviewed

FSRA Funds Reporting Template - Closed Ended Foreign Fund Data point 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager acting as host fund manager in relation to this Fund? 11 Identification code type 12 Identification code 13 Has the fund been launched? 14 Inception date 15 Portfolio valuation frequency 16 Jurisdiction of incorporation 17 Regulator 18 Fund type 19 Legal Structure 20 Predominant Fund type Hedge Fund /Venture Capital Fund /Private Equity /Private Credit Fund /Sharia-compliant / Sustainability / ESG / REIT 21 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 22 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 23 Is this a fund a feeder fund? 24 If this fund is a feeder fund, in which jurisdiction is the Master Fund located? 25 Is the product marketed as Shariah compliant ? 26 Base Currency 27 AuM (Assets under management) of fund ('000) 28 Is a minimum investment required? 29 Amount of the minimum investment (in fund base currency) if required 30 Does the Fund utilise an Eligible Custodian? 31 Name of custodian (as indicated in the prospectus) 32 Which jurisdiction is the Eligible Custodian located in? 33 Name of administrator (as indicated in the prospectus) 34 Is the fund listed on an exchange? 36 If listed, state which exchange
Section 3: Fees and expenses (% NAV)
37 Total Expense Ratio
Section 4: Portfolio holdings and exposures
Simplified exposure
Securities
45 Cash and cash equivalents
46 Reverse repo
47 Listed equities
48 Unlisted equities
Corporate bonds
50 Investment grade
51 Non-investment grade / High yield
Sovereign and municipal bonds
52 Investment grade
53 Non-investment grade / High yield
54 % allocated to UAE
55 % allocated to non UAE GCC
56 All other sovereign exposure
57 Municipal and other public local debt
58 Convertible bonds
Loans
59 Collateralised debt obligation (CDO) / Collateralised loan obligations (CLO) 60 Other loans Structured/securitised products 61 ABS 62 RMBS 63 CMBS 64 Agency MBS 65 ABCP 66 Other Derivatives 67 Equity derivatives 68 Credit derivatives 69 Credit default derivatives 70 Single name CDS 71 Single name sovereign 72 Single name financial 73 Single name other Market value ('000) exposure

FSRA Funds Reporting Template - Closed Ended Foreign Fund 74 Index CDS 75 Exotic CDS 76 Other 77 Foreign exchange derivatives (for investment purposes) 78 Foreign exchange derivatives (for hedging purposes) 79 Virtual asset derivatives 80 Interest rate derivatives (total gross notional without adjustments) 81 Interest rate derivatives (notional adjusted by the duration of a risk free 10-year bond equivalent) Commodity derivatives 82 Crude oil 83 Natural gas 84 Power 85 Gold 86 Other energy 87 Other precious metals 88 Agricultural products 89 Other commodity derivatives Other information on derivatives 90 Mean total daily average number of derivatives positions opened during reporting period 91 Mean total daily average number of derivatives positions closed during reporting period 92 Mean total daily average value of derivatives positions opened during reporting period 93 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the fund) Physical (Real/Tangible) assets 94 Physical real estate 95 Residential real estate 96 Commercial real estate 97 Physical commodities 98 Physical transportation assets 99 Other physical assets Collective investment Funds 100 Investments in internal private funds/operated by Fund manager 101 Investments in external private funds/not-operated by Fund manager Digital assets 102 Virtual Assets 103 Fiat referenced tokens 104 Other Non base currency holdings 105 % of portfolio in non base currency holdings Total leverage of the Fund 106 As calculated under the Gross Notional Exposure Method Sharpe Ratio 107 Where calculated: portfolio sharpe ratio Amount of borrowing and cash financing available to the fund 108 Drawn 109 Undrawn 110 Committed 111 Uncommitted 112 Term Financing 113 Are there any other sources of leverage available to this fund not already captured or disclosed in this submission? Counterparties 114 Identify the top five counterparties to which the Fund has the greatest mark-to-market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund
Section 5: Performance
115 Beginning Net Asset Value per Unit
116 Ending Net Asset Value per Unit
One year fund performance for the following calendar years (Total return) (%) 117 2024 118 2023 119 2022
Section 6: Unitholders
120 Total subscriptions during the period (in fund base currency) 121 Total redemptions during the period (in fund base currency) 122 Total number of subscriptions during the period (absolute/units) 123 Total number of redemptions during the period (absolute/units) 124 Mean average investor holding period 125 Total number of Unitholders 126 Number of new Unitholders during this reporting period 127 Number of Unitholders who exited the Fund during this reporting period 128 Total number of Retail Client unitholders 129 Total number of Assessed Professional Clients 130 Total number of Deemed Professional Clients 131 Percentage of the funds equity owned by the five beneficial owners that have the largest equity interest in the product/ fund 132 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 8: Declaration
133 Declaration to be made by the Senior Executive Officer 134 Name of Senior Executive Officer 135 Date reviewed:

