SFDR disclosure

Last updated: 16 April 2026

H2 Equity Partners Holding B.V. | SFDR website disclosures 

In order to comply with the sustainable finance disclosure regulation (SFDR), H2 Equity Partners Holding B.V. (H2) makes the following disclosures.

Integration of sustainability risks 
A sustainability risk means: 

“an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”.    

Before any investment decisions are made on behalf of a fund that H2 manages, a structured investment decision process is followed. This process includes initial deal screening, detailed commercial and financial due diligence, and a formal review and approval by H2’s Investment Committee. H2 views ESG as a standard topic in its pre-investment process. As part of the due diligence process, H2 assesses the risks attached to a potential investment opportunity, which includes sustainability risks. Identified sustainability risks are taken into account by H2 when making investment decisions.

All employees are expected to comply with H2’s internal policies and procedures, including those relating to the consideration of sustainability risks, and are made aware of these when starting their employment with H2.

Remuneration policy and sustainability risks
H2’s remuneration policy does not incentivise excessive risk-taking with respect to sustainability risks and is consistent with the integration of sustainability risks in H2’s investment decision-making process.

No consideration of sustainability adverse impacts 
In accordance with article 4 sub 1 (b) of the SFDR, H2 states that it does not consider adverse impacts of investment decisions on sustainability factors as set forth in article 4 sub 1 (a) of the SFDR and therefore does not make the disclosures as described in article 4 sub 1 (a) of the SFDR. 

At this stage H2 does not consider the adverse impacts of its investment decisions on sustainability factors, (i) because H2 could not reasonably gather and/or measure all the relevant data of the portfolio companies of H2, taking into account reasonable cost for clients and investors and (ii) due to  the small size of the organisation of H2, such disclosure as set forth in article 4 sub 1 (a) of the SFDR and the administrative burden in connection therewith would not be proportional.

H2 continues to closely monitor the market developments (including the level of availability of the data) as well as the regulatory developments. H2 will at least on an annual basis review whether and when to comply with article 4 sub 1 (a) of the SFDR.

H2 Equity Partners
info@h2ep.nl