Compliance with EU Sustainable Finance Disclosure Regulation (2019/2088) (“SFDR”)

Plural II GP S.à r.l. (“Plural” or “we”) make the following disclosures in accordance with Articles 3(1), 4(1)(a), 4(2) and 5 of the SFDR.
Last updated 16 January 2024.


A sustainability risk means “an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment”. For Plural, sustainability risks are risks which, if they were to crystallize, would cause a material negative impact on the value of the portfolios of its funds.

Plural does not currently deem sustainability risks as being relevant to the value of the portfolio of its funds. Plural is however is aware of the potential negative impact that sustainability risks may have on the value of an investment. In light of such potential effect, Plural may modify its approach to the integration of such sustainability risks in the future.

Notwithstanding its current approach, Plural takes very seriously the potential negative impact sustainability risks may have on the value of its investments, and therefore intends, to the extent applicable in the future, to assess such risks and their impact on the value of an investment during its due diligence process and mitigate, where possible, such risks.

By way of example, Plural will look to adopt an opportunistic approach in respect of the mitigation of such sustainability risks and exercise, where applicable, its governance rights to influence the management of the relevant risks related to sustainability in compliance with Article 3 of the SFDR.


Article 4 of the SFDR requires fund managers to make a clear statement as to whether or not they consider “principal adverse impacts”.

Plural does not take into consideration the principal adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the SFDR. This is because Plural is not, in its view, currently in a position to obtain and/or measure all the data which it would be required by the SFDR to report, or to do so systematically, consistently and at a reasonable cost with respect to all its investment strategies to clients and investors. This current position will be kept under review and may change in the future.


Plural pays its staff a combination of fixed remuneration (salary and benefits) and variable remuneration (which may include bonus). Any variable remuneration for relevant staff would take into account performance and other factors, which may include compliance with Plural’s policies and procedures.

Plural does not currently have policies that address sustainability risks given it does not consider sustainability risks relevant to the value of the portfolio of its funds but will keep this position under review. We consider this appropriate, as it aligns the interest of investment teams with our investors and incentivizes consideration of longer-term risk reduction alongside financial performance.

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