Sustainable Finance Disclosure Regulation
Sustainable Finance Disclosure Regulation (EU) 2019/2088
Regeneration Fund 2 CommV (private privak) (the “Fund”)
Financial Market Participant: Regeneration GP2 the “General Partner”
February 2024
DISCLOSURES COVERED BY THIS DOCUMENT
The Regulation (EU) no. 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability-related disclosures in the financial services sector (SFDR) requires financial market participants such as General Partner to provide information to investors with regard to the integration of sustainability risks, the consideration of adverse sustainability impacts, the remuneration in relation to sustainability risks and the promotion of environmental or social characteristics, and sustainable investment.
Published on 28 June 2026
• Regeneration.VC Fund 2 - Principal Adverse Impact Statement 2025
• Regeneration.VC Fund 2 - Annex V Periodic Disclosure 2025
Entity-level sustainability related disclosures SFDR 2019/288
1. Transparency of sustainability risk policies Article 3
2. Adverse sustainability impacts (entity level) Article 4
3. Remuneration policy with regards to sustainability risk Article 5
Sustainability disclosures SFDR Level 2
Transparency of Sustainability Risk Policies (SFDR 2019/2088 Article 3)
The General Partner considers sustainability-related risks in its investment decision-making process and has sustainable investments as its core investment objective. Sustainability-related risks and sustainable investments are embedded within the investment policy and are addressed through the selection or exclusion of investments based on their environmental objectives. These objectives include, but are not limited to, the investment’s impact on the environment and climate. In addition, the Fund intends to promote, human rights, labor rights, equal treatment, and anti-corruption practices.
Sustainability risks
This Policy defines “Sustainability Risk” as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
Disclosure of sustainability risks
The General Partner shall, in accordance with Regulation (EU) 2019/2088 (together with its delegated acts and as amended from time to time, the “SFDR”) and Regulation (EU) 2020/852 (together with its delegated acts and as amended from time to time) provide the required information to potential investors, in order to ensure that investors are able to make a well-informed decision about their investment in the Fund. The information to be disclosed and the format for such disclosures are set out in the SFDR. These include inter alia the manner in which sustainability risks are integrated into General Partner’s investment decision making process (as set out in this policy); the results of the assessment of the likely impacts of sustainability risks on the returns of the Fund; and how sustainable investments are achieved.
The information set out above shall be presented on the website of the Fund, as required by the SFDR.
When investing in early stage/developing companies, it is common that such companies may not have a strong ESG framework in place at the time of investment which addresses Sustainability Risks.
Since these are early-stage companies, their operations are limited and exposure to potential climate risks, nature risks, labor law and human rights breaches is therefore limited. During its initial screening of any potential portfolio company, the General Partner assesses the presence of minimum safeguards. These safeguards include three main categories 1) environmental criteria, 2) social criteria and 3) governance criteria, as outlined in further detail below. If early stage companies do not yet have the necessary policies and commitments in place, the General Partner will work with these companies to help them design the right policies and implement them.
Further details on our investment process, including our Impact and ESG due diligence practices, can be found in our Impact and Sustainability Policy.
2. Statement on Principal Adverse Impacts of Investment Decisions on Sustainability Factors (SFDR 2019/2088 Article 4)
a. description of the principal adverse sustainability impacts and of any actions in relation thereto taken or, where relevant, planned
The General Partner considers the principal adverse impacts (PAI) of its investment decisions on sustainability factors. Information on how it identifies and takes into account these impacts of investment decisions on sustainability factors are published in the periodic disclosures which are available from time to time on the Fund’s website in line with the rules of website disclosures as set out in the SFDR.
The General Partner intends to avoid principal adverse impacts (“PAI”) on sustainability factors, to ensure consistency in achieving its sustainable investment objectives. Accordingly, it is important to note that, since the General Partner is screening early-stage investments in companies that help to drive climate related impact associated with consumer industries, it is often the case that due to their size, the principal adverse impact of their activity on sustainability factors is often inexistent. The General Partner wants to help build responsible ventures, on governance, environment and social aspects, as they grow.
General Partner considers all 14 of the mandatory PAI indicators listed in Table 1 of Annex I of the Regulatory Technical Standards (RTS), however given the early stage of our portfolio companies not all of these PAIs are relevant for each portfolio company.
