Fidelio Capital II AB, reg. no 559109-8818, and Fidelio Capital AB, reg. no 559355-3505, (jointly referred to as “Fidelio” or the ”Company”) believe that effective management of sustainability risks is consistent with its investment approach as well as critical to protect the long-term value of its investments.

Fidelio shall adhere to the EU’s Sustainable Finance Disclosure Regulation ((EU) 2019/2088) (“SFDR”) and comply with all applicable sustainability disclosure requirements with respect to Fidelio’s funds and investment processes.

Integration of sustainability risks in the investment decision-making process

In accordance with Article 3 of the SFDR, Fidelio hereby provides information on its policies on the integration of sustainability risks in the investment decision-making process.
Fidelio is committed to integrating sustainability risks into its investment analysis and decision-making processes by:

• conducting appropriate assessments of material sustainability risks during due diligence;
• integrating sustainability risks into its investment decisions alongside financial, legal, commercial, and other considerations, and
• abstaining from investments which may risk substantial environmental or social harm that cannot be mitigated or remediated by the Fidelio during ownership.

To determine the materiality of sustainability risks, Fidelio shall rely on external sources and frameworks, including, but not limited to, SASB Standards.

Fidelio has identified sustainability as a future priority area and will closely monitor and adapt to prevailing market conditions, regulatory developments and risks, and may from time to time refine or modify its sustainability approach.

Transparency of remuneration policies with respect to integration of sustainability risks

In accordance with Article 5 of the SFDR, Fidelio hereby provides information on how its remuneration policies are consistent with the integration of sustainability risks.

Fidelio place a strong emphasis on maintaining its unique culture and ethos throughout its business, which is also reflected in its remuneration policies. Team members are evaluated and incentivised based on firm contribution and cultural alignment, rather than individual success or activity-based metrics. This helps ensure that individuals are not encouraged to take excessive risks in pursuit of individual and short-term gains.

Pursuant to Fidelio’s remuneration policies, all remuneration to individuals shall be aligned with the Company risk profile, business strategy, objectives, values, and interests. In this context, sustainability risk is one of many factors that are considered.

No consideration of adverse impacts of investment decisions on sustainability factors

In accordance with Articles 4 and 7 of the SFDR, Fidelio hereby provides information on whether Fidelio considers adverse impacts of its investment decisions, in accordance with the principal adverse impacts (“PAI”) regime that has been established by the SFDR.

Fidelio does not currently consider adverse impacts of its investment decisions. Fidelio assesses the disclosure preparedness of its investment targets and existing portfolio companies against the PAI regime as low. However, Fidelio is supportive of considering the PAI indicators and will work to establish the required data collection and reporting mechanisms to confirm its consideration of principal adverse impacts of investment decisions on sustainability factors. The Company will at least on an annual basis review whether and when to comply with the PAI regime.

Information updated: June 2024