SFDR Reporting

The information and documents made available on this page are provided in accordance with the disclosure obligations under Regulation (EU) 2019/2088 (Sustainable Finance Disclosure Regulation – SFDR) and related delegated regulations. The SFDR classifications (Article 6 or Article 8) are regulatory disclosures only and do not imply any commitment to achieve specific sustainability outcomes, nor do they constitute an offer, solicitation or recommendation to invest. This information is intended for professional investors and other eligible counterparties only.

Regeneration Seed Fund Coöperatief U.A.

Regeneration Seed Fund – SFDR Disclosure Article 8

Regeneration Seed Fund – SFDR Disclosure Article 8

Summary

The Norrsken Regeneration Fund is an early-stage venture capital fund focused on regenerative ventures. It aims to back innovations that work alongside natural systems to achieve tangible natural outcomes, particularly in land ecosystems and soil health. While it does not have a sustainable investment objective as its sole goal (classified as an Article 8 product under SFDR), it commits 100% of its investments to promoting environmental and/or social characteristics. The fund’s strategy is to be the first institutional check for visionary founders in the regenerative space, integrating ecological and economic goals to build resilient and profitable systems that contribute to a thriving humanity within planetary boundaries.

No sustainable investment objective

This financial product promotes environmental or social characteristics, but does not have as its objective
sustainable investment.

Environmental or social characteristics of the financial product

The financial product promotes regenerative practices focused on achieving tangible natural outcomes, with a special emphasis on land ecosystems and soil health. Key characteristics include:


● Supporting innovations that heal and improve natural systems.
● Aiming for measurable positive results such as revitalized land, biodiversity gains, and enhanced perennial crops and keystone species.
● Integrating ecological and economic goals to foster resilient and profitable systems.
● Contributing to broader environmental goals like increased water retention, reduced vulnerability to droughts and floods, enhanced biodiversity, and carbon sequestration.
● Indirectly contributing to social objectives by supporting resilient food systems and healthy communities.

Investment Strategy

The Norrsken Regeneration Fund invests in early-stage regenerative ventures. Its strategy involves:


● Catalyzing and leading the nascent regenerative investment category.
● Providing the first institutional check for visionary founders.
● Backing innovations that work alongside natural systems to achieve tangible natural outcomes.
● Focusing on land ecosystems and soil health.
● Investing across the “regenerative stack,” including software tools, regenerative brands, distribution platforms, fintech, inputs and material resources, data solutions, biomimetic regenerative materials, tech for ecosystem restoration, and water tech.
● Actively seeking secondary opportunities for liquidity while maintaining potential for outsized returns.
● Acting as a trusted partner to founders with ultra-light proxy boards.
● The binding elements of the investment strategy are outlined in the “deep impact investment decision framework,” which includes Qualitative Impact Screening and Key Indicators such as:
● Mission Alignment: Core purpose aligned with regenerating natural systems.
● Regenerative Impact Metrics: Measurable science-based environmental benefits.
● Economic Viability and Long-Term Vision: Balanced mission and profitability, scalable approaches.
● Ecosystem Integration: Strengthening other regenerative efforts and building collaborative ecosystems.
● Leadership and Team Commitment: Expertise and commitment beyond profit.
● Additionality: Assessing whether the impact would occur without the startup and if it attracts additional resources to the regenerative movement.
● Key Indicators also include explicit focus on restoration/regeneration, defined science-based goals, evidence-based metrics, relevant certifications, diversified revenue from regenerative activities, community involvement, aligned partnerships, and strong governance.

Proportion of investments


The fund assesses good governance practices as part of its “deep impact investment decision framework.” This includes evaluating the investee companies’ commitment to transparency and accountability in governance. Good
governance is understood to encompass sound management structures, positive employee relations, fair remuneration of staff, and tax compliance.

The financial product aims for 100% of its investments to be aligned with environmental and/or social characteristics. Specifically, 100% of the investments are considered sustainable investments with an environmental objective. There is 0% allocated to “Other” categories. The fund does not commit to making investments that are aligned to any minimum extent with the EU Taxonomy. The Investment Advisor does not currently use the EU Taxonomy as a mandatory part of its investment process, retaining flexibility to invest without being tied to a minimum commitment for Taxonomy-aligned investments

Monitoring of environmental or social characteristics

While specific monitoring indicators are not exhaustively detailed, the investment strategy emphasizes “measurable science-based environmental benefits” and “evidence-based metrics on soil organic matter, biodiversity indices, or ecosystem restoration.” The fund seeks to create “measurable positive results” across its portfolio, including revitalized and protected hectares of land, biodiversity gains, and specific keystone species or perennial crop enhancement.

Methodologies

The fund’s “deep impact investment decision framework” utilizes Qualitative Impact Screening and Key Indicators to ensure alignment with its regenerative mission. This includes assessing:

  • Regenerative Impact Metrics: Measurable science-based environmental benefits.
  • Evidence-based metrics on soil organic matter, biodiversity indices, or ecosystem restoration.
  • Certifications with credible regenerative organizations.
  • Scalability plans aligned with regeneration.
Data sources and processing

The fund’s assessment of environmental and social characteristics, and the monitoring of its sustainable investments, relies on data from various sources. While specific data providers are not detailed in the provided
materials, the investment strategy emphasizes the use of:


● Science-based regenerative goals: This implies data and methodologies derived from scientific research and frameworks to define and measure regenerative outcomes.
● Evidence-based metrics: The fund looks for quantifiable data such as soil organic matter, biodiversity indices, and ecosystem restoration metrics to assess the impact of investee companies.
● Information from investee companies: The fund’s due diligence and ongoing engagement with portfolio companies will be a primary source of data regarding their environmental and social
performance. This includes data on their defined regenerative goals, operational data related to their impact, and their adherence to governance practices.
● Partnerships with credible regenerative organizations: These partnerships may serve as sources of data, methodologies, and verification for regenerative claims.


The processing of this data is implicitly for:


● Qualitative Impact Screening: To assess the alignment of potential investments with the fund’s regenerative mission.
● Monitoring: To track the measurable positive results created across the portfolio, such as revitalized land and biodiversity gains.
● Reporting: To fulfill disclosure requirements related to the environmental and social characteristics promoted by the financial product.

The fund also invests in “data solutions” within the regenerative stack, suggesting an understanding of the importance of robust data for this sector, and potentially leveraging such solutions for its own analysis or for
its portfolio companies.

Limitations to methodologies and data

This financial product does not consider principal adverse impacts on sustainability factors

Due diligence

The fund employs a “deep impact investment decision framework” which includes rigorous qualitative impact screening and assessment against key indicators for all potential investments. This framework ensures that investee
companies are deeply aligned with the fund’s regenerative mission, have measurable environmental benefits, possess economic viability, integrate within existing ecosystems, and demonstrate strong leadership and
additionality.

Engagement policies

As a first institutional investor, the fund establishes ultra-light proxy boards and serves as a trusted partner to founders. This indicates an active engagement approach with investee companies, likely focused on supporting their growth while ensuring adherence to regenerative principles. The framework also highlights the importance of community involvement and co-creation, and building ecosystems of trust and collaboration with stakeholders.

Designated reference benchmark

The provided presentation does not specify a designated reference benchmark for the financial product.

Published by Global Diversified Fund Management B.V. — November 2025

Victoriam Equity I C.V.

Victoriam Equity I C.V. – SFDR Disclosure Article 6

Victoriam Equity I C.V. – SFDR Disclosure Article 6

Sustainability Related Disclosures

Global Diversified Fund Management B.V. (the AIFM), a Dutch-based registered alternative investment fund manager within the meaning of article 3(2)(b) of Directive 2011/61/EU of 8 June 2011 on alternative investment fund managers (AIFMD), makes the following disclosures for the purposes of Regulation (EU) 2019/2088 of 27 November 2019 on sustainability-related disclosures in the financial services sector (SFDR) and Regulation (EU) 2020/852 of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (the Taxonomy Regulation). As clarified by the European Commission in its Q&As on sustainability-related disclosures published on 14 July 2021, the AIFM must comply with certain SFDR requirements applicable to registered alternative investment fund managers.

The AIFM acts as registered alternative investment fund manager of Victoriam Equity I C.V. (together referred to as the Fund).

The Fund qualifies under Article 6 of the SFDR as it does not promote environmental or social characteristics (Article 8 SFDR) nor does it have sustainable investments as its objective (Article 9 SFDR).

AIFM-related disclosures
Transparency of sustainability risk policies and of the integration of sustainability risks — Article 3(1) & Article 6 SFDR

A sustainability risk refers to an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

The AIFM does not integrate sustainability risks in its investment decision-making process for the following reasons:

  • The investment due diligence and monitoring tools used by the AIFM to calculate risk and returns of the Fund do not take such risks into account, but mainly economic and financial risks.
  • In view of the AIFM’s size, it is not intended to change the investment decision-making process to integrate sustainability risks, as this would be too costly and not relevant with respect to the Fund.
No consideration of adverse impacts of investment decisions on sustainability factors — Article 4(1)(b) SFDR

Article 4(1) SFDR requires fund managers to provide a clear statement as to whether or not they consider the adverse impacts of investment decisions on sustainability factors, such as environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

Although ESG and sustainability risks are important to the AIFM, it does not consider the adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4(1) SFDR, in particular because:

  • No reliable and sufficiently available or accessible data is available to perform such impact measurement.
  • The underlying investments are not generally required to report on such factors in the manner prescribed by SFDR.

The AIFM does not intend to consider adverse impacts of investment decisions on sustainability factors in the near future as a mandatory investment decision criterion.

Transparency of remuneration policies — Article 5(1) SFDR

For the purposes of Article 5(1) SFDR, the AIFM declares that it has not put in place a remuneration policy in light of the fact that it qualifies as a registered alternative investment fund manager and thus does not fall under the requirement to uphold a remuneration policy as required for licensed AIFMs under the AIFMD.

Fund-related disclosures

The investments underlying the Fund do not take into account the EU criteria for environmentally sustainable economic activities.

Published by Global Diversified Fund Management B.V. — November 2025

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