SFDR Disclosure

SFDR DISCLOSURE

Transparency of Sustainability Risk Policy

Wind Point Partners (“Wind Point”) seeks to integrate environmental, social and governance (ESG) factors into its investment process. When evaluating investment opportunities, Wind Point generally considers sustainability risks associated with such opportunities, and it considers whether there are material ESG or reputational concerns with regard to prospective portfolio companies. In particular, Wind Point generally evaluates material ESG risks, mitigating factors and opportunities applicable for the asset type. Wind Point tracks certain relevant data, and where appropriate, integrates such data into the investment research, acquisition and post-acquisition monitoring process. Wind Point’s Investment Committee generally considers material sustainability risks raised during due diligence as part of the decision-making process to invest.

Transparency of Adverse Sustainability Impacts at Entity Level

Wind Point aims to manage the risk connected to adverse impacts from its investments in several ways, including during investment due diligence and as part of monitoring during the period of ownership of a portfolio company. Wind Point has considered, and continues to consider, ESG factors in its investment process to help deliver risk-adjusted returns but it does not consider adverse impacts of investment decisions on sustainability factors as specifically set out in Regulation 2019/2088 on sustainability-related disclosures in the financial services sector dated 27 November 2019 (SFDR). Wind Point has chosen not to do so for the present time as it considers that its existing responsible investment policies and procedures are appropriate, proportional and tailored to the investment strategies of the funds managed by Wind Point. Wind Point continues to closely monitor regulatory developments with respect to the SFDR and other applicable responsible investing laws and regulations, including the implementation of related and secondary legislation and regulatory guidance, and will, where required or otherwise appropriate, make changes to its existing policies and procedures.