1. Introduction

The European Sustainable Financial Disclosure Regulation ((EU)2019/2088) (hereafter “SFDR”) and amending Regulation (EU) 2020/852 (hereafter “Taxonomy Regulation”), as relevant since March 10, 2021, requires Inkef Capital B.V. (‘Inkef’) to publish its policy regarding the incorporation of sustainability aspects whilst investing, and report on sustainability impact of the its Funds.

Sustainable investment: Is defined as an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labour relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.

Sustainability risk: Means 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.

Sustainability factors: Mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

2. Principal Adverse Impact and Sustainability Risks

When making investment decisions, Inkef takes sustainability risks into account. Inkef identifies and assesses potential sustainability risks that, if it were to occur, would cause a real or potential material adverse effect on the value of the (potential) investment. Investment decisions are made on the basis of pre-defined criteria that need to be met.

During the various stages of a portfolio journey, Inkef considers sustainability factors as integral part of the (pre) investment analysis, the day-to-day management of portfolio companies and eventually as part of the exit considerations.

Inkef does not make disclosures on the adverse impacts of its investment decisions on sustainability factors. Inkef is at this stage assessing which information requirements need to be met and/or whether the required information is sufficiently available to make a proper and reliable assessment and subsequently a proper periodic reporting.

Inkef’s fund is not labelled as an article 8 and/or article 9 fund under the EU’s Sustainable Finance Disclosure Regulation (SFDR).

3. Remuneration policy

Inkef recognizes the risk that if not appropriately structured, the remuneration policies and the incentives they create could lead to negative impacts on Sustainability Risks. Therefore, Inkef has adopted a remuneration policy which is consistent with the integration of Sustainability Risks.