FSRA Funds Reporting Template - Open Ended Foreign Fund Data point 1 Name of person making the submission 2 Position 3 Email address 4 Contact telephone number 5 Contact email address
Section 2:
Static Data
6 Name of fund
7 Name of Fund Manager
8 Investment manager
9 Investment advisor(s)
10 Is the Fund Manager a Foreign Fund Manager?
11 Is the Fund Manager acting as host fund manager in relation to this Fund? 12 Identification code type 13 Identification code 14 Has the fund been launched? 15 Inception date 16 Portfolio valuation frequency 17 Jurisdiction of incorporation 18 Regulator 19 Fund type 20 Legal Structure 21 Predominant Fund type Hedge Fund /Venture Capital Fund /Private Equity /Private Credit Fund /Sharia-compliant / Sustainability / ESG / REIT 22 Predominant strategy type /Equity /Fixed income /Real estate /Infrastructure /Fund of Funds /Money market /Commodity / Mixed / Virtual asset /Other 23 Predominant geographic region of assets ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa 24 Is this a fund a feeder fund? 25 If this fund is a feeder fund, in which jurisdiction is the Master Fund located? 26 Is the product marketed as Shariah compliant ? 27 Base Currency 28 AuM (Assets under management) of fund ('000) 29 Is a minimum investment required? 30 Amount of the minimum investment (in fund base currency) if required 31 Does the Fund utilise an Eligible Custodian? 32 Name of custodian (as indicated in the prospectus) 33 Which jurisdiction is the Eligible Custodian located in? 34 Name of administrator (as indicated in the prospectus) 35 Open or Closed Ended 36 Is the fund listed on an exchange? 37 If listed, state which exchange
Section 3: Fees and expenses (% NAV)
38 Total Expense Ratio
Simplified exposure
Securities
39 Cash and cash equivalents
40 Reverse repo
41 Listed equities
42 Unlisted equities
Corporate bonds
43 Investment grade
44 Non-investment grade / High yield
Sovereign and municipal bonds
45 Investment grade
46 Non-investment grade / High yield
47 % allocated to UAE
48 % allocated to non UAE GCC
49 All other sovereign exposure
50 Municipal and other public local debt
51 Convertible bonds
Loans
52 Collateralised debt obligation (CDO) / Collateralised loan obligations (CLO) 53 Other loans Structured/securitised products 54 ABS 55 RMBS 56 CMBS 57 Agency MBS 58 ABCP 59 Other Derivatives 60 Equity derivatives 61 Credit derivatives 62 Credit default derivatives 63 Single name CDS
Section 4: Portfolio holdings and exposures Market value ('000)
exposure

