SFDR Disclosure

Disclosure requirements with regard to SFDR (Sustainable Finance Disclosure Regulation)

Waldegg Equity Partners GmbH (LEI: 8945002HWX54Y7MD1O68, "Waldegg") makes the following disclosures in accordance with the Sustainable Finance Disclosure Regulation "SFDR" EU2019/2088:

Dealing with Sustainability Risks (Art. 3).

It is our commitment and lived practice to include considerations of the environment, social aspects and the principles of responsible corporate governance in addition to the economic aspects of an investment decision. However, we do this without committing to a strict set of criteria or reporting requirements, as this would be cost prohibitive due to the small scale of our investments and Waldegg in general.

As part of the investment process, identified sustainability risks are addressed at Waldegg and clearly argue against the acquisition of potential investments. No investments are made that conflict with our standards.

Dealing with adverse sustainability impacts (Art. 4)

We are aware that our investments, as economic actors, have an impact on the environment and social aspects. Based on our findings from the investment process, environmentally relevant targets are defined during the holding period (energy, use of resources, CO2 emissions and circular economy). Both the special AIFs and the investments have of course to comply with all applicable laws and regulations, as well as all generally accepted rules and standards applicable in the respective business area.

The SFDR requires Waldegg to make a "comply or explain" determination as to whether it will consider the most significant negative impacts of its investment decisions on sustainability factors in accordance with a particular system set forth in the SFDR. Waldegg has chosen not to comply with this regime, both in general and with respect to its advisory special purpose AIFs and their underlying investments, as the data basis does not yet meet the regulatory requirements and the collection effort would not be feasible as of today. By implementing an annual reporting on the level of the investments, Waldegg Equity Partners GmbH is working on the collection of the corresponding data basis. Our handling of adverse sustainability impacts and a disclosure of the data is therefore reviewed annually.

Consideration of sustainability risks in the remuneration policy (Art. 5)

Waldegg Equity Partners GmbH takes sustainability risks into account in its remuneration policy to the extent that no incentives are created to take sustainability risks. The management of sustainability risks is implicitly included in the performance assessment of employees, but is not assessed separately.


Regarding Art. 3: A sustainability risk represents a circumstance or event from the environmental, social or governance areas, the materialization of which could potentially have a negative impact on the value of an investment.

‍to Art. 4: Adverse sustainability impacts are impacts that the investment has on the ecological and social environment. It is an outward-looking risk approach compared to sustainability risk.