Last updated: 21 October 2025

Waves Capital Fund Management B.V. — Website Disclosure on Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”)

Waves Capital Fund Management B.V. (“Waves Capital” or “the Firm”) makes the following disclosures in accordance with Articles 3(1), 4(1)(b) and 5(1) of the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”).

Sustainability Integration and ESG Approach
Waves Capital Fund Management B.V. is a venture capital investment firm focused on early- and growth-stage companies across both hardware and software sectors. The Firm seeks to identify and support innovative businesses with long-term growth potential.

While Waves Capital recognizes the importance of environmental, social, and governance (“ESG”) factors and sustainability considerations, the Firm does not currently promote specific ESG characteristics or pursue sustainable investment objectives within the meaning of Articles 8 or 9 of the SFDR. Accordingly, Waves Capital is classified as an Article 6 fund under the SFDR.

Waves Capital considers sustainability risks as part of its overall investment decision-making process, in line with its responsibility to act in the best interests of its investors. The Firm assesses potential environmental, social, and governance risks where these may have a material impact on the value or performance of an investment.

The Firm does not currently maintain a formal Code of Conduct or dedicated ESG policy, though it may adopt such policies in the future as its investment operations and regulatory environment evolve. Similarly, Waves Capital does not perform standalone ESG reporting but may include relevant information on ESG matters when such data is provided by portfolio companies as part of their regular reporting.

Sustainability Risk Policies
A sustainability risk is defined as 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.

Before making any investment decisions, Waves Capital conducts a thorough due diligence process covering financial, legal, fiscal, and operational aspects. Where relevant, sustainability risks and ESG considerations are assessed as part of this process. These risks are evaluated alongside other material factors influencing investment performance.

If material ESG risks are identified during due diligence, Waves Capital may further assess their potential impact on the investment opportunity. Where such risks are considered unmanageable or disproportionate, the Firm may decide not to proceed with the investment. Where risks are deemed acceptable, they may be monitored during the ownership period in line with the Firm’s standard portfolio oversight practices.

Principal Adverse Impacts
In accordance with Article 4(1)(b) of the SFDR, Waves Capital does not currently consider the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors. This decision reflects the nature, scale, and resources of the Firm, as well as the type of investments it makes in early-stage companies, for which consistent and reliable sustainability data is often unavailable. Waves Capital will continue to monitor regulatory developments and market practices in this area and may revisit this position in the future.

Remuneration Policy
Waves Capital’s remuneration policy is designed to encourage long-term performance and prudent risk management. The policy combines fixed remuneration (salary and benefits) with variable components (including performance-based remuneration) that reflect the success of the Firm and its portfolio companies.

Variable remuneration for relevant staff is determined fairly, objectively, and in a manner consistent with responsible risk-taking. Although sustainability risks are considered in the investment process, the Firm’s remuneration structure does not create incentives for excessive risk-taking in relation to sustainability or any other factors. The policy is reviewed periodically to ensure compliance with applicable laws and best practices.

Periodic Review
Waves Capital reviews this SFDR disclosure on a periodic basis and will update it as necessary to reflect material changes in its approach to sustainability risk management, regulatory developments, or investment strategy.