Ardabelle Fund I — Sustainable Investment Disclosure

1. Summary

Ardabelle Fund I (the "Fund") is classified as an Article 9 financial product under the EU Sustainable Finance Disclosure Regulation (SFDR). The Fund has a sustainable investment objective.

The Fund is managed by Ardabelle Capital, a Paris-based private equity firm specialising in buyout investments in middle market companies within consumer-focused supply chains.

Through its ESG due diligence process and ongoing monitoring, the Fund requires strong environmental practices, social standards, and robust governance aligned with long-term value creation.

The Fund does not designate an index as a reference benchmark. It employs a proprietary impact assessment methodology and develops sustainability business plans with each portfolio company to track and enhance sustainability performance throughout the holding period assessed through the Planetary Boundaries framework.

Ardabelle strives to avoid significant harm to key environmental and social objectives through systematic consideration of Principal Adverse Impact (PAI) indicators, a structured Do No Significant Harm assessment, and alignment with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

2. No Significant Harm to the Sustainable Investment Objective

Ardabelle seeks to only make investments in companies that do not significantly harm other environmental or social objectives as defined by the EU Taxonomy through the following mechanisms:

Principal Adverse Impact (PAI) Indicators

The Fund systematically assesses portfolio companies against all 14 mandatory PAI indicators established in Table 1 of Annex I to the Delegated Regulation (EU) 2022/1288. Ardabelle also collects two additional PAI indicators for each portfolio company, in compliance with Article 9 requirements. These are: 1) Lack of human rights policy and 2) Breakdown of energy consumption by type of non-renewable sources of energy. PAI indicators are assessed during due diligence and monitored throughout the holding period.

Do No Significant Harm (DNSH) Assessment

During due diligence and ongoing monitoring, the Fund applies a structured DNSH assessment covering all six EU environmental objectives:

1. Climate change mitigation
2. Climate change adaptation
3. Sustainable use and protection of water and marine resources
4. Transition to a circular economy
5. Pollution prevention and control
6. Protection and restoration of biodiversity and ecosystems

Companies must demonstrate either neutral or positive performance across all objectives. Where material risks are identified, mitigation plans are identified and assessed for feasibility, and if deemed actionable, incorporated into the plans for portfolio management and value creation. If no feasible meaningful mitigation plan can be identified, the potential investment is dropped from consideration.

Alignment with International Standards

All portfolio companies are required to operate in compliance with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, including the principles and rights set out in the eight fundamental conventions identified in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work. These requirements are formalized in fund documentation and directly in investment agreements where possible. Procedures are implemented to monitor compliance with these standards and to report violations.

3. Sustainable Investment Objective of the Financial Product

The Fund's sustainable investment objective is to support the decarbonisation and overall sustainable transition of value chains, particularly within the consumer goods industry. It aims to reduce the adverse environmental impacts across the value chain, including those commonly classified as Scope 3 emissions, as well as to foster sustainable transformation in operations. As such, it classifies as an Article 9 fund under the SFDR Regulation. The Fund utilizes the Planetary Boundaries framework in assessing the environmental impact of companies.

Measurement Framework

For each investment, Ardabelle employs a rigorous and structured approach to evaluate and try to maximise the global impact of each portfolio company. This process integrates scientific methodologies, quantifiable targets, and continuous monitoring of each investment's contribution to the Fund's sustainable investment objective.

4. Investment Strategy

The investment strategy is structured around four core themes:

• Resource preservation and productivity: optimising resource use and reducing the planetary footprint associated with the production of inputs
• Sustainable delivery: minimising the environmental footprint of product delivery through innovation in packaging, logistics, and distribution
• Material circularity and extended life: extending product lifecycles and closing material loops
• Analytics and management: leveraging data and technology to steer, measure, and accelerate the sustainability transition

Investments are selected based on their ability to provide critical, non-commoditised solutions within these four pillars.

Binding Elements of the Investment Strategy

The investment strategy incorporates binding elements structured across the different phases of the investment process:

Exclusion criteria. The Fund applies two layers of negative screening. First, investments fundamentally incompatible with the Fund's impact thesis are excluded, including companies misaligned with the investment themes and relevant Sustainable Development Goals, sub-sectors that do not contribute to the Fund's objectives, and companies unable to comply with a science-led path to sustainable transition. Second, activities listed on the European Investment Bank's exclusion list are excluded.

Strategic alignment assessment. Ardabelle employs a Theory-of-Change Framework to assess the strategic alignment of each target with the Fund's broader environmental impact commitments, including contributions to the Net Zero by 2050 pathway and the potential for transformational change within major consumer brands' supply chains.

Preliminary impact assessment. All potential investments undergo a proprietary impact assessment using a structured scorecard methodology. This results in a Go/No Go decision by the Sustainability Committee before the investment may proceed to due diligence. Only companies meeting minimum impact thresholds are eligible.

Impact quantification during due diligence. During due diligence, Ardabelle quantifies each investment's impact through sectoral baseline analysis, lifecycle assessments or equivalent proxy methods, target setting, and evaluation of the broader potential for positive change across value chains.

Sustainability business plan and monitoring. Following investment, a sustainability business plan is developed for each portfolio company, defining specific KPIs for each planetary boundary affected by the company's activities that can materially influence the company's valuation. These KPIs are monitored throughout the holding period.

Impact-linked incentives at exit. Financial incentives are linked to the achievement of impact targets through impact-linked carried interest at exit.

Ardabelle incorporates good governance criteria into its evaluation of all investment opportunities through a robust ESG due diligence process. A primary focus of the good governance assessment is best practice in terms of alignment with international standards (OECD Guidelines and the UN Guiding Principles on Business and Human Rights, amongst others).

5. Proportion of Investments

Planned Asset Allocation

All the Fund's investments, excluding hedging and liquidity instruments, target the sustainable investment objective. All investments will contribute to the sustainable objective and qualify as sustainable investments in the meaning of the SFDR Regulation.

Category	Minimum allocation	Description
#1 Sustainable investments	100%	Investments with an environmental objective contributing to the Fund's sustainable investment objective
— #1A Taxonomy-aligned	15%	Investments meeting EU Taxonomy technical screening criteria (target up to 25%)
— #1B Other environmental	85%	Sustainable investments with an environmental objective not aligned with the EU Taxonomy
#2 Not sustainable	0%	Excluding hedging and liquidity instruments, all investments qualify as sustainable

A minimum of 15% of the Fund's investments will be aligned with the EU Taxonomy, with an aim to reach up to 25%. The Fund does not invest in fossil gas or nuclear energy related activities that comply with the EU Taxonomy. Considering its investment universe, the Fund will invest mostly in enabling activities and activities that contribute substantially to one of the six environmental objectives. Transitional activities are anticipated to represent less than half of investments.

The Fund will not make sustainable investments with a social objective. It is not planned to use derivatives at the Fund level.

6. Monitoring of Sustainable Investment Objective

Sustainability performance is monitored throughout the life of the Fund through a structured, multi-level system:

Portfolio Company-Level Monitoring

It is the conviction of Ardabelle Capital that certain ESG factors drive outperformance. Ardabelle has designed its own proprietary list of ESG metrics, named the ESG Essentials. The ESG Essentials are derived from the extensive industry research available in the market, as well as the experience of our Founding Partners in implementing and measuring the outcome of ESG programs in their 20+ year careers in investing and corporate transformation. Each portfolio company reports standardized ESG data covering environmental metrics (GHG emissions, energy consumption, waste, water use, biodiversity impact), social metrics (headcount, gender ratios, living wage compliance, health and safety incidents), and governance indicators (board composition, cybersecurity, ethics). Data is collected at least annually, with certain indicators tracked more frequently. Ardabelle defines targets for each portfolio companies.

Fund-Level Aggregation and Reporting

Consolidated ESG metrics are reported to the Sustainability Committee and the Social, Governance, Diversity & Inclusion Committee on a quarterly basis and to investors annually. PAI indicators are calculated and disclosed in the annual SFDR periodic report. The Fund engages external advisors for specialized assessments as needed, such as for carbon accounting and biodiversity analysis.

