SFDR Disclosures - Wellington

SFDR Disclosures

Transparency of Sustainability Risk Policies
(SFDR Art. 3)

Commitment to ESG

Wellington Partners is convinced that responsible investment not only creates a closer alignment of objectives among investors, investee companies and society at large, but also leads to enhanced and more sustainable financial returns in the long run. Understanding ESG risks and opportunities can be critical when assessing a company’s value and addressing ESG risks systematically after investment can act as an important lever to add value to Wellington Partners’ portfolio.

Since Wellington Partners makes investments in the life science sector – one of the most regulated industries with high ethical standards – many important ESG issues have always been an integral part of Wellington Partners’ investment considerations. Nevertheless, Wellington Partners is committed to further broadening its perspective on ESG in line with stronger societal demands. Therefore, with the support of independent and external ESG advisors, Wellington Partners has established a customized ESG framework and respective processes.

ESG Framework & Processes

In order to evaluate the ESG compliance of investment targets during the due diligence process, Wellington Partners applies a customized ESG rating tool that allows us to engage with the investee companies’ management to identify and evaluate relevant ESG risks and opportunities. This tool also allows us to define specific ESG targets and performance indicators and to track the progress over time. An appraisal of the prospective portfolio company’s ESG status will be incorporated into Wellington Partners’ internal investment documentation and will be discussed as part of the approval process. Wellington Partners will seek firm commitments from the investment targets to track and report on applicable ESG performance indicators, which will be monitored during the holding period and regularly assessed and discussed at board level. Wellington Partners will periodically report on the status and progress of ESG implementation in its portfolio against pre-defined KPIs. The periodic ESG report will become part of internal discussions on portfolio progress and will be shared with interested LPs. The described ESG Framework and respective processes as well as roles and responsibilities on the integration of sustainability risks in the investment decision-making process are outlined in detail within Wellington Partners’ ESG Policy.

ESG at Wellington Partners

Wellington Partners’ ESG activities are coordinated by an internal ESG team, which is supported by independent and external ESG consultants. The ESG team is responsible for developing the ESG Policy, establishing analytical ESG frameworks and processes, and leading internal advocacy. Since each investment manager is responsible for ensuring that ESG criteria are integrated into an investment decision and followed through by the portfolio company, the ESG team will organize regular training for the investment team to stay informed on current regulatory requirements, investor expectations, market developments and internal sustainability commitments. All team members at Wellington Partners have signed up and adhere to the firm’s compliance regulation, which comprises several separate policies adopted by Wellington Partners according to its commitment to responsible investment and compliance management.

Transparency of Adverse Sustainability Impacts at Entity Level
(SFDR Art. 4)

Statement on Principal Adverse Impacts of Investment Decisions on Sustainability Factors

Summary

Wellington Partners considers principal adverse impacts (PAIs) of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of Wellington Partners. This statement on principal adverse impacts on sustainability factors covers the reference period from 1 January to 31 December 2024. The adverse sustainability indicators applicable to investments in investee companies as defined by Table 1 (and where relevant Table 2 and 3) of Annex I of the Delegated Regulation 2022/1218 is reported here (see tables below).

However, it should be noted that the database for the present PAI statement is only based on data from Wellington Partners’ Fund VI investee companies since the respective regulations had not entered into force and/or been applicable at the time of Wellington Partners’ Fund IV and Fund V investments. Wellington Partners will try to collect data for Fund IV and Fund V in the near future to provide a “consolidated” statement at entity level.

