Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):

A. Brightpoint Capital Invest GmbH

Date of Publication: April 24th, 2023

I. Transparency of sustainability risk policies (Article 3 SFDR)

Brightpoint Capital Invest GmbH (the “Fund Manager”) is a long-term investor that embraces its responsibility towards investors, portfolio companies and stakeholders in the wider ecosystem in which the firm and its portfolio companies operate. The Fund Manager manages sustainability risks through a combination of committed participation on the boards of directors of its portfolio companies as well as ongoing monitoring of the progress of each company. Furthermore, sustainability risks will be considered as part of the due diligence and risk assessment processes in advance of each investment.

II. No consideration of adverse impacts of investment decisions on sustainability factors/Statement on principal adverse impacts of investment decisions on sustainability factors (Article 4 SFDR)

Article 4 SFDR provides for a framework aimed at achieving transparency with regard to any principle adverse impacts of investment decisions on sustainability factors. For this purpose, financial market participants such as the Fund Manager must disclose certain information (taking into account the Commission Delegated Regulation (EU) 2022/1288 (“RTS”) with regard to regulatory technical standards). Currently, the Fund Manager does not take into account any principle adverse impact of investment decisions on sustainability factors as provided for by the RTS, as it believes that the information provided to it by the portfolio companies in relation to the investments is not sufficient to allow it to do so. The Fund Manager will monitor developments with regard to available information and consider whether it is reasonably possible in the future to disclose the information required by the Article 4 SFDR-framework (including the future RTS).

III. Transparency of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)

As a registered AIFM within the meaning of section 2(4) of the German Capital Investment Code (Kapitalanlagesetzbuch), the Fund Manager does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the German Capital Investment Code (Kapitalanlagesetzbuch). Accordingly, the integration of sustainability risks is not considered with respect to the determination of the remuneration.


1 “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“ (Article 2 no. 22 SFDR).