In order to comply with the sustainable finance disclosure regulation (SFDR)* , Diffusion Capital

Partners B.V. (DCP) makes the following disclosures.

Integration of sustainability risks

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".


Before any investment decisions are made on behalf of a fund that DCP manages, an investment

decision process is followed which in regard to specific investments includes the approval of the

Investment Committee of such fund. DCP views sustainability as a standard topic in the pre-

investment process. Part of the investment decisions process is that DCP assesses the risks attached

to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks

are considered by DCP when making investment decisions.

In addition, DCP implements a performance-based policy while reviewing its employees. DCP

considers compliance with all policies and procedures which are in effect within DCP, including the

ESG policy manual which defines DCP’s commitment to Environmental, Social and Governance

(ESG) matters and which outlines how DCP integrates ESG into investment and portfolio monitoring


Employees are made aware of the applicable policies and procedures when starting their employment

with DCP.

No consideration of sustainability adverse impacts

DCP integrates sustainability risk considerations in its investment decision making process, in

accordance with article 4 sub 1 (b) of the SFDR. Nonetheless, DCP states that it does not consider

adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of

the Disclosure Regulation and therefore does not make the disclosures as described in article 4 sub 1

(a) of the SFDR. DCP mostly carries out investments in Seed and Series A rounds, the disclosures as

set forth in article 4 sub 1 (a) of the SFDR would therefore not be proportional to the stage of the




*Regulation (EU) 2019/2088