Statement on Principal Adverse Impacts of Investment Decisions on Sustainability Factors

Financial market participant: Ardabelle Capital

Reference period: 1 January 2025 – 31 December 2025

Summary

Ardabelle Capital considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of Ardabelle Capital.

This statement on principal adverse impacts on sustainability factors covers the reference period from 1 January 2025 to 31 December 2025.

As this is the first reporting period for the fund and no investments were held during the reference period, all indicators are reported as not applicable (n.a.). Ardabelle Capital will begin collecting and disclosing adverse sustainability indicators from investee companies once the first investments are made.

Description of the Principal Adverse Impacts on Sustainability Factors

As all investments made by Ardabelle Capital are expected to have environmental impacts, portfolio companies will be required to report their principal adverse impacts on sustainability. These impacts are defined by the European Union as “negative, material, or likely to be material effects of investment decisions on sustainability factors.”

Ardabelle Capital will collect and disclose the adverse sustainability indicators on an annual basis. The collection of indicators will be based on a systematic process engaging with investee companies.

As no investments were held during the reference period (1 January 2025 – 31 December 2025), all mandatory and additional PAI indicators are reported as not applicable for this reporting cycle.

Table 1 — Indicators Applicable to Investments in Investee Companies

Climate and Other Environment-Related Indicators

#	Adverse sustainability indicator	Metric	Impact 2025	Impact 2024	Explanation
Greenhouse gas emissions
1.	GHG emissions	Scope 1 GHG emissions	n.a.	n.a.	No investments were held during the reference period.
		Scope 2 GHG emissions	n.a.	n.a.	No investments were held during the reference period.
		Scope 3 GHG emissions	n.a.	n.a.	No investments were held during the reference period.
		Total GHG emissions	n.a.	n.a.	No investments were held during the reference period.
2.	Carbon footprint	Carbon footprint	n.a.	n.a.	No investments were held during the reference period.
3.	GHG intensity of investee companies	GHG intensity of investee companies	n.a.	n.a.	No investments were held during the reference period.
4.	Exposure to companies active in the fossil fuel sector	Share of investments in companies active in the fossil fuel sector	n.a.	n.a.	No investments were held during the reference period. According to the fund’s thesis, Ardabelle will not invest in fossil gas and/or nuclear energy related activities.
5.	Share of non-renewable energy consumption and production	Share of non-renewable energy consumption and non-renewable energy production of investee companies from non-renewable energy sources compared to renewable energy sources, expressed as a percentage of total energy sources	n.a.	n.a.	No investments were held during the reference period.
6.	Energy consumption intensity per high impact climate sector	Energy consumption in GWh per million EUR of revenue of investee companies, per high impact climate sector	n.a.	n.a.	No investments were held during the reference period.
Biodiversity
7.	Activities negatively affecting biodiversity-sensitive areas	Share of investments in investee companies with sites/operations located in or near to biodiversity-sensitive areas where activities of those investee companies negatively affect those areas	n.a.	n.a.	No investments were held during the reference period.
Water
8.	Emissions to water	Tonnes of emissions to water generated by investee companies per million EUR invested, expressed as a weighted average	n.a.	n.a.	No investments were held during the reference period.
Waste
9.	Hazardous waste and radioactive waste ratio	Tonnes of hazardous waste and radioactive waste generated by investee companies per million EUR invested, expressed as a weighted average	n.a.	n.a.	No investments were held during the reference period.

Indicators for Social and Employee, Respect for Human Rights, Anti-corruption and Anti-bribery Matters

#	Adverse sustainability indicator	Metric	Impact 2025	Impact 2024	Explanation
10.	Violations of UN Global Compact principles and OECD Guidelines for Multinational Enterprises	Share of investments in investee companies that have been involved in violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	n.a.	n.a.	No investments were held during the reference period.
11.	Lack of processes and compliance mechanisms to monitor compliance with UN Global Compact principles and OECD Guidelines for Multinational Enterprises	Share of investments in investee companies without policies to monitor compliance with the UNGC principles or OECD Guidelines for Multinational Enterprises, or grievance/complaints handling mechanisms to address violations of the UNGC principles or OECD Guidelines for Multinational Enterprises	n.a.	n.a.	No investments were held during the reference period.
12.	Unadjusted gender pay gap	Average unadjusted gender pay gap of investee companies	n.a.	n.a.	No investments were held during the reference period.
13.	Board gender diversity	Average ratio of female to male board members in investee companies, expressed as a percentage of all board members	n.a.	n.a.	No investments were held during the reference period.
14.	Exposure to controversial weapons (anti-personnel mines, cluster munitions, chemical weapons and biological weapons)	Share of investments in investee companies involved in the manufacture or selling of controversial weapons	n.a.	n.a.	No investments were held during the reference period.

Voluntary Additional Indicators

Category	#	Adverse sustainability indicator	Metric	Impact 2025	Impact 2024
Environmental	15.	Energy Consumption intensity per high impact climate sector	Energy use per unit of revenue (high climate-impact sectors)	n.a.	n.a.
Social	16.	Lack of a human rights policy / Investment countries experiencing violations of social standards	Share of investments in entities without a human rights policy / Number of investment countries experiencing violations of social standards, as defined by international treaties and conventions, United Nations principles, or, where applicable, national law.	n.a.	n.a.

Description of Policies to Identify and Prioritise Principal Adverse Impacts on Sustainability Factors

Ardabelle Capital is committed to identifying, assessing, and prioritising principal adverse impacts of its investment decisions on sustainability factors. As an impact-oriented fund, Ardabelle Capital integrates ESG considerations into its investment process from due diligence through to portfolio monitoring.

Each investment opportunity will undergo screening against Ardabelle Capital’s ESG methodology, which includes:

• Assessment of substantial contribution to environmental and/or social objectives
• Verification that investments do not cause significant harm to other sustainability objectives, assessed via PAI indicators
• Evaluation of compliance with minimum governance standards

Each of the mandatory and additional indicators listed in this statement will be collected directly from investee companies on an annual basis once investments are made.

Engagement Policies

Ardabelle Capital intends to actively engage with its portfolio companies to encourage the adoption of best management practices on environmental and social topics when risks or principal adverse sustainability impacts are identified.

As no investments were held during the reference period, no engagement activities were conducted. Once investments are made, Ardabelle Capital will act as a support for portfolio companies to develop best-practices in ESG monitoring, including through knowledge sharing and monitoring of PAI indicators.

References to International Standards

Ardabelle Capital’s approach to identifying and managing principal adverse impacts is informed by the following international frameworks:

• UN Sustainable Development Goals (SDGs)
• UN Global Compact Principles
• OECD Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights

These frameworks will guide the assessment and engagement activities once investments are made.

Historical Comparison

Historical comparison is not applicable for this reporting period (1 January 2025 – 31 December 2025) as this is the first reporting cycle for the fund and no investments were held during the reference period.

This statement is published on Ardabelle Capital’s website in accordance with Article 4 of Regulation (EU) 2019/2088 and Annex I to the Commission Delegated Regulation (EU) 2022/1288.

Last updated: April 2026