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Disclaimer

“Brevet Capital Management, LLC’s (“Brevet”) refers to the attached article (the “Article”) written by a third party and titled “Sustainable Investments Awards 2022 Hedge Fund Manager of the Year” (the “Award”). Brevet’s inclusion of the Article about the Award on its website may be deemed to be a “third-party rating” under the SEC’s Investment Advisor Act Rule 206(4)-1 (the “Marketing Rule”).  The Marketing Rule defines third-party ratings as a “rating or ranking of an investment adviser provided by a person who is not a related person and such person provides such ratings or rankings in the ordinary course of its business.”  In order to comply with the Marketing Rule, Brevet is providing the following disclosures:

1. Source – The Article was written by Environmental-Finance.com (“Environmental Finance”), which, according to its website, is “an online news and analysis service established in 1999 to report on sustainable investment, green finance and the people and companies active in environmental markets.”  Environmental Finance is published by Field Gibson Media.
2. Period – The award covers the period from March 1, 2021, to April 1, 2022, and was announced on June 29, 2022.
3. Compensation – Until Environmental Finance contacted Brevet to inform the firm that they had chosen Brevet for the Award, the firm had no idea that it was under consideration.  Brevet did not provide any information to Environmental Finance in connection with the Award, nor did it pay any cash or non-cash compensation for the Award or its publication. For more information about Brevet’s compensation policies and other disclosures, please refer to Brevet’s Form ADV Part 2, accessible at http://adviserinfo.sec.gov/firm/summary/151672.
4. Content of Article – The Article explains Brevet’s strategy related to sustainability-focused businesses and lists a number of transactions on which Brevet supported innovative growth companies working on environmental solutions.  Brevet did not provide this information to Environmental Finance and does not know the source of such information.  The Article states that the listed transactions won Brevet the Award and that its “judges praised the investor for its clear investment in lending solutions companies.”
5. Potential Conflict – Given the lack of compensation or prior knowledge, Brevet does not see a conflict related to this third-party rating.  Brevet was one of 30 firms listed as award recipients by Environmental Finance for 2022.  Brevet is not aware of any questionnaire or survey used by Environmental Finance or its judges as a basis for deciding which firm would receive each of the awards.
6. Compliance with Marketing Rule – The Article lists a number of transactions in which Brevet was involved.  Brevet believes that a third party must have recommended Brevet for the Award.  Brevet does not know the identity of that endorser or other potential endorsers.   Brevet has no reason to believe that Environmental Finance did not comply with the Marketing Rule, based on Brevet: (a) having no knowledge that it was being nominated for the Award; (b) paying no compensation to receive or use the Award or for Environmental Finance to publish it; and (c) having no apparent conflict of interest.
7. No Client Testimonials – This disclosure relates solely to the third-party Award and Article and does not constitute an endorsement or testimonial from any client. Brevet does not selectively solicit or use client testimonials in connection with the Award.  If client testimonials are used in other contexts, Brevet aims to comply with applicable SEC marketing rules regarding fair solicitation and representation.