Statement on principal adverse impacts of investment decisions on sustainability factors:

Adverse sustainability indicator		Metric	Unit	Impact 2024	Impact 2023	Explanation	Actions taken, and actions planned and targets set for the next reference period
Greenhouse gas emissions	1. GHG emissions	Scope 1 GHG emissions	tCO₂e	19.89	0.00	Scope 1 emissions are direct emissions from owned or controlled sources. In 2024, Wellington Partners’ portfolio grew by 60%. Consequently, the number of Scope 1 GHG emissions has increased with more investee companies reporting their GHG emissions.	In the impact year 2024, GHG metrics have been collected through the use of a dedicated questionnaire created with the aim of monitoring specific indicators that are key for Wellington Partners, both for reporting purposes and our strong commitment towards implementing sustainable practices within our portfolio. Wellington Partners encourages its investee companies to achieve a notable decrease in GHG emissions and GHG intensity.
		Scope 2 GHG emissions	tCO₂e	13.85	1.88	Scope 2 emissions are indirect emissions from the generation of purchased energy. In 2024, Wellington Partners’ portfolio grew by 60%. Consequently, the number of Scope 2 GHG emissions has increased with more investee companies reporting their GHG emissions.
		Scope 3 GHG emissions	tCO₂e	24.67	21.88	Scope 3 emissions are all indirect emissions (not included in Scope 2) that occur in the value chain of the reporting company, including both upstream and downstream emissions. In 2024, Wellington Partners’ portfolio grew by 60%. Consequently, the number of Scope 3 GHG emissions has increased with more investee companies reporting their GHG emissions.
		Total GHG emissions	tCO₂e	58.4	23.76	In 2024, Wellington Partners’ portfolio grew by 60%. Consequently, the total GHG emissions have increased with more investee companies reporting their Scope 1, 2 and 3 GHG emissions.
	2. Carbon footprint	Carbon footprint	tCO₂e / million € invested	0	0	The carbon footprint is calculated by collecting actual Scope 1 and Scope 2 emissions from the investee companies and multiplying the number by Wellington Partners’ share of equity. Since the total emissions results from portfolio companies are considerably low, the aggregated result is 0.	Wellington Partners requires all of its investee companies to calculate their carbon footprint according to the GHG protocol. The GHG Protocol establishes comprehensive global standardized frameworks to measure and manage greenhouse gas (GHG) emissions from private and public sector operations, value chains and mitigation actions. As Wellington Partners invests in early-stage start-ups, their own operational footprint is marginal. However, as we add new companies to our portfolio and these start to scale, we expect the carbon footprint across the fund’s investments to grow.
	3. GHG intensity of investee companies	GHG intensity of investee companies	tCO₂e / million € of revenue	11.68	14.2	This ratio illustrates the intensity of GHG emissions relative to the revenue generated by the investee companies.
	4. Exposure to companies active in the fossil fuel sector	Share of investments in companies active in the fossil fuel sector	%	0%	0%	As fossil fuel-based energy production and related activities are part of Wellington Partners’ Exclusion Policy, the share of investments in companies active in the fossil fuel sector will always be 0%.
	5. Share of non-renewable energy consumption and production	Share of non-renewable energy consumption and non-renewable energy production of investee companies from non-renewable energy sources compared to renewable energy sources, expressed as a percentage of total energy sources	%	Consumption: 60% Production: 0%	Consumption: 68% Production: 0%	In 2024, the share of energy consumption from renewable sources has increased. However, Wellington Partners’ investee companies still utilized more non-renewable energy sources than renewable ones.	All portfolio companies are encouraged to maximise their use of renewable/low-carbon energy.
	6. Energy consumption intensity per high impact climate sector	Energy consumption in GWh per million EUR of revenue of investee companies, per high impact climate sector	GWh / million € of revenue (per sector)	N/A	N/A	Since Wellington Partners has not generated any revenue from sales of WPLS-VI investee companies in 2024, a calculation is not possible.
Biodiversity	7. Activities negatively affecting biodiversity-sensitive areas	Share of investments in investee companies with sites/operations located in or near to biodiversity-sensitive areas where activities of those investee companies negatively affect those areas	%	0%	0%	Currently, none of Wellington Partners’ investee companies have sites/operations located in or near to biodiversity-sensitive areas.	Wellington Partners has incorporated a climate and biodiversity risk assessment, aligned with the TCFD, in its investment process. This assessment is an integral part of our pre-investment evaluation for new deals and remains an ongoing process throughout the holding period, ensuring a continuous monitoring of these risks.
Water	8. Emissions to water	Tonnes of emissions to water generated by investee companies per million EUR invested, expressed as a weighted average	# tonnes / million € invested	0	0	No emissions to water were generated by our investee companies in 2024.	Companies within our portfolio must report on their emissions to water annually. The quantities of emissions to water will be monitored, and potential actions to mitigate this adverse indicator will be analysed in the coming years.
Waste	9. Hazardous waste and radioactive waste ratio	Tonnes of hazardous waste and radioactive waste generated by investee companies per million EUR invested, expressed as a weighted average	# tonnes / million € invested	0	0	No hazardous waste and/or radioactive waste was generated by our investee companies in 2024.	Companies within our portfolio are required to report annually on their hazardous and radioactive waste ratios. The quantities of hazardous and radioactive waste will be monitored, and potential actions to mitigate this adverse indicator will be analysed. To the extent possible, Wellington Partners will collaborate with investee companies to minimize hazardous waste generation. If an investee company produces a significant amount of hazardous waste, Wellington Partners will encourage the company to ensure proper waste management procedures (incl. collection and disposal by reputable and well-regulated environmental service providers) and ensure that adequate safety protocols are followed.
Additional mandatory voluntary PAI Indicators
Emissions	4. Investments in companies without carbon emission reduction initiatives	Share of investments in investee companies without carbon emission reduction initiatives aimed at aligning with the Paris Agreement	%	100%	100%	Currently, none of Wellington Partners’ investee companies have any written carbon emission reduction initiatives.	Wellington Partners encourages its investee companies to adopt and implement carbon emission reduction policies. These initiatives aim to raise awareness and to assist companies in monitoring and minimizing their carbon footprint.

Additional indicators for social and employee, human rights, anti-corruption and anti-bribery matters:

Adverse sustainability indicator		Metric	Unit	Impact 2024	Impact 2023	Explanation	Actions taken, and actions planned and targets set for the next reference period
INDICATORS FOR SOCIAL AND EMPLOYEE, RESPECT FOR HUMAN RIGHTS, ANTI-CORRUPTION AND ANTI-BRIBERY MATTERS
Social and employee matters	10. Violations of UN Global Compact principles and Organisation for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises	Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	%	0%	0%	Wellington Partners acts in accordance with the International Labor Organization (ILO) standards, United Nations Guiding Principles (UNGPs), United Nations Global Compact (UNGC) Principles and the Organization for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, and is guided by these international standards to assess the behavior of its investee companies.
	11. Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises	Share of investments in investee companies without policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises or grievance/complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	%	50%	72%	In 2024, the share of investments in investee companies with written policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises or grievance/complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises increased by 22%.	Investment targets are primarily SMEs, often with informal compliance mechanisms rather than formalised policy frameworks. Formalising these informal mechanisms typically represents an opportunity to review, enhance and professionalise compliance frameworks. If any procedure is found to be missing or implementation seems to be improper, Wellington Partners will work with its investee company to set up adequate mechanisms and oversight (e.g. anti-corruption policy and procedure).
	12. Unadjusted gender pay gap	Average unadjusted gender pay gap of investee companies	%	15%	9%	The unadjusted gender pay gap is defined as the difference between the average gross hourly earnings of men and women expressed as a percentage of the average gross hourly earnings of men. As early-stage companies may have only a few employees at the point of investment, this indicator is and will be highly sensitive to small changes, incl. the addition/removal of individuals.
	13. Board gender diversity	Average ratio of female to male board members in investee companies, expressed as a percentage of all board members	%	27%	19%	Board is defined as the administrative, management or supervisory body of a company. In 2024, the percentage of female board members in investee companies increased by 8%.	Wellington Partners encourages its investee companies to increase the number of female board members.
	14. Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons)	Share of investments in investee companies involved in the manufacture or selling of controversial weapons	%	0%	0%	As exposure to controversial weapons is part of Wellington Partners’ Exclusion Policy, the share of investments in investee companies involved in the manufacture or selling of controversial weapons will always be 0%.
Additional mandatory voluntary PAI Indicators
Social and employee matters	15. Lack of anti-corruption and anti-bribery policies	Share of investments in entities without policies on anti-corruption and anti-bribery consistent with the United Nations Convention against Corruption	%	36%	40%	Wellington Partners decided to monitor this additional indicator as the existence of anti-corruption and anti-bribery policies in our investee companies is in line with our Responsible Investment Policy.	SMEs often have informal anti-corruption and anti-bribery policies and commitments in place. Formalising these informal commitments presents an opportunity to review, enhance and professionalise compliance frameworks. Wellington Partners will continue to monitor this indicator in the coming years and will raise awareness among its investee companies about the importance of implementing anti-corruption measures.

