European Sustainable Finance Disclosure Regulation (SFDR) Disclosure

Introduction

Highland Europe GPGP VI Limited (together with its affiliates “Highland”) is making the following disclosure pursuant to 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”) in relation to the funds managed by Highland (the “Funds”) and which are either managed in, or marketed into, the European Economic Area.

Our Process

Sustainability risk means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment (“Sustainability Risk”).

Highland integrates environmental, social and governance (ESG) factors into its investment process, particularly in the course of its overall due diligence and deal evaluation process in a manner which does not bind the investment decision-making process. Highland does so by requiring potential investee companies to complete an ESG questionnaire, and engaging in discussions with the relevant company’s management. The outcomes of this process are reported internally, and appropriate consideration is given where necessary.

Furthermore, Highland will where possible seek to incorporate ESG commitments into the investment agreement with investee companies, requiring these companies to work with Highland and other shareholders to consider, monitor and implement the application of ESG principles into their operations.

Principal Adverse Impact Statement

Highland aims to manage the risk connected to adverse impacts from its investments but it does not currently consider adverse impacts of investment decisions on sustainability factors as specifically set out in the SFDR. Highland has chosen not to do so for the present time as it considers that its existing ESG policies and procedures are appropriate, proportional and tailored to the investment strategies of the Funds. Highland continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance, and will, where required or otherwise appropriate, make changes to its existing policies and procedures.