Escalation Process

If a portfolio company fails to meet its sustainability targets or ESG requirements, or is identified through controversy monitoring as potentially breaching international standards (OECD Guidelines, UN Guiding Principles, ILO conventions, etc.), Ardabelle follows a structured escalation process:

• Issues are identified through annual controversy screening, or event-driven alerts
• The Head of Sustainability conducts an initial assessment of severity, root causes, and potential remediation approaches
• Ardabelle engages directly with portfolio company management to confirm facts, understand context, and discuss corrective actions
• A remediation plan is co-developed with management, defining specific actions, responsibilities, timelines, and interim milestones

7. Methodologies

The Fund uses the following methodologies to measure the attainment of its sustainable investment objective:

Impact Assessment Methodology and Quantification

Each investment is assessed through a structured process integrating scientific methodologies and quantifiable targets. The assessment identifies the most relevant Planetary Boundaries affected by the target's operations and produces an impact scorecard evaluating the target's global impact. Investment decisions are based on minimum impact thresholds across relevant planetary boundaries.

Ardabelle performs sector-level assessments of how relevant planetary boundaries are affected within the value chains impacted by the company's solutions. Lifecycle assessments or suitable proxy methods are used when relevant to evaluate the current impact of the company's solutions.

Carbon Footprint and Climate Impact

• Scope 1, 2, and 3 emissions calculated using the GHG Protocol Corporate Standard
• Carbon intensity measured as tonnes CO₂e per € million revenue
• For companies providing climate solutions, avoided emissions estimated using counterfactual baseline scenarios
• Net-zero alignment assessed against Science-Based Targets initiative (SBTi) pathways

Social Metrics

Social performance is tracked through gender parity at board, management, and workforce levels; living wage compliance; and health and safety indicators.

Governance Quality

Governance is assessed through the ESG grid covering corporate governance structures, board independence, compensation frameworks, ethical standards, and stakeholder engagement, updated regularly during the holding period.

PAI Indicators

All 14 mandatory PAI indicators from Table 1 of Annex I to the Delegated Regulation are calculated using data collected directly from portfolio companies, supplemented by sector-level estimates where company-specific data is not yet available.

8. Data Sources and Processing

Data Sources

ESG data is collected directly from portfolio companies through structured ESG questionnaires, management reporting, and operational data systems. Where direct company data is unavailable, the Fund relies on recognised emissions factor databases for Scope 3 calculations, protected area and biodiversity databases, living wage benchmarks from national statistical offices, and sector-specific ESG benchmarks for contextual comparison.

Taxonomy Alignment Data

Information on Taxonomy alignment for the Fund's participations will be derived from two types of data sources: data from audited CSRD reports, and other relevant Taxonomy data including information obtained through ESG reports and company discussions, considered by the regulations as data equivalent information.

Data Processing and Frequency

ESG data is aggregated and validated by the sustainability team, with quality checks to identify outliers or inconsistencies. Where direct measurement is not feasible, estimated data is used with conservative assumptions and disclosed accordingly. All KPIs are collected and reviewed at least annually, and the fund will try to collect more frequently for monitoring purposes.

9. Limitations to Methodologies and Data

The Fund acknowledges the following limitations:

Limited Historical Baseline

As a newly established fund, historical ESG data for portfolio companies prior to acquisition may be incomplete or absent. This is mitigated by establishing standardized baseline measurements in the first stage of ownership and focusing on forward-looking improvement trajectories.

Scope 3 Emissions Complexity

Supply chain emissions require extensive third-party data that is often unavailable for SMEs. The Fund uses industry-average proxies and spend-based calculations as interim measures and works with portfolio companies to progressively improve data quality.

EU Taxonomy Alignment

Technical Screening Criteria are complex and evolving. Not all activities covered by the Fund are eligible under the EU Taxonomy. The Fund takes a phased approach and reports Taxonomy alignment conservatively, differentiating between audited CSRD data and data equivalent information.

