SFDR / Disclosure Regulation

Sustainability related disclosures pursuant to Regulation (EU) 2019/2088

Publication date: 8 October 2025

The following information contains the sustainability related disclosures of SOL Capital Management GmbH, FN 554999 a (“SOL Capital Management”), in accordance with Regulation (EU) 2019/2088 on sustainability-related disclosure obligations in the financial services sector (“Disclosure Regulation”).

Management of sustainability risks (Art. 3 Disclosure Regulation)

Sustainability risks are events or developments in the areas of environment, social, or governance that can actually or potentially have a negative impact on the value of an investment.

In investment decisions by SOL Capital regarding SOL Drei EuVECA GmbH & Co KG, FN 565317 z (“SOL Drei”), there is currently no independent, systematic consideration of sustainability risks. However, SOL Capital takes into account the potential material impacts of such risks on the assets, financial, and earnings situation of SOL Drei within the framework of general risk management.

During due diligence reviews, ESG-related information (e.g., via questionnaires or checklists) may be obtained. These are generally not externally verified or thoroughly examined.

SOL Drei neither promotes environmental nor social characteristics (Art. 8 Disclosure Regulation) and does not pursue sustainable investments within the meaning of Art. 9 Disclosure Regulation. Therefore, SOL Capital may, at its own discretion, decide to invest despite existing sustainability risks or refrain from doing so. Where appropriate, risk mitigation measures may be implemented, taking into account the principle of proportionality and the respective transaction context.

No consideration of adverse impacts (Art. 4 Disclosure Regulation)

“Sustainability factors” include environmental, social, and employee matters, human rights, as well as anti-corruption and anti-bribery issues. Due to the broad investment spectrum and varying investment volumes, a comprehensive assessment of adverse impacts of investment decisions on sustainability factors would currently only be possible with disproportionate effort. Therefore, SOL Capital does not systematically consider them at this time (Art. 4 para. 1 lit. b Disclosure Regulation).

Nevertheless, potential negative impacts on sustainability factors may be reviewed and considered in the decision-making process as part of due diligence or risk management. The decision to invest despite negative impacts remains at the discretion of SOL Capital.

Remuneration policy (Art. 5 Disclosure Regulation)

Sustainability risks are currently not incorporated into the remuneration policy of SOL Capital.