Sustainability-related disclosures
Green Flag Fund II GP S.à r.l., 12, rue des Mérovingiens, L-8070 Bertrange, Luxembourg (RCS Luxembourg B309730), is registered with the Commission de Surveillance du Secteur Financier as an alternative investment fund manager under Article 3(2)(b) of the Luxembourg law of 12 July 2013 on alternative investment fund managers. It acts as general partner and alternative investment fund manager of Green Flag Fund II SCSp. The disclosures below are made under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR). Last updated: 7 October 2026.
1. Integration of sustainability risks (Article 3 SFDR)
A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. Green Flag Fund II GP S.à r.l. integrates sustainability risks into its investment decisions as part of its due diligence on each prospective investment. The investment team identifies environmental, social and governance factors that could materially affect the value of the investment, and those findings are considered by the investment committee alongside the other risks of the investment. Material sustainability risks identified at investment are monitored during the holding period through the manager's regular engagement with portfolio companies. Given the early-stage technology companies in which the fund invests, the manager considers that sustainability risks are unlikely to be a principal driver of the fund's returns.
2. No consideration of adverse impacts of investment decisions on sustainability factors (Article 4(1)(b) SFDR)
Green Flag Fund II GP S.à r.l. does not consider the principal adverse impacts of its investment decisions on sustainability factors. The manager is a small organisation managing a single venture capital fund that invests in early-stage private companies, which do not produce the data needed to report against the indicators set out in the regulatory technical standards under SFDR. Collecting and reporting that data would be disproportionate to the size of the manager and the fund. The manager will review this position at least annually and if the nature or scale of its activities changes.
3. Remuneration policy (Article 5 SFDR)
The remuneration arrangements of Green Flag Fund II GP S.à r.l. are consistent with the integration of sustainability risks described above. Remuneration is not linked to sustainability metrics and does not encourage risk-taking that is inconsistent with the sustainability-risk profile of the fund.
4. Classification of the fund
Green Flag Fund II SCSp does not promote environmental or social characteristics and does not have sustainable investment as its objective (Article 6 SFDR). The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities.