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DCP – Entity-level Website Disclosures

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 decision 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 adverse sustainability impacts at the entity level

DCP does not consider adverse impacts of investment decisions on sustainable factors at the entity level within the meaning of article 4 sub 1 (b) of the SFDR. Hence, DCP 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 investees.



*Regulation (EU) 2019/2088

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