Sustainability disclosures on Sustainable Finance Disclosure Regulation (SFDR)

Sustainability risks (Article 3 of the SFDR)

StartGreen Capital's ESG policy describes how sustainability risks are identified and mitigated by the funds. 'Sustainability risk' means an environmental, social or governance event or circumstance that, if it occurs, could cause a material adverse effect on the value of the investment.

The aim of our ESG policy is to identify both ESG risks (potential negative return effects) and ESG opportunities (potential value creation). Thus, we exclude sectors that do not align with our values, such as the arms industry, oil and gas industry (fossil fuels), tar sands oil companies and the tobacco industry. During the due diligence phase, we identify potential company-specific ESG risks, such as nitrogen emissions, and opportunities, such as strengthening diversity. If we decide to invest, material ESG risks (if any) are monitored periodically. The combination of these practices should lead to fewer risks (such as reputational risk), more future-proof and attractive portfolio companies (both for talent and prospective investors) and thus better returns. Below is a schematic overview of the ESG process.

Before providing financing to a company, we use our ESG survey to investigate whether the company has a potentially negative impact on sustainability factors ('inside-out'), such as environmental pollution or child labour in the supply chain. We also analyse for each company whether it faces serious external sustainability risks ('outside-in'), for example a physical climate risk that, if it occurs, could lead to a material adverse effect on the value of the investment.

Below is an overview of the ESG items we analyse prior to providing financing.

Consideration of Principal Adverse Impacts (Article 4 of the SFDR)

Since 2021, StartGreen Capital has been making an annual call to its portfolio companies to report on issues arising from the SFDR, including the "adverse impacts on sustainability" better known as "Principal Adverse Impacts" (PAIs). These are indicators of potential adverse impacts on people (including on diversity, worker safety, human rights) and environment (including through greenhouse gases and waste or on biodiversity).

Many of StartGreen Capital's portfolio companies are relatively young and small. Because of the size of the companies, data on this is often not available publicly or through a data provider (as is the case for some large listed companies). In addition, the portfolio companies themselves often do not have the resources and/or obligation to report on these PAI indicators. The survey is therefore completed on a "best-effort" basis. Because StartGreen Capital depends on the quality of the information it receives from portfolio companies, in previous years it could not guarantee the necessary completeness and quality required for a publication of PAI statements.

StartGreen Capital will do report on Principal Adverse Impacts (PAIs) in accordance with Article 4 of the SFDR at entity level from FY2024. In doing so, StartGreen Capital's goal is to improve the quality and completeness of this information every year, including through better guidance to portfolio companies and by using improved applications.

Since StartGreen Capital invests in sustainable companies based on its mission and many of the PAI indicators have already been assessed during the ESG due diligence, it is considered unlikely that material, negative impacts will occur.

Remuneration policies related to the integration of sustainability risks (Article 5 of the SFDR)

StartGreen Capital pays all employees a fixed monthly remuneration that is not dependent on targets. StartGreen Capital may pay discretionary variable rewards, which are rewards linked to the achievement of criteria in relation to the employee's performance, as well as in relation to StartGreen Capital's financial soundness. The ratio between fixed and variable remuneration is appropriate and can never exceed 20 per cent of fixed income. StartGreen Capital does not work with guaranteed variable remuneration.

StartGreen Capital has a statutory objective to "through its business operations and activities, have a significant positive impact on society and the environment at large". Employee remuneration is therefore always linked to objectives that ideally make a positive contribution to, but in no case have a negative impact on, any of the Sustainable Development Goals. Investments and financing may only qualify for the quantitative targets if the ESG risks have been sufficiently assessed and ratified beforehand by the mandated committee.

Read the full remuneration policy.

Website fund disclosures (Article 10 of the SFDR)

In addition to the sustainability policy key aspects of sustainability information for each fund are summarised below. These statements are in accordance with Articles 45 to 57 of Delegated Regulation (EU) 2022/1288 (SFDR RTS). In addition, the "periodic disclosures" from the funds' annual reports - as described in Annex V of the SFDR RTS - are linked.

Energiefonds Overijssel

• SFDR Article 10 - Website disclosure

Participation Fund Sustainable Economy North Holland

• SFDR Article 10 - Website disclosure
• SFDR RTS Annex V - Periodic disclosure

Borski Fund

• SFDR Article 10 - Website disclosure
• SFDR RTS Annex V - Periodic disclosure

StartGreen Capital's other mandates are not covered by the SFDR or have since been closed and are therefore not included in the overview above.