Description of policies to identify and prioritize principal adverse impacts of investment decisions on sustainability factors

Wellington Partners’ ESG Policy describes all relevant ESG-related processes including the identification and prioritization of principal adverse impacts on sustainability factors. Certain PAIs have been prioritized and are part of Wellington Partners’ exclusion criteria, such as the “exposure to controversial weapons”. The governing body of Wellington Partners approved this policy on 27 May 2021 and the last updated version is dated 30 April 2025. The responsibility for the implementation of this policy is integrated within organizational strategies and allocated on management level as well as within the dedicated ESG team and each investment manager. The two additional indicators were selected based on their relevance for and expected data availability at the portfolio companies and potential future targets. The status on data availability with regards to all (14+2) indicators is assessed as part of the ESG due diligence. Furthermore, the probability of occurrence and the severity of those principal adverse impacts is estimated and their potentially irremediable character is assessed. In case any significant risks or severe negative impacts with irremediable character are identified, Wellington Partners will not invest in such a target. As Wellington Partners invests in early and growth stage companies, the data to assess the PAIs might not be fully available at the time of acquisition, which could lead to a minor margin of error in the assessment of the PAIs at the time of acquisition. However, any data gaps will be filled during the holding period by obtaining the information directly from investee companies and the initial assessment of the PAIs will be revised respectively. Initial data sources used include documentation received from the potential target during the due diligence process (e.g. through the data room) and through interviews with the management of the potential targets. Additional documentation and relevant data points will be collected from the investee companies during the holding period and will be monitored on a yearly basis.

Engagement Policies

Wellington Partners engages with its portfolio companies to support the collection and reporting of principal adverse impacts on sustainability factors. Wellington Partners’ engagement policy generally covers all (14+2) indicators as shown in the tables above, and the development of the principle adverse impacts with the investee companies will be monitored over the periods reported on. Where possible, Wellington Partners will encourage its portfolio companies to reduce their principal adverse impacts on sustainability factors through adequate improvement measures. However, due to its minority holdings, the level of engagement might be limited. In these cases, Wellington Partners will undertake its best efforts to promote the consideration of PAI improvements.

Reference to International Standards

To undermine its commitment to avoiding adverse sustainability impacts, Wellington Partners is a signatory of the UN Principles for Responsible Investment and its ESG due diligence approach is generally aligned with the Ten Principles of the UN Global Compact (UNGC). To measure the adherence to the UN Global Compact principles, the following PAIs are used:

Violations of UN Global Compact principles and Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises
Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises

Adherence with the ten principles of the UNGC along the topics of human rights, labor, environment and anti-corruption is assessed as part of the ESG due diligence in the acquisition phase and is monitored on a yearly basis as part of regular ESG reviews. Relevant data is collected directly from the potential targets and investee companies. By addressing these topics already in the due diligence phase, the principal adverse impacts of potential targets are forecasted to the extent possible for the holding phase.

