Sustainable Finance Disclosure Regulation

EU entity level sustainability risk disclosure 


The statement is based on the requirements as set out in the Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability‐related disclosures in the financial services sector (SFDR) specifically relating to the integration of sustainability risks.

This statement describes and details how the below listed financial market participants assess and integrate sustainability risk information into their investment processes. Furthermore, it outlines the approach and oversight mechanisms used to monitor the integration approach.

In our policies, the integration of sustainability risks into our investment decision-making process is referred to as ‘ESG integration’, as used throughout this statement.


This statement applies to Connected Capital & Partners Holding B.V (CC&P) and its affiliates including CC&P Growth Fund II Manager B.V. and to Connected Capital & Partners B.V. and its affiliates.


As ESG conscious investors, we recognize the importance of sustainable investing and aim to transition towards becoming an “Article 8” Fund, in line with the EU Sustainable Finance Disclosure Regulation (SFDR) investment selection and reporting standards. During this transition period, we are committed to implementing robust policies, putting in place the necessary processes and systems across the entire investment cycle to ensure compliance with SFDR standards. This includes but is not limited to integrating sustainability criteria into our investment selection process as well as establishing clear monitoring and reporting mechanisms to track and report on the sustainability performance of our investments according to SFDR requirements designed for “Article 8” Funds.

We recognize that becoming an Article 8 Fund is a journey that requires time, effort, and continuous improvement. Hence, we are dedicated to transparently communicating our progress to our investors and stakeholders and seeking feedback to enhance our sustainability practices. Our aim is to build a strong foundation for sustainable investing that will enable us to make a meaningful positive impact on the environment, society, and the economy.

While Connected Capital works on the transitioning to an Article 8 Fund, CC&P I and CC&P II funds have been and will continue to operate as “Article 6” funds, adhering to sustainable investment practices, which means that these Funds do not actively promote sustainable investment objectives. However, as responsible investors, we strive to integrate sustainability criteria into our full investment cycle from investment selection process to exit, considering environmental, social, and governance (ESG) factors alongside traditional financial metrics.

Sustainability risk policies

Connected Capital has developed a robust Responsible Investment Policy that outlines our commitments to investing in a responsible manner and is designed to uphold high standards of environmental, social, and corporate governance throughout the entire investment lifecycle, from sourcing to exit. The summary of the Responsible Investment Policy can be found on Connected Capital’s website with the detailed policy being available for the relevant stakeholders.

In accordance with the Sustainable Finance Disclosure Regulation (SFDR), Connected Capital defines sustainability risk as a material environmental, social, or governance (ESG) event or condition that, if it occurs, has the potential to adversely affect the value of an investment.

We maintain transparent reporting on our activities and progress at both the firm and portfolio company levels. Moreover, we actively promote responsible investment practices within the investment management industry, aiming to participate and add value through industry wide initiatives that add to our common goals.

Adverse sustainability impact at entity level

While we consider ESG factors in our investment decision making, we currently do not address the adverse impacts of investment decisions and sustainability factors as outlined in the SFDR. We believe that the processes we are currently putting in place in order to integrate ESG into our decision making from initial scan to due diligence and exit as well as the Responsible Investment Policy adequately align with the investment strategies of our funds.

However, we actively monitor regulatory developments related to the SFDR and other relevant ESG related laws and regulations. This includes staying informed about the implementation of associated legislation and regulatory guidance. As we transition to an Article 8 Fund we will work towards any required changes to our existing policies and procedures to ensure ongoing compliance and to reflect evolving industry standards, if necessary or appropriate.

We are committed to continuously improving our practices and remaining responsive to changes in the regulatory landscape to ensure the effective integration of responsible investment considerations in our investment approach and processes.

Remuneration policy and Sustainability risks

Connected Capital maintains a remuneration approach that aligns with market standards and risk management practices. This approach encompasses the management of sustainability risks within our investments. Our investment teams’ performance evaluation and compensation framework consider various criteria, including their adherence to our due diligence procedures. These procedures are specifically designed to identify and mitigate risks associated with each investment, including sustainability and other ESG-related risks that are identified and managed in accordance with our Responsible Investment Policy.