Estimation and Proxies

Where direct measurement is infeasible, estimated data introduces uncertainty. This is mitigated by clearly disclosing where estimates are used, applying conservative assumptions, and improving primary data collection over time.

These limitations do not prevent the Fund from meeting its sustainable investment objective. The Fund is committed to continuous improvement in data quality and will transparently communicate any changes in methodology.

Planetary Boundaries Assessment Limitations

The Planetary Boundaries framework provides a scientifically grounded basis for assessing environmental impact, but its application at the portfolio company level is subject to inherent methodological constraints. No standardised methodology currently exists to allocate global boundaries to individual companies or funds. Several boundaries — in particular novel entities (chemical pollution), biosphere integrity (biodiversity), and land system change — remain among the least quantified, with robust, company-level metrics still under development. Where direct measurement is unavailable, the Fund tries to rely on proxy approaches such as regulatory compliance data, biodiversity screening tools, and protected area proximity assessments.

10. Due Diligence

ESG due diligence is a mandatory and integral component of the Fund's investment process.

Phase 1: Initial Screening

A preliminary impact assessment is conducted using a proprietary scorecard to evaluate alignment with the Planetary Boundaries and the Fund's sustainable investment thesis. The Sustainability Committee issues a Go/No Go decision based on this assessment before detailed due diligence may proceed.

Phase 2: Detailed Due Diligence

The due diligence produces a comprehensive ESG report presented to the Investment Committee alongside financial analysis. Material ESG risks must be addressable. Issues incompatible with the Fund's sustainable investment objective can result in deal withdrawal.

Phase 3: Impact Value Creation Plan

Following investment, the Fund develops a tailored sustainability business plan with portfolio company management, defining priority ESG KPIs, baseline metrics, and improvement targets. The plan is reviewed by the Sustainability Committee and monitored throughout the holding period.

Ongoing Due Diligence

ESG risks and opportunities are re-assessed at least annually. Sustainability business plan milestones and PAI indicators are tracked regularly. Event-driven reviews are conducted in the case of material incidents.

11. Engagement Policies

Active ownership and engagement are central to the Fund's approach to driving sustainable value creation. Ardabelle Capital is a signatory to the UN Principles for Responsible Investment (PRI). The Fund's approach is aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

Board-Level Engagement

Ardabelle holds Board representation in its portfolio companies. ESG and sustainability topics are standing agenda items at Board meetings. Board members oversee both financial and ESG performance, and material ESG considerations are integrated into company strategic planning.

Sustainability Business Plan Governance

Sustainability targets are reviewed at board meetings. Management presents progress, challenges, and corrective actions. Ardabelle provides hands-on support including connecting portfolio companies with specialised advisors and facilitating peer learning across the portfolio.

Sustainability and Social, Governance, Diversity & Inclusion Committees

The Fund's Sustainability and Social, Governance, Diversity & Inclusion Committees meet quarterly, reviewing portfolio-wide ESG performance, emerging risks, and regulatory developments.

12. Attainment of the Sustainable Investment Objective

The Fund's investment strategy is based on active, fundamental analysis of each company's sustainability profile and potential for impact improvement.

How Success Is Measured

In the absence of a benchmark, the Fund assesses attainment through:

• Absolute improvement in portfolio companies' sustainability performance, including progress against planetary boundary-related KPIs
• Achievement of sustainability business plan milestones across the portfolio
• Compliance with the Fund's exclusion criteria and DNSH requirements
• PAI indicator performance over time
• Impact-linked evaluation at exit

Reporting Period Note

As of 31 December 2025, the Fund had not yet completed any portfolio company investments. The Fund's first periodic report under Annex V of the Delegated Regulation will reflect portfolio-level sustainability data once investments have been deployed.

Annual progress will be reported transparently in the SFDR periodic report (Annex V) appended to the Fund's annual report.

This disclosure is published on Ardabelle Capital's website in accordance with Article 10 of Regulation (EU) 2019/2088 and Articles 38 to 49 of the Commission Delegated Regulation (EU) 2022/1288.

This disclosure is updated periodically to reflect portfolio developments and regulatory changes.

Last updated: March 2026