Sustainable Finance Disclosure Regulation Statement

Fidelio Capital II AB, reg. no 559109-8818, and Fidelio Newco AB, reg. no 559355-3505, (“Fidelio” or the ”Company”) believe that strategic and effective management of environmental, social and governance (“ESG”) risks and opportunities is consistent with its values as well as critical to create long-term value for investors, portfolio companies and society alike.

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 evaluating material ESG risks and, where relevant, opportunities for value creation as part of its screening and due diligence processes. To determine the materiality of ESG risks, Fidelio shall rely on external sources and frameworks, including, but not limited to, SASB Standards.

Furthermore, Fidelio is committed to seeking inspiration from relevant international (non-binding) frameworks, guidelines and best practices as it further develops its sustainability approach. This includes, but is not limited to, the UN Sustainable Development Goals, the UN Principles for Responsible Investment (UNPRI), the UN Global Compact and the OECD Guidelines for Multinational Enterprises.

The Company shall generally abstain from investments which risk causing substantial environmental and/or social harm that cannot be mitigated by Fidelio during ownership.

Fidelio has identified sustainability as a future priority area and shall during the coming year further develop its approach in line with the commitments described above. Fidelio will closely monitor and adapt to prevailing market conditions, regulatory developments and risks and may from time to time refine or modify its ESG 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.

Information published: 7 July 2022