Wellington Partners takes a pragmatic approach to assess climate-related risks which are considered on a high level as part of the ESG due diligence. Comprehensive forward-looking climate scenarios are not used.

Transparency of Remuneration Policies in Relation to the Integration of Sustainability Risks
(SFDR Art. 5)

Wellington Partners’ compensation policies are structured to incentivize investment managers to promote sustainable growth within investments. Consequently, the remuneration model includes a variable component that qualitatively takes into account compliance with the firm’s sustainability principles, such as successful internal training on these principles, the application of ESG processes and methodologies in the investment process, and the regular monitoring and communication of ESG measures.

Furthermore, the compensation model of Wellington Partners includes a carried interest component which, among others, reflects the sustainability performance of investments.

Product-Level Disclosure
(SFDR Art. 8)

Summary

The information described below applies to Wellington Partners Life Sciences VI GmbH & Co. KG (“WPLS-VI”). WPLS-VI promotes environmental or social characteristics but does not have as its objective sustainable investments. ESG is an essential part of the investment strategy and is integrated through the whole investment process. ESG-related exclusion criteria are applied, ESG topics are assessed during the due diligence, considered as part of the investment decision and monitored during the holding phase. A proprietary ESG rating tool is applied for the initial assessment as well as the regular monitoring process. Wellington Partners engages with investee companies to support the improvement of their ESG performance to the extent possible.

No Sustainable Investment Objective

WPLS-VI promotes environmental or social characteristics but does not have as its objective sustainable investments.

Environmental or Social Characteristics of the Financial Product

To ensure that all investee companies are aligned with its ESG values, WPLS-VI does not invest in companies or venture engaged in the following activities:

Human Rights Violations: Companies that engage in activities that violate human rights, including but not limited to forced labour, child labour, discrimination and unfair treatment of employees or communities.
Environmental Harm: Companies engaged in activities that cause significant harm to the environment, including but not limited to deforestation and the destruction of biodiversity.
Illegal Economic Activities: Companies whose business activities, after conducting due diligence, engage in any economic activities that are illegal under applicable laws or regulations.
Non-Compliance with Local and International Laws: Companies that fail to comply with legal standards and regulations within their jurisdiction, including local, European Union (EU) and international laws, particularly those pertaining to corruption, bribery and tax evasion.
Weapons and Military Technology: Companies engaged in the manufacturing, sale or distribution of weapons, ammunition or other military-related technologies, including those that contribute to conflicts or escalate violence.
Nuclear Energy and Nuclear Waste: Companies engaged in the production, distribution or disposal of nuclear energy and nuclear waste, including those involved in the mining, processing or sale of radioactive materials.
Fossil Fuel-Based Energy Production: Companies engaged in the production of fossil fuel-based energy and related activities.
High CO₂-Emitting Industries: Companies involved in energy-intensive and high CO₂-emitting industries, including but not limited to steel and cement manufacturing, mining and the extraction of natural resources.
Tobacco and Alcohol: Companies whose primary business involves the production, distribution or sale of tobacco products and alcoholic beverages.
Gambling and Betting: Companies that generate a significant portion of their revenue from gambling, betting or other similar activities that are linked to considerable social harm.
Adult Entertainment: Companies operating within the adult entertainment industry, including pornography, adult films and associated services.
Electronic Data Programs Related to Harmful Activities: Companies engaged in the research, development or technical application of electronic data programs that (i) support any of the aforementioned activities, and/or (ii) are designed to facilitate unauthorized access to electronic data networks or the illegal downloading of electronic data.
Non-Compliant Jurisdictions and Sanctioned Entities: Companies that (i) have violated any United Nations treaties or conventions, (ii) are headquartered in or conduct a significant portion of their business in any country subject to economic and financial sanctions imposed by Germany and the European Union, (iii) are headquartered in or conduct a substantial amount of their business in any country listed as a Non-Cooperative Country and Territory (NCCT) by the Financial Action Task Force (FATF), or (iv) have key personnel who are subject to sanctions from Germany and/or the European Union, or where sanctioned individuals would benefit from Wellington’s funds.