FSRA Funds Reporting Template - Open Ended Foreign Fund 64 Single name sovereign 65 Single name financial 66 Single name other 67 Index CDS 68 Exotic CDS 69 Other 70 Foreign exchange derivatives (for investment purposes) 71 Foreign exchange derivatives (for hedging purposes) 72 Virtual asset derivatives 73 Interest rate derivatives (total gross notional without adjustments) 74 Interest rate derivatives (notional adjusted by the duration of a risk free 10-year bond equivalent) Commodity derivatives 75 Crude oil 76 Natural gas 77 Power 78 Gold 79 Other energy 80 Other precious metals 81 Agricultural products 82 Other commodity derivatives Other information on derivatives 83 Mean total daily average number of derivatives positions opened during reporting period 84 Mean total daily average number of derivatives positions closed during reporting period 85 Mean total daily average value of derivatives positions opened during reporting period 86 Mean total daily average value of derivatives positions closed during reporting period (aggregate for the fund) Physical (Real/Tangible) assets 87 Physical real estate 88 Residential real estate 89 Commercial real estate 90 Physical commodities 91 Physical transportation assets 92 Other physical assets Collective investment Funds 93 Investments in internal private funds/operated by Fund manager 94 Investments in external private funds/not-operated by Fund manager Digital assets 95 Virtual Assets 96 Fiat referenced tokens 97 Other Non base currency holdings 98 % of portfolio in non base currency holdings Total leverage of the Fund 99 As calculated under the Gross Notional Exposure Method Sharpe Ratio 101 Where calculated: portfolio sharpe ratio ADGM Green Funds 102 % of the Fund invested in Eligible Green Fund Property 103 % of the Fund invested in assets which are not Eligible Green Fund Property ADGM Climate Transition Funds 104 % of the Fund invested in Eligible Climate Transition Fund Property 105 % of the Fund invested in assets which are not Eligible Climate Transition Fund Property Amount of borrowing and cash financing available to the fund 106 Drawn 107 Undrawn 108 Committed 109 Uncommitted 110 Term Financing 111 Are there any other sources of leverage available to this fund not already captured or disclosed in this submission?
Section 5 – Liquidity
Potential investor redemptions
112
Contractual frequency of investor redemption (according to prospectus) (business days) 113 Notice period required by investors for redemptions (business days) 114 Investor ‘lock-up’ period (business days) Portfolio liquidity profile 115 Percentage of portfolio capable of being liquidated within the following periods:
116 1 business day
117 5 business days
118 20 business days
119 60 business days
120 120 business days
121 120+ business days
What percentage of the NAV can be liquidated in the below periods whilst ensuring the fund continues to meet its investment policy and restrictions and is managed in accordance with the interests of all unitholders (including those remaining)? 122 1 business day 123 5 business days 124 20 business days 125 60 business days 126 120 business days 127 120+ business days Which of the following measures may be employed by the Fund Manager to address liquidity risks? 128 Side pockets 129 Gates 130 Suspension of dealing 131 Other arrangements (narrative) As at the reporting date, what percentage of the fund's NAV is subject to the following arrangements? 132 Side pockets (in %) 133 Gates (in %)

FSRA Funds Reporting Template - Open Ended Foreign Fund 134 Suspension of dealing (in %) 135 Other arrangements (in %) Dilution 136 Which anti dilution tools are capable of being used by the Fund Manager according to the prospectus? 137 Number of valuation days / dealing days anti dilution tools applied during period 138 Mean average value of anti dilution tools applied during reporting period Counterparties 139 Identify the top five counterparties to which the Fund has the greatest mark-to-market net counterparty credit exposure (excluding CCPs), measured as a % of the NAV of the Fund
Section 6: Performance
140 Beginning Net Asset Value per Unit
141 Ending Net Asset Value per Unit
One year fund performance for the following calendar years (Total return) (%) 142 2024 143 2023 144 2022
Section 7: Unitholders
145 Total subscriptions during the period (in fund base currency) 146 Total redemptions during the period (in fund base currency) 147 Total number of subscriptions during the period (absolute/units) 148 Total number of redemptions during the period (absolute/units) 149 Mean average investor holding period 150 Total number of Unitholders 151 Number of new Unitholders during this reporting period 152 Number of Unitholders who exited the Fund during this reporting period 153 Total number of Retail Client unitholders 154 Total number of Assessed Professional Clients 155 Total number of Deemed Professional Clients 156 Total number of Market counterparties 157 Percentage of the funds equity owned by the five beneficial owners that have the largest equity interest in the product/ fund 158 Total % of Fund held by Clients by jurisdiction ADGM / UAE ex ADGM / GCC and MENA ex UAE / UK and Europe / Russia and CIS states / USA and Canada / Americas ex USA and Canada / India / China / Asia ex India and China / Australasia / Sub￾saharan Africa
Section 8: Declaration
159 Declaration to be made by the Senior Executive Officer 160 Name of Senior Executive Officer 161 Date reviewed: