SFDR Disclosure

Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”)

SFDR imposes new transparency obligations and periodic reporting requirements on investment management firms (including managers of qualifying venture capital funds within the meaning of Regulation EU No 345/2013) at both a product and firm level. SFDR forms part of the European Commission’s action plan on sustainable finance.

3TS Capital Partners Oy as shareholder and investment advisor of TCEE Fund III GP Sàrl, TCEE Fund IV GP Sàrl and the general partner of Catalyst Romania SCA SICAR which named entities are Luxembourg based alternative investment fund managers (“AIFMs”) makes the following disclosure in accordance with SFDR.

Integration of Sustainability Risks

Sustainability risks, being environmental, social or governance events or conditions that, if they occur, could cause a negative material impact on the value of the investments, are considered by the AIFMs in their investment processes and due diligence procedures.

The AIFMs adopt and implement environmental and social due diligence and monitoring in respect of each of the target portfolio companies of a European venture capital fund managed by it. Certain sectors are completely excluded from investment on environmental, social or governance grounds. The risk management policies of the AIFMs identify sustainability risks as one of those categories of risk to be monitored in the investment and due diligence process.

No Consideration of Principal Adverse Impacts

Article 7 of the SFDR requires disclosure of how principal adverse impacts are considered at the level of the Partnership. The AIFMs are supportive of the policy aims in relation to principal adverse impacts, however, given the number of uncertainties in this area, currently principal adverse impacts (as such term is understood in the SFDR) are not considered by the AIFMs in the investment process. If and to the extent the relevant regulations evolve or a practicable market practice and administrative practice is established in this regard, the AIFMs will consider following them in due course.


The AIFMs are remunerated by means of management fee calculated on either capital commitments to the alternative investment funds managed by them or acquisition costs of investments and in some cases are subject to a cap. Such mechanism does not encourage excessive risk taking and is thus consistent with the integration of sustainability risks into the investment decision making process. Affiliates of the AIFMs are entitled to receive a special return which is dependent of the financial returns of the alternative investment funds managed by them. The risk management process in place regarding the investment decision making process ensures that excessive risk is not encouraged (including as regards sustainability risks).