In the healthcare sector, Wellington Partners meticulously evaluates the ethical, legal and regulatory implications of various practices and technologies. The following points outline our approach to several key areas that require special consideration:

Human Cloning and GMOs: When providing support for the financing of research, development or technical applications related to (i) human cloning and the creation of human embryos for research or therapeutic purposes, or (ii) genetically modified organisms (GMOs), we will ensure appropriate oversight of the legal, regulatory and ethical issues associated with these activities.

Animal Experimentation: Any animal experimentation conducted by portfolio companies must comply with EU and/or US regulations and adhere to the standards set by the Association for Assessment and Accreditation of Laboratory Animal Care International certification and/or comparable standards. Additionally, these companies must follow the “three R-principles” (replacement, reduction, refinement) in accordance with industry standards.
Nuclear Medicine: We permit investments in companies that develop radionuclides for diagnostics, therapeutics, and/or other medical application, provided that these technologies aim to enhance healthcare and medical treatments while aligning with our commitment to advancing innovative, life-enhancing solutions.

Furthermore, WPLS-VI considers the following ESG topics as part of its ESG due diligence assessment of any potential investments:

Environment

Social

Governance

· Climate protection and mitigation (e.g. reducing greenhouse gas emissions);

· Climate change resilient business models and raising awareness;

· Transition to a circular economy (e.g. limiting production of waste, improving recycling);

· Responsible handling of hazardous materials;

· Avoidance and reduction of environmental pollution (to air, land and water);

· Responsible use and protection of water and maritime resources;

· Protection of biodiversity and healthy ecosystems;

· Sustainable resource management.

· Employment safety and health protection;

· Appropriate remuneration and fair working conditions;

· Diversity, equal opportunity, training and development opportunities;

· Compliance with labor standards (no child labor, forced labor or discrimination);

· Adequate product safety incl. health protection;

· Customer welfare;

· Safety and wellbeing of clinical trial participants;

· Replace, reduce and refine animal testing (3Rs principle);

· Fair preliminary market access strategy;

· Ethical Marketing, fair selling practices and product labelling;

· Access & affordability (fair pricing policies);

· Business ethics and sound ethical mission and values;

· Board independence, quality and diversity;

· Adherence to prevailing principles of ethics in biomedical research;

· Anti-bribery and -corruption measures;

· Data protection and privacy;

· Transparent information disclosure;

· Independent and qualified clinical oversight;

· Quality assurance and internal controls;

· Facilitation of whistle blowing.

In case any severe risks are identified with regards to any of the above listed ESG topics, this might lead to a negative investment decision. Where relevant, improvement measures are defined which will be monitored during the holding phase.

Investment Strategy

With WPLS-VI, Wellington Partners focuses on the development of innovative therapeutics, medical technology, diagnostics and digital health products addressing high unmet medical needs and will selectively consider opportunities in the field of industrial biotechnology. The above-mentioned investment exclusions, i.e. the understanding of ESG risks and opportunities of investment targets in detail during due diligence and systematically monitoring and addressing ESG compliance after the initial investment, is a standard component of Wellington Partners’ investment strategy. The integration of ESG considerations along the whole investment process is described in Wellington Partners’ ESG Policy and includes an assessment of environmental, social and governance aspects of the investee companies as part of Wellington Partners’ ESG due diligence as well as during annual ESG updates. The ESG assessment includes the assessment of good governance practices with respect to sound management structures, employee relations and remuneration of staff. In addition, a legal due diligence is conducted which also covers tax compliance topics. If any tax related risks are identified, a detailed tax due diligence is conducted to ensure tax compliance.

