Remuneration Policy –
Sustainability Risks

SFDR Article 5

EU Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (“SFDR” or the “Regulation”) applicable as of 10 March 2021 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.

This website disclosure specifically addresses the obligation in Article 5(1) of the Regulation.

Sustainability risks

A “Sustainability Risk” as defined in Article 2(22) of the Regulation is: “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 the investment”.

More information related to the firm’s responsibilities under the SFDR, and the firm’s approach to impact and ESG (Environmental, Social, and Governance factors) and responsible investment in general, can be found on the firm’s website a 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 treatment. In addition, it encourages long-term alignment of interests and financial stability.

Variable Compensation

HPE Growth awards variable remuneration to its employees on a fully flexible and discretionary basis. Variable remuneration consists of a balanced assessment which includes performance of the firm, adherence to HPE Growth’s values, compliance with all policies and procedures, ESG considerations and individual performance. HPE Growth takes into account sustainability risk factors as part of its investment process by applying a strict and clear investment exclusion list as well as by conducting ESG due diligence. As part these processes, HPE Growth ensures that investment decisions are not made which could result in excessive risk taking behaviour which would increase the likelihood of sustainability risks to materialize. Therefore, HPE Growth does not directly consider the impact of sustainability risks on the investment decisions as part of the assessment of variable compensation. HPE Growth is of the view that the investment process sufficiently takes into account the impact of sustainability risk factors on investment decisions.

Review of the Policy

This Remuneration Policy disclosure is based upon and reflects the Remuneration Policy that is effective as of May 2023 and will be reviewed at least once a year.