SFDR Article 10 Disclosure

This Fund is categorised as an Article 9 Fund for the purposes of SFDR.



No significant harm to the sustainable investment objective

Where the Fund makes SFDR sustainable investments it will seek to ensure through pre-investment due diligence that such investments:

. do not significantly harm any of the other sustainable investment objectives set out under SFDR, including taking into account the Minimum PAI Indicators referred to in section (b) below,

· are appropriately aligned with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, and

· where relevant (for potentially EU taxonomy-aligned investments), do not significantly harm any of the other sustainable investment objectives set out under the relevant EU Taxonomy category.

Sustainable investment objective of the financial product

The Fund’s sustainable investment objective spans a range of environmental and social objectives including:

· Environmental objectives: less production of greenhouse gas emissions (including through more efficient use of energy and renewable energy), positive impact on the circular economy (including through more efficient use of raw materials and less production of waste), more efficient use of water and land, and a positive impact on biodiversity

· Social objectives: investment in human capital (including through fostering labour relations), tackling inequality, and fostering social cohesion and integration

Investment strategy

The Fund intends to pursue well established, private mid-to-late stage growth companies expected to have a majority or all of the following characteristics:

· high quality business models deemed by the Investment Manager to be suitable for long-term investing, with a secure local market position at scale with further global growth potential;

· the potential to act as a 'Sustainability Platform' (i.e. the potential to drive an industry-level sustainability transformation in its respective sector), often with an opportunity to deploy further capital over time;

· stable governance and strong management deemed by the Investment Manager to be led by world class entrepreneurs/leaders that share Generation's vision to drive sustainability outcomes and shareholder value in lockstep; and

· an ownership model in respect of which the Fund generally expects to be able to exert significant influence over value creation and/or strategic direction.

Proportion of investments

Other than ancillary cash, liquid assets and derivatives, the Fund intends that the whole of its portfolio will be invested in SFDR sustainable investments.

Within that commitment the Fund has made no minimum commitment to/as between environmentally and socially sustainable investments or to EU-taxonomy aligned investments.

Monitoring of sustainable investment objective

Generation uses a suite of investment-specific sustainability indicators and cross-portfolio indicators to measure the attainment of the Fund’s sustainable investment objective.

For each investment of the Fund, Generation defines:

· the specific SFDR environmental or social objective to which that investment contributes; and

· an investment-specific sustainability indicator used to measure the investment’s contribution to that objective over the life of the investment.

Methodologies for the sustainable investment objective

Investment-specific sustainability indicators used to measure contribution to the investment-specific social or environmental objective are typically designed in partnership with the portfolio company itself. These indicators are typically selected based on a combination of factors and strive to capture the ‘additional’ effect of the product or service on the specific social or environmental objective versus the status quo or business as usual.

The methodologies applied to measure the cross-portfolio measures vary according to the nature of the metric. Guidance is provided for portfolio companies in order to maximise consistency in calculation. This guidance is aligned to regulatory definitions, where relevant.

Data sources and processing

Generation aims to use primary data sources where possible by working closely with portfolio companies, supplemented with third party data providers, desktop research, as well as interviews and discussions with industry and subject matter experts. But in some cases data may be estimated.

Limitations to methodologies and data

The breadth of Generation’s overarching mission makes it hard to quantify the outcomes of all aspects associated with the actions underlying the attainment of the sustainable investment objective of the Fund. Generation has selected indicators that focus particularly on the contribution of the investee companies’ products and services to specific social or environmental objectives, as well as cross-portfolio sustainability performance indicators.

There remain significant gaps in corporate sustainability reporting, and a lack of relevant, comparable, reliable and publicly available sustainability data on companies.

Sustainability (including PAI indicator) data often rely on the data collection and assessment efforts of third parties and delays in accessing disclosures or inaccuracies in the data supplied will be beyond Generation’s control. Even where data is available, its impact and/or interpretation may be disputed. This is particularly the case for sustainability indicators that draw on third-party assessments.

Due diligence

Due diligence carried out on underlying assets of the Fund, and the associated internal and external controls on that due diligence, is set out in Generation’s approach to Sustainability in the Investment Process.

Engagement policies

The engagement policies implemented in support of the sustainable investment objective, including any management procedures applicable to sustainability-related controversies in investee companies, as set out in Generation’s Stewardship and Engagement Policy.

Attainment of the sustainable investment objective

Generation does not make use of an index as a reference benchmark for the purposes of measuring the attainment of the sustainable investment objective of the Fund.

This section is intended to be treated as a summary of the following disclosures and does not purport to be complete.