North Sea Capital makes the following disclosures in accordance with the Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial service sector (the “SFDR”) Articles 3(1), 4(1)(a) and 5(1).

The disclosure apply to the following North Sea Capital entities:

• North Sea Capital General Partner S.à r.l (the “General Partner”)
• North Sea Capital Private Equity Fund of Funds SCA SICAV SIF (the “Fund”)
• North Sea Capital A/S (the “Investment Advisor”)

SFDR Art. 3 – Integration of sustainability risks in the investment decision process

A sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”. For North Sea Capital, sustainability risks are risks which, if they were to crystallise, would cause a material negative impact on the value of the portfolio of the Fund.

Before any investment decisions are made on behalf of the Fund, the Investment Advisor will, subject to the General Partner’s approval, complete a process that identifies the material risks associated with each proposed investment; these will include relevant and material sustainability risks.

The Investment Advisor considers these risks as part of its risk management process for the sub-funds it advises, starting with an overall assessment of the likely risks associated with investments pursuant to the relevant sub-fund’s investment policy and objectives, and leading to specific investment proposals submitted to the General Partner.

The General Partner assesses all the identified risks, including sustainability risks alongside other relevant factors set out in the proposal. Following its assessment, the General Partner makes investment decisions regarding to the relevant sub-fund’s investment policy and objectives. Throughout the entire process, relevant sustainability risks are identified and assessed using the same process as is applied to other relevant risks affecting the sub-funds and investments made on their behalf.

The Investment Advisor has a long-standing commitment to responsible investment principles and was one of the first Nordic fund-of-funds to become a signatory to the UN supported Principles for Responsible Investment initiative in November 2011.

SFDR Art. 4 – Information about adverse sustainability impacts

Whilst North Sea Capital takes sustainability and ESG risks very seriously, North Sea Capital does not consider the principal adverse impacts of its investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR. The relevant data needed to identify and weight principal adverse sustainability impacts is not yet available in the market to a sufficient extent or of the required quality. North Sea Capital will review the data situation on a regular basis and, if necessary, decide again on THE basis on the possibility of taking into account principal adverse impacts of investment decisions on sustainability factors as part of internal strategies.

SFDR Art. 5 – Remuneration policy consistency with integration of sustainability risks

The remuneration system targets an alignment of interest between investors and North Sea Capital employees, avoiding incentives for inappropriate risk taking and is in line with the sustainable long-term financial development of North Sea Capital. The Investment Advisor pays staff a combination of fixed remuneration (salary and benefits) and variable remuneration (including bonus). Variable remuneration for relevant staff takes into account performance and a number of other factors, such as compliance with North Sea Capital’s policies and procedures, including those relating to the impact of sustainability risks during the investment decision making process.