Please, find below the Sustainable Finance Disclosure Regulation (SFDR) for LAUNCHub Fund II and LAUNCHub Fund III.
SFDR Disclosures – LAUNCHub Fund II Management B.V. and of LAUNCHub Fund II Coöperatief U.A.
Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)
On 10 March 2021, the Sustainable Finance Disclosure Regulation (Regulation (EU) 2019/2088), the SFDR) came into force. This European Regulation requires certain financial market participants (such as managers of alternative investment funds) to publish sustainability-related information on their website and in pre-contractual disclosures.
1. Sustainability risks
At LAUNCHub Ventures, we integrate the consideration of sustainability risks into our investment decision-making process. These risks encompass environmental, social, or governance issues that could potentially or actually impact the value of an investment significantly. In our due diligence process, prior to making any investment, we conduct an assessment of these sustainability risks using a specialized questionnaire. The findings from this assessment play a role in shaping our investment decisions. However, we retain the autonomy to make investment choices, whether to invest or abstain, regardless of the sustainability risks identified. In all our investment decisions, we adhere to the principle of proportionality, giving due consideration to the strategic significance of the investment and the specifics of the transaction context. However, we consciously steer clear of industries that have a high environmental impact. This means no investments in sectors like manufacturing, oil and gas, heavy machinery, tobacco or other.
2. No consideration of adverse impacts of investment decisions on sustainability factors
At LAUNCHub, we do not consider the adverse impacts of our investment decisions on sustainability factors due to insufficient reliable data available to adequately analyze these principal adverse impacts and integrate them into the investment decision-making process.
Should there be enhancements in the availability and dependability of sustainability data, along with greater clarity in the legal framework concerning the evaluation of these impacts, we might consider incorporating the principal adverse impacts of investment decisions on sustainability factors in the future. In this regard, LAUNCHub keeps a close watch on the progress and updates related to the SFDR and its associated delegated laws and regulations.
3. Remuneration
In line with regulatory requirements LAUNCHub does not have a remuneration policy and therefore does not integrate sustainability risks into such a policy.
SFDR Disclosures – LAUNCHub Fund III Management B.V. and of LAUNCHub Fund III Coöperatief U.A.
SFDR Disclosures – LAUNCHub Fund III Management B.V. and of LAUNCHub
Fund III Coöperatief U.A.
Published on November 17th, 2025.
LAUNCHub Fund III Management B.V. (the AIFM), a Dutch-based registered alternative investment fund manager within the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 on alternative investment fund managers (AIFMD), makes the following disclosures for the purposes of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation). As clarified by the European Commission in its Q&As on sustainability-related disclosures published on 14 July 2021, the AIFM must comply with certain SFDR requirements applicable to registered alternative investment fund managers.
The AIFM acts as registered alternative investment fund manager of LAUNCHub Fund III Coöperatief U.A. (the Fund).
The Fund qualifies under article 6 of the SFDR as it does not promote environmental or social characteristics (article 8 of the SFDR) nor does it have sustainable investments as its objective (article 9 of the SFDR).
I. AIFM-related disclosures
Transparency of sustainability risk policies and transparency of the integration of sustainability risks – article 3(1) and article 6 of the SFDR
General overview
A sustainability risk refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.
The AIFM does not integrate sustainability risks in its investment decision-making process for the following reasons:
(i) the performance tools used by the AIFM to estimate returns of the Fund do not take into account such risks but mainly economic and financial risks;
(ii) since the portfolio companies in which the Fund invests do not usually report on such risks, the AIFM is not in a position to assess and integrate such risks in its investment decision-making process;
(iii) the AIFM is managing the Fund that intends to invest exclusively in portfolio companies that focus on software solutions, for which the returns should not be impacted by sustainability risks; and
(iv) in view of the AIFM size it is not intended to change the investment decision-making process of the AIFM to integrate such sustainability risks as this will be too costly and not relevant with respect to the Fund. No consideration of adverse impacts of investment decisions on sustainability factors – article 4(1)(b) of the SFDR Article 4(1) of the SFDR requires fund managers such as the AIFM to provide a clear statement as to whether or not they consider the "principal adverse impacts" of investment decisions on sustainabilityfactors, e.g. environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
Although ESG and sustainability risks are important to the AIFM, the latter does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by article 4(1) of the SFDR, in particular due to the fact that (i) no reliable and sufficiently available or accessible data is available to perform such impact measurement and provide the mandatory reporting imposed by the regulatory technical standards in a consistent manner; and (ii) the underlying investments are not generally required to report on such factors in the manner prescribed by SFDR.
The AIFM does not intend to consider principal adverse impacts of investment decisions on sustainability factors in the near future. Transparency of remuneration policies in relation to the integration of sustainability risks – article 5(1) of the SFDR.
For the purposes of article 5(1) of the SFDR, the AIFM declares that it has not put in place a remuneration policy in light of the fact that it qualifies as a registered alternative investment fund manager and thus does not fall under such requirement under the AIFMD.
II. Fund-related disclosures
Transparency of other financial products in pre-contractual disclosures and in periodic reports – article 7 of the Taxonomy Regulation
The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.