Proportion of Investments

The consideration of environmental and social characteristics is an integral part of Wellington Partners’ investment strategy. Therefore, 100% of investments within the WPLS-VI fund are aligned with the fund’s ESG policy and all investments are direct investments. While the focus is not to set specific environmental or social characteristics, all portfolio companies are assessed with regards to a large set of sustainability criteria (see table above) and the improvement of their overall ESG performance is actively supported through respective recommendations and monitoring of their implementation.

Monitoring of Environmental or Social Characteristics

The consideration of environmental and social characteristics is carried out both before and after the investments. Wellington Partners incorporates the above-mentioned exclusion (negative screening) aspects during its decision-making process. All ESG topics are initially assessed during the due diligence phase. After the investment, the ESG status is monitored during the holding period and information is regularly obtained from the portfolio companies using a proprietary rating tool.

Methodologies for Environmental or Social Characteristics

In order to evaluate the ESG compliance of investment targets during the due diligence process, Wellington Partners uses a customized rating tool. The rating tool follows the recommendations for financial advisors by Principles for Responsible Investment and Invest Europe and reflects healthcare-specific sustainability issues, such as access to medicine and patient safety as provided by the Sustainability Accounting Standards Board.

An appraisal of the prospective portfolio company’s ESG status is incorporated into Wellington Partners’ internal investment documentation and discussed as part of the approval process.

With the ESG rating tool, each ESG aspect is assessed on a scale from 0-4 and an overall ESG score is calculated for each portfolio company which is tracked during the holding period. The rating tool is adapted to the context of early-stage companies and structured along essential business model components. In addition, relevant KPIs (based on the PAIs) are collected and monitored on a yearly basis.

Data Sources and Processing

The main data sources regarding ESG data are internal documents and information provided by the portfolio companies. These are complemented by public information, e.g. from their website or press releases. To ensure data quality and due to a common lack of documentation in early-stage companies, interviews are held with the company’s management as part of the ESG due diligence and regular update process. Furthermore, a four-eye principle is applied in the sourcing and processing of the data. The information collected within these processes then serves as input into Wellington Partners’ rating tool.

Relevant ESG data is processed and aggregated through the ESG rating tool and serves as a basis to prepare periodic reports. In case of data gaps, relevant data will be estimated or indicated as not available. Wellington Partners will periodically report on the status and progress of ESG implementation in its portfolio against pre-defined KPIs. The periodic ESG report will become part of Wellington Partners’ internal discussion on portfolio progress and will be shared with interested LPs.

Limitations to Methodologies and Data

The information collected via the due diligence process for the fund is externally verified only if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may remain undetected in certain cases. Furthermore, due to the early stage of the portfolio companies, data availability and quality may be limited. However, Wellington Partners applies reasonable effort to improve data availability and quality through active engagement with the portfolio companies to increase their awareness of ESG topics and related data.

Due Diligence

An ESG Due Diligence is conducted for all potential targets before acquisition by the investment team. Wellington Partners’ proprietary ESG rating tool is applied as described under the above section “Methodologies for environmental or social characteristics”. The 4-eye-principle is applied as internal control during the due diligence to ensure adequate quality of the results which are considered during the investment decision. As a final control, the summary of the ESG due diligence results is part of the overall investment documentation and is discussed by the investment committee during the investment decision.

Engagement Policies

The ESG rating tool will allow Wellington Partners to engage with the investee companies’ management to define specific ESG targets. Wellington Partners seeks firm commitments from the investment targets to track and report on applicable ESG performance indicators, which will be monitored during the holding period and regularly assessed and discussed at board level. In case any sustainability-related controversies or incidents are identified in investee companies, a clear reporting procedure has been established as part of Wellington Partners’ ESG policy, which defines the content to be disclosed to investors as soon as practicable after becoming aware of any such event.

Designated Reference Benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by WPLS-VI.