Sustainability-related Disclosures

Last updated: October 2025

Article 3 SFDR – Sustainability risk policies

Our NAP Investment Management GmbH, LEI: 894500YCEMYO3A7KPA92, (“NAP”, also referred to as “we”, “us”, “our”) integrates sustainability risks into its investment decision-making process.

Sustainability risks mean 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. Sustainability risks are assessed during the due-diligence phase and considered by the Investment Committee before any decision is made.

The assessment is proportionate to the early-stage, technology-focused nature of our portfolio. We use the KfW Sustainability Framework and the AtlasMetrics platform to identify, track and monitor key ESG indicators over time. Where material sustainability risks are identified, reasonable mitigation measures are evaluated before investment.

Article 4 SFDR – No consideration of adverse impacts of investment decisions on sustainability factors

NAP currently does not consider principal adverse impacts (“PAI”) of its investment decisions on sustainability factors.

This approach reflects the early-stage venture capital model and the limited availability of reliable ESG data from portfolio companies. As ESG data quality and regulatory clarity improve, we will review this position and may reassess PAI reporting in the future.

Nevertheless, we collect ESG-relevant data from portfolio companies (e.g., diversity, data security, environmental footprint) through AtlasMetrics to monitor progress and encourage continuous improvement.

Article 5 SFDR – Remuneration policies and sustainability

As a registered alternative investment fund manager within the meaning of the KAGB and the EuVECA-Regulation, NAP does not have, nor is required to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.