As an Alternative Investment Fund Manager (AIFM), CataCap Management A/S is subject to the Regulation (EU) 2019/2088 (“SFDR”) and ensures compliance with the regulation on behalf of the funds under management.

In accordance with the SFDR, CataCap provides disclosures on:

• the integration of sustainability risks in its investment decision-making process (Article 3),

• the consideration (or lack thereof) of principal adverse impacts of investment decisions on sustainability factors (Article 4), and

• the alignment of its remuneration policy with the integration of sustainability risks (Article 5).

These disclosures are reviewed on a regular basis and updated to reflect regulatory requirements as well as CataCap’s Responsible Investment Policy and ESG Framework.

Sustainability Risk Policy (Article 3)

Read our Sustainability Risk Policy here

No consideration of adverse impacts of investment decisions on sustainability factors (Article 4)

CCM does not consider all adverse impacts of investment decisions on sustainability factors on an entity level in accordance with SFDR Article 4. When making investment decisions, CCM considers ESG risks and opportunities that are material in relation to the specific target company. CCM recognises the importance of principal adverse impacts (“PAI”) of the investments, and CCM assesses and manages sustainability factors from both a risk mitigation and a value creation perspective.

The AIFs managed and/or advised by CCM invest in small and medium-sized companies located in Denmark and adjacent markets. With respect to this investment strategy, CCM is not in a position to collect the data required under the SFDR in a sufficient manner and quality to report systematically, consistently and at a reasonable cost. CCM will re-assess this position no later than at the final closing of the next flagship fund, CataCap IV, taking into account the quality, reliability and availability of data that CCM is able to obtain to provide a sufficient adverse impact assessment. Further, this statement and the Responsible InvestmentPolicy is reviewed at least on an annual basis.

Remuneration Policy (Article 5)

CataCap has adopted a remuneration policy. CataCap’s remuneration policy is consistent with the integration of sustainability risks in our investment process, i.e. the risk of environmental, social or governance events or conditions which, if they occur, could cause a material negative impact. The overall purpose of the remuneration policy is to ensure credible, reasonable, and fair remuneration, and that the ratio of fixed and variable remuneration is adequate, proportional and balanced. Variable remuneration is based on an overall assessment of performance criteria, and handling of ESG issues and opportunities is part of the overall assessment.

Website product disclosure for CataCap III K/S

CataCap III K/S is classified as promoting environmental and/or social charact eristics within the meaning of Article 8 of the SFDR. The product level disclosure prepared in accordance with Article 24 of Regulation (EU) 2022/1288 is available here.

Periodic disclosure for CataCap III K/S

The latest periodic disclosure detailing the performance of the fund in terms of the environmental and social characteristics it seeks to promote is available in the Appendix of the latest Annual Report for CataCap III K/S, which is accessible from our website.