Legal

SFDR disclosures.

Hiro Capital NSCALE I SCSp

Hiro Capital NSCALE I GP SARL, a private limited liability company (société à responsabilité limitée), with registered office at 22, rue des Bruyères, L-1274 Howald, Grand Duchy of Luxembourg, and registered with the RCS under number B309367 (the "AIFM") hereby makes the following disclosures for the purposes of the Sustainable Financial Disclosure Regulation (EU) 2019/2088 (the "SFDR") amended by Regulation (EU) 2020/852 (the "Taxonomy Regulation").

The AIFM acts as the alternative investment fund manager of Hiro Capital NSCALE I SCSp (the "Fund").

General

The Fund is a "neutral fund" that classifies as an Article 6 fund under the SFDR on the basis that it does not promote sustainability nor has it sustainable investment as its objective.

SFDR distinguishes three regimes:

  1. The neutral regime for investment funds that do not have sustainability features;
  2. The light green regime for investment funds that promote sustainability; and
  3. The dark green regime for investment funds that have sustainable investments as their objective.

Definitions

The following definitions are relevant:

A "sustainable investment" is defined as an investment in an economic activity that contributes to an environmental objective, as measured, for example, by key resource efficiency indicators on the use of energy, renewable energy, raw materials, water and land, on the production of waste, and greenhouse gas emissions, or on its impact on biodiversity and the circular economy, or an investment in an economic activity that contributes to a social objective, in particular an investment that contributes to tackling inequality or that fosters social cohesion, social integration and labor relations, or an investment in human capital or economically or socially disadvantaged communities, provided that such investments do not significantly harm any of those objectives and that the investee companies follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.

"No significant harm" means that for each environmental objective, uniform criteria for determining whether economic activities contribute substantially to that objective should be laid down. One element of the uniform criteria should be to avoid significant harm to any of the environmental objectives. This is in order to avoid that investments qualify as environmentally sustainable in cases where the economic activities benefitting from those investments cause harm to the environment to an extent that outweighs their contribution to an environmental objective.

"Environmental objective" means the objectives as laid down in Article 9 of the Taxonomy Regulation. "Promoting sustainability" means a product (e.g a fund) promotes among other characteristics, environmental or social characteristics, or a combination of those characteristics, provided that the companies in which the investments of the fund are made, follow good governance practices.

"Sustainability risk" means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

"Sustainability factors" mean environmental or social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. This is what is or can be impacted by investment decisions.

AIFM-related disclosures

Transparency of sustainability risk policies and transparency of the integration of sustainability risks — article 3(1) SFDR

The AIFM does not integrate sustainability risks in its investment decision-making process, notably in view of the investment strategy and restrictions applicable to the Fund, for which sustainability risks are not relevant. The sustainability risks will not likely have an adverse effect on the Fund's returns, i.e. if any such risk arises, it is not likely to have a more materially adverse effect on the Fund's returns than any other normal market, operational or external risk.

No consideration of adverse impacts of investment decisions on sustainability factors — article 4(1)(b) SFDR

The AIFM does not consider the adverse impacts of its investments decisions on sustainability factors at its own level and in respect of investments of the Fund in the manner prescribed by SFDR due to (i) the investment approach that it follows that does not take sustainability into account (ii) the lack of reliable and sufficiently available or accessible data to perform such impact measurement and to provide the mandatory reporting imposed by the regulatory technical standards in a consistent manner and (iii) the size of the AIFM and the limited resources available to it, the cost and operational burden of implementing the necessary processes to measure this accurately would be disproportionate given the AIFM's scale.

The AIFM does not intend to consider principal adverse impacts of investment decisions on sustainability factors in the near future.