Additionally, it considers:
Indicator 4 from Table 2: Investments in companies without carbon emission reduction initiatives aimed at aligning with the Paris Agreement.
Indicator 9 from Table 3: Lack of human right policies
Indicator 15 from Table 3: Lack of anti-corruption and anti-bribery policies
Principal adverse impacts are assessed as part of an impact assessment framework, where SFDR PAI indicators are integrated into the decision-making process. During the ownership period, the General Partner monitors SFDR PAI indicators annually. These practices are further detailed in our Impact and Sustainable Investment Policy, available on our website.
b. Policy on the identification and prioritization of principal adverse sustainability impacts and indicators
The Principal Adverse Impacts (PAI) indicators are considered before investment and then monitored throughout the post investment ownership period:
Pre-investment: As part of Impact and ESG Due diligence process Sustainability Questionnaire will be shared with portfolio companies. Relevant PAI indicators form part of this Sustainability Questionnaire. If any potential adverse impacts are identified, these are screened further as part of the due diligence and mitigation efforts will be required. If considered necessary, commitments to realize these mitigation efforts may be formalized in a side letter alongside the Investment documentation. If mitigations are not considered possible, resulting in a risk of adverse impact outweighing the positive impact potential, the General Partner shall not make the investment.
Post-investment: The PAI indicators will form part of the Annual Impact and Sustainability Reporting process which portfolio companies commit to report on. Additional support and guidance are provided to companies to build their capability to report this information correctly. Any adverse impacts discovered as a result of this reporting are further evaluated, to ensure that appropriate mitigation measures are put in place. In addition to the 14 mandatory indicators, the additional three indicators as outlined above have been identified as most relevant to our portfolio and ambition of the fund. As such, we will collect this data as a valuable baseline which we will aim to improve over time.
Our process on identifying and prioritizing Principal Adverse Impacts both pre- and post-investment is defined in our Impact and Sustainability Policy.
c. Engagement policies
Policy and practices relating to portfolio engagement are outlined in our Impact and Sustainable Investment Policy as published on our website. Where the General Partner has a significant influence over the portfolio company’s structure and governance, we exercise our influence at Board level and make sure that impact and ESG related topics are included in the Board Meeting’s agendas. We actively engage with management to ensure that impact and ESG is a recurring theme implemented into daily business operations.
In situations where the General Partner does not have significant influence, there are still a number of ways it can support the portfolio companies to focus on impact and ESG issues. The General Partner provides close support to the Fund’s portfolio companies to meet SFDR’s requirements of being a ‘sustainable investment’. It monitors impact and ESG related data, including risks and opportunities, through annual reports from our portfolio companies; which includes how they manage impact and ESG related risks and opportunities on a day to day basis, and how they take them into account in their business planning and strategy. We work proactively to add impact and ESG to the agenda of board Meetings.
d. Reference to internationally recognized standards
The General Partner aims to contribute to keeping the planet within Planetary Boundaries and positively contribute to a number of focus Sustainable Development Goals (SDGs) with every portfolio company. The Impact and Sustainable Investment policy is based on the international standards including the Operating Principles for Impact Management, Impact Management Project and the Global Impact Investment Network (GIIN).
The General Partner works actively with its portfolio companies with the aim to ensure they are aligned with the requirements in the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles for Business and Human Rights, ILO Declaration on Fundamental Principles and Rights at Work, and the Universal Declaration of Human Rights.
3. REMUNERATION POLICY (SFDR 2019/2088 Article 5)
The General Partner, as a sub-threshold manager of the Fund 2, does not have an obligation to have a formal remuneration policy in accordance with article 40 and following of the Belgian law of April 19, 2014, on alternative entities for collective investments and their managers.
In practice, in accordance with general venture capital remuneration and award processes, a significant portion of an investment professional's compensation is typically in deferred instruments aligned to the performance of portfolio companies, meaning that the value of an investment professional's compensation will be negatively impacted by a sustainability risk that impacts the value of the underlying portfolio company.
3. INDEX AS A REFERENCE
Not applicable since there is no reference benchmark designated for the purpose of attaining the environmental and/or social characteristics promoted by the Fund.