Remuneration Policy –
Sustainability Risks

SFDR Article 5

EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (“SFDR” or the “Regulation”) applied from 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.

The firm considers principal adverse impacts of investment decisions on sustainability factors in a manner appropriate to its size and the nature and scale of its activities and the types of financial product it makes available. 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, the firm will determine and disclose whether, and the extent to which, it considers the principal adverse impacts of its investment decisions.

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.

Therefore, this Principal Adverse Sustainability Impacts Statement (“this Statement”) specifically addresses the obligation in Article 4(1)(a) of the Regulation:

“Financial market participants shall publish and maintain on their websites:

(a) where they consider principal adverse impacts of investment decisions on sustainability factors, a statement on due diligence policies with respect to those impacts, taking due account of their size, the nature and scale of their activities and the types of financial products they make available.”
HPE Growth notes that pursuant to the Regulation, the EBA, EIOPA and ESMA (the “ESAs”) are mandated to develop regulatory technical standards (the “RTS”) with respect to climate and other environment-related adverse impacts, and with respect to social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

HPE Growth notes further that as of the date of this Statement, the European Commission has adopted the RTS, which has not yet been ratified. Notwithstanding the aforementioned, where adverse impacts are considered in respect of one of the firm’s products, the firm will apply the standards as set out in the adopted RTS as of the date of this Statement and will take into account ongoing advice to monitor and update its related policies and procedures where necessary due to any change in the RTS in order to ensure alignment and compliance with applicable laws and regulations.

HPE Growth will also monitor the development and adoption of any further regulation and RTS and consider, where appropriate on a product-by-product basis, the adoption of those standards to be set out in such regulation or RTS.

More information related to the firm’s responsibilities under the SFDR, and the firm’s approach to environmental, social and governance (“ESG”) factors and responsible investment in general, can be found on the firm’s website here:
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Remuneration and sustainability risks

The purpose of HPE Growth’s remuneration policy is to ensure that the remuneration structures within the firm encourage fair treatment of investors and responsible risk-taking behaviour consistent with the risk profile of HPE Growth and the funds managed by it.

HPE Growth’s remuneration policy promotes team orientation and fair employee consideration. In addition, it encourages long-term alignment of interests and financial stability and takes into account Sustainability Risks. To ensure continued alignment with these principles, the firm has updated and adopted a remuneration policy effective as of 1 August 2022 which it believes is consistent with the integration of Sustainability Risks over relevant time periods.

Variable Compensation

HPE Growth awards variable remuneration to its employees on a fully flexible and discretionary basis. Variable remuneration takes into account compliance with all policies and procedures, including those relating to the impact of Sustainability Risks on the investment decision making process.

Review of the Policy

This Remuneration Policy disclosure is based upon and reflects the Remuneration Policy that is effective as of 1 August 2022 and will be reviewed at least once a year.