Principal Adverse Sustainability
Impacts Statement

SFDR Article 4

EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (“SFDR” or the “Regulation”) applies as of 10 March 2021. The Regulation requires financial market participants such as HPE Growth B.V. (the “firm” or “HPE Growth”) to provide information to investors with regards to the integration of sustainability risks, the consideration of adverse sustainability impacts, the promotion of environmental or social characteristics, and sustainable investment.

No consideration of sustainability adverse impacts at entity-level

HPE Growth does currently not consider principal adverse impacts of investment decisions on sustainability factors at entity level as outlined in article 4 sub 1(a) of the SFDR. We therefore do not disclose any information as described in this article.

HPE Growth has started collecting information on the PAI metrics in 2023 for the reporting year 2022 in line with its updated ESG Framework. Due to their size, not all portfolio companies (are obliged to) report (audited) ESG data. While the majority of HPE Growth’s portfolio companies have provided requested PAI data and information on their negative effects, the accuracy of the information has not been validated and thus cannot be guaranteed. Consequently, at this stage, HPE Growth cannot ensure the comprehensive and necessary quality of information that is required for meeting the technical standards outlined in Article 4 of the SFDR. As such, HPE Growth cannot ensure that the information will meet the necessary standards outlined in Article 4 of the SFDR in terms of completeness and quality.

HPE Growth will periodically evaluate its consideration of not disclosing the adverse impacts of its investment decisions on entity-level sustainability factors. Reconsideration will occur when data quality and availability of the entire portfolio are at the level required to comply fully.

Consideration of sustainability adverse impacts at product-level

Depending on the characteristics of the product which it is managing, and in particular the product’s designation as promoting “environmental or social characteristics” or having “sustainable investment” as its objective, HPE Growth will determine and disclose whether, and the extent to which, it considers the principal adverse impacts of its investment decisions on product-level.

In relation to products that do not expressly claim to promote environmental or social characteristics or have a sustainable investment objective, HPE Growth does not consider the principal adverse impacts of its investment decisions.

In relation to products that promote environmental or social characteristics, or have sustainable investment as their objective, the firm considers principal adverse impacts to the extent described in that product’s pre-contractual documents. In all cases, please refer to a product’s pre-contractual information for the specific policies applicable to that product.