Disclosures pursuant to the sustainable finance disclosure regulation (EU) 2019/2088

The information provided here sets out how the financial product has sustainable investment as objective as required by Article 9 of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”).

A. SUMMARY

ECIIF II (hereafter also referred to as “the Fund”)  is an Article 9 impact fund committed to making sustainable investments that generate both financial returns and measurable positive environmental and social impact. The Fund strategically invests in businesses addressing global challenges across four interconnected impact topics:

• Education & employment – access to quality education, lifelong learning, inclusive job creation.
• Health & care – improved healthcare access, digitalisation of services, innovative care solutions and prevention.
• Circular economy & climate action – circular business models, resilient energy systems, adaptation and decarbonisation.
• Food & agriculture – transparent and fair value chains, reduced food waste, sustainable livelihoods.

ECIIF II invests exclusively in sustainable investments. The Fund targets a minimum of 80% of assets as sustainable investments (#1 Sustainable). The remaining up to 20% may be held as cash for liquidity purposes (#2). The Fund assesses, manages and monitors impact and ESG matters throughout the investment lifecycle. For each investment, 2–3 impact KPIs and target values are agreed pre-investment and integrated into the investment agreement; progress is monitored at least annually. Principal Adverse Impacts (PAIs) are assessed during due diligence and monitored during ownership.

No EU-approved benchmark index is designated as a reference benchmark because none fully reflects the Fund’s impact strategy. Progress toward the sustainable investment objective is reported via portfolio- and fund-level impact KPI reporting and sustainability disclosures.

ECIIF II operates as an impact-driven investment fund that adheres to the SFDR’s Article 9 classification, reflecting its commitment to sustainable investments. The Fund is dedicated to investing in businesses that generate both financial returns and measurable positive environmental and social impact.

ECIIF II’s mission is to create a sustainable future for people and planet by mobilizing capital for impact ventures. In supporting high-impact companies that address the world’s most pressing environmental and social challenges the Fund aims to create measurable impact while delivering strong financial performance.

In alignment with Article 9 of SFDR, ECIIF II incorporates the following key principles into its investment framework:

• Ensuring No Significant Harm – establishing a rigorous framework for assessing target investments, integrating minimum safeguards, exclusion criteria, governance standards, and principal adverse impact (pai) considerations.
• Sustainable investment strategy – structuring investments around 4 primary impact topics and their interdependencies:
• Comprehensive due diligence and monitoring – embedding sustainability factors into the investment selection, due diligence, and portfolio oversight process, ensuring alignment with impact objectives.
• Active engagement with portfolio companies – collaborating with management teams to improve impact and sustainability performance, optimize business practices, and mitigate adverse environmental and social impacts.
• Measuring and evaluating success – defining key impact metrics and target values to assess the effectiveness of investments, track progress towards sustainability objectives, and address data limitations where applicable.

Through this structured approach, ECIIF II remains committed to driving impactful investments, fostering sustainable business growth, and aligning with global ESG and sustainability standards.

No EU-approved benchmark index is used as none reflects the fund specific impact strategy; progress is reported to stakeholders in an annual impact report.

B. No significant harm to the sustainable investment objective

ECIIF II ensures that all investments do not significantly harm any sustainable investment objectives by implementing a comprehensive impact and ESG investment review process and a robust reporting framework. This framework is designed to provide transparency on Principal Adverse Impacts (PAIs) and ensure adherence to minimum safeguards.

ECIIF II follows a rigorous exclusion list inspired by IFC Exclusion List and Paris-Aligned Benchmark (PAB) exclusion criteria, prohibiting investments in companies in certain sectors.

Integration of adverse impacts on sustainability factors

The Fund applies a sustainability risk analysis and a good governance assessment when evaluating potential investments. This process integrates the PAI indicators outlined in Annex I, Table 1 of the Commission Delegated Regulation (EU) 2022/1288 and considers relevant additional indicators from Tables 2 and 3.

Information regarding mandatory PAIs listed in Table 1 will be gathered and assessed during the due diligence phase of an investment. This data may be obtained directly from the portfolio company’s management team, a trusted third-party advisor or from publicly accessible datasets as relevant. If certain information is not readily available, ECIIF II may, at the general partner’s discretion, utilize proxy data points or indicators from reputable sources.

For the optional PAIs selected from Tables 2 and 3, ECIIF II will determine which indicators are relevant to each investment and integrate them into the same due diligence process.

Selected optional PAIs (Table 2 and 3):

• Investments in companies without carbon-emission reduction initiatives
• Investments in companies without sustainable land/agriculture practices
• Investments in companies without workplace accident prevention policies
• Lack of a supplier code of conduct
• Lack of grievance/complaints handling mechanism related to employee matters

All findings related to PAIs will be reviewed individually to contribute to an overall qualitative “score,” which serves as one of the fundamental components of ECIIF II sustainability analysis.

The Fund systematically evaluates the Principal Adverse Impact (PAI) indicators at multiple stages of the investment lifecycle:

• Due Diligence stage: PAI indicators are assessed using data obtained directly from portfolio company management, third-party consultants, or publicly available datasets.
• Investment decision: ECIIF II integrates PAI results into its sustainability risk assessment model, ensuring that only investments meeting high ESG standards are approved.
• Ongoing monitoring: PAIs are regularly reviewed, and corrective actions are taken if an investee’s operations begin to pose sustainability risks.

All data gathered during the underwriting process is internally reported and stored for future reference. Specifically, PAI findings and related information for all companies successfully invested in and held within the Fund will be shared with relevant stakeholders in accordance with the Fund’s reporting policy.

Alignment with minimum safeguards

All investee companies are required to respect minimum safeguards in line with SFDR and Article 18 of the EU Taxonomy Regulation. In this context, the Fund ensures that its Sustainable Investments are aligned with internationally recognised standards on human rights, labour rights and responsible business conduct, including the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises (when applicable), the International Bill of Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work.

Alignment with minimum safeguards is assessed through dedicated due diligence questionnaires and forms part of the Fund’s ongoing monitoring and engagement with investees.

C. Sustainable investment objective of the financial product

ECIIF II’s sustainable investment objective is to create a sustainable future for people and planet by mobilizing capital for impact ventures.

To achieve this objective, ECIIF II employs a strategic investment framework informed by the team’s extensive impact investment expertise, alongside a deep understanding of evolving social and environmental challenges and macroeconomic trends. The Fund’s investment approach is structured around four key themes:

• Education & employment
• Health & care
• Food & agriculture
• Circular economy & climate action

ECIIF II is committed to investing exclusively in sustainable investments, with a targeted allocation of 40% directed toward environmental impact investments and 40% allocated to social impact investments; remaining 20% are to be held in cash for liquidity purpose.

Investment Criteria:

To fulfil its sustainability objective, the Fund selects companies that actively and demonstrably create measurable impact in at least one of the four sectors above.

To assess the contribution of investments to these social and environmental objectives, the Fund has developed its own impact methodology to assess an investment’s impact across the entire investment process from pre-screening and due diligence over investment, portfolio management up to exit.

The Fund does not set a minimum threshold for sustainable investments with an environmental objective that aligns with the EU Taxonomy, resulting in a minimum target of 0%. However, for each relevant investment, a thorough assessment will be conducted to consider EU Taxonomy criteria.

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