Nyver Sustainability Policy — Pre-Investment Assessment
Framework: Nyver Sustainability Policy 2025 · SFDR Article 8 · UN PRI Principle 1
This scorecard assesses the Portfolio company against three pre-investment requirements: (1) Annex B — Exclusion List screen, (2) Annex C — Good Governance assessment, and (3) sustainability risk integration.

Nyver's ESG Sustainability Strategy Pillars are Climate & Environment and Diversity & Inclusion — where Nyver encourages portfolio companies to continuously enhance performance.

This is the Screening artefact. The Exclusion List is applied before any substantive DD work; any match requires escalation to the Advisory Committee. Hard stops listed per Annex B of the Nyver Sustainability Policy and Fund Members Agreement.

Annex C assessment. Status: ✅ MET no concerns · ⚠️ OBS proceed with note · ❌ NOT MET logged as a 100-Day ESG Action Plan item · ⏳ PEND awaiting response.

STATUS LEGEND (applies to all B1–B5 indicators)

Annex C assessment — see STATUS Legend, Section B1.

Annex C assessment — see STATUS Legend, Section B1.

Annex C assessment — see STATUS Legend, Section B1.

Annex C assessment — see STATUS Legend, Section B1.

The team identifies sustainability risks and assesses their likely impact on investment returns (aligned with SFDR Article 6 at fund level). This section records the material sustainability risks identified for this investment. ESG opportunities and mitigating actions are captured in Section F.

UN PRI Principle 6 requires annual reporting on ESG activities and progress. This section records the baseline KPI data at the point of investment. Items marked PENDING are to be completed once the target's data-request response is received. The lead indicators for Nyver's two ESG Sustainability Strategy Pillars are drawn from this baseline and reviewed annually.

These are Nyver's fixed calculation conventions, applied centrally for every portfolio company so baselines stay comparable. Values marked "Calculated per Methodology" in the Source column were derived this way from an ESG Data Request response — see the referenced request for the underlying raw data.

• LTIFR = (lost-time injuries × 1,000,000) ÷ hours worked.
• TRIR = (recordable incidents × 200,000) ÷ hours worked (OSHA convention).
• Turnover % = (employees who left during the year ÷ average headcount over the year) × 100.
• Sickness % = (total sick days ÷ total available working days) × 100 (Dutch verzuimpercentage convention).
• Gender split reported as % female with the underlying male/female/unknown counts.
• GHG Scope 1 = direct emissions (owned/leased vehicles, on-site combustion, refrigerants). Scope 2 = purchased electricity/heat. Derived from fleet-fuel and electricity data using standard published conversion factors (e.g. RVO/DEFRA) where the company has no calculation of its own.

This section combines all post-closing ESG requirements arising from due diligence — whether flagged by the ESG assessment, legal, tax or financial DD — together with value-creation opportunities identified during the assessment, into a single 100-Day ESG Action Plan. It is the direct output of this scorecard for the deal team, legal advisers and the portfolio company, and forms the opening commitments of the ESG Plan maintained throughout the holding period. This list captures the ESG-relevant subset of post-closing actions only; it is not a complete record of all SPA-related obligations, which are tracked separately in the completion/SPA checklist.

Not a 100-Day Action Plan item. Captured for context; no acceptance criteria or owner required at this stage.

Assessment basis: Nyver Sustainability Policy 2025 — Annex B (Investment Exclusion List) and Annex C (Minimum Requirements Good Governance Practices Portfolio Companies). The Nyver Sustainability Policy operationalises SFDR Article 8 and UN PRI Principle 1; PRI Principle 6 alignment via Section D KPI baseline.

Engagement artefact under §c of the Nyver Sustainability Policy 2025. Tracks ESG progress against the baseline in the ESG Scorecard.

Track against baseline (T0) and prior year. Trend: ↑ improved · → stable · ↓ declined · — no data

Status of every ESG action previously committed — 100-day plan items, focus-area Year-1 actions, and actions carried from prior reviews. Anything not complete is carried into Section 5.
Status: ✅ Done · 🟡 In progress · 🔴 Delayed · ⚪ Dropped (give reason)

Annual refresh for the Fund's PRI Principle 6 submission. Baseline T0 is pre-filled from the ESG Scorecard Section D. The Climate & Environment and Diversity & Inclusion lead indicators in Section 1 are drawn from this set.

A full Annex C re-assessment is not required annually. This section captures only material changes since the last review. Anything flagged is carried into Section 5. A serious adverse change (e.g. Exclusion List proximity) is escalated per the Policy.

Forward ESG plan for the next 12 months — becomes input to next year's Section 2 tracker. Includes new priority focus-area improvement actions and any items carried over from Section 2.
Priority: 🔴 Immediate · 🟡 Within 6 months · 🟢 Within the year.

Engagement artefact under §c of the Nyver Sustainability Policy 2025, which operationalises SFDR Article 8 and UN PRI Principle 1. PRI Principle 6 annual reporting via Sections 1 and 3. Tracked against the ESG Scorecard baseline.

Nyver Capital Management is an Article 8 fund under SFDR and a UN PRI signatory. This request is deliberately short — it only covers items still missing from our ESG Scorecard assessment; everything already covered by legal, tax and financial DD is intentionally left out of this request.

What our advisers are already covering — do not repeat these: tax compliance, transfer pricing, payroll, employment contracts, litigation, permits, GDPR gaps, articles of association, real-estate leases, financing, insurance, IP, audited financial statements, and fund-side SFDR/PRI disclosures.

Where a document exists, please attach it. Where nothing formal exists, a short written answer is fine — please do not create policies for this request. Several items on the next tab are pre-filled from our DD; for those, the portfolio company only needs to confirm, correct or add to what is already known.

Only items still missing or pending from the ESG Scorecard are pre-selected (checked). Untick anything that isn't relevant to this deal, or tick one back on if you want to ask it anyway — the underlying text is a standard reference set, edit the pre-filled context freely.