Sustainability-related disclosure
EKK & Co. III Early Growth GmbH & Co. KG
1. Summary
EKK & Co. III Early Growth GmbH & Co. KG (the “Fund”) promotes environmental and social characteristics within the meaning of Article 8 of Regulation (EU) 2019/2088 (“SFDR”), but does not have as its objective sustainable investment.
The environmental and social characteristics are implemented in particular through binding exclusion criteria and their integration into the investment process. Prior to each investment decision, the exclusion criteria are assessed and an ESG due diligence is conducted. In addition, the good governance practices of investee companies are assessed.
Compliance with the environmental and social characteristics promoted by the Fund is monitored throughout the holding period. The assessment is based in particular on information provided by target and portfolio companies, publicly available information and internal assessments by the Fund management.
The Fund does not commit to a minimum proportion of sustainable investments within the meaning of SFDR or to a minimum proportion of investments aligned with the EU Taxonomy.
2. No sustainable investment objective
This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.
3. Environmental or social characteristics of the financial product
The Fund promotes environmental and social characteristics through the binding application of exclusion criteria.
The Fund does not invest in companies that:
- are involved in the manufacture or distribution of controversial weapons or essential components thereof;
- operate in the pornography, gambling or tobacco sectors;
- engage in fracking, oil sands extraction or other extraction of oil or coal;
- are involved in the production or distribution of genetically modified organisms or in nuclear energy, to the extent that such activities are excluded or subject to specific treatment under the investor agreements applicable to the Fund; or
- are involved in serious violations of internationally recognised standards, in particular the UN Global Compact, human rights, minimum labour standards or anti-corruption requirements.
4. Investment strategy
The environmental and social characteristics promoted by the Fund are integrated into the investment process. Prior to each investment decision, the binding exclusion criteria are assessed and a structured ESG due diligence is conducted. Identified material ESG risks are taken into account in the investment decision and, where necessary, appropriate measures are agreed with the management of the target company.
As part of the ESG due diligence, the good governance practices of the target company are also assessed. In particular, this assessment considers sound management structures, employee relations, remuneration of staff and tax compliance.
5. Proportion of investments
At least 80% of the Fund's investments are aligned with the environmental and social characteristics promoted by the Fund. The remaining investments may include, in particular, cash and other positions that are not aligned with the environmental and social characteristics promoted by the Fund.
The Fund does not commit to a minimum proportion of sustainable investments within the meaning of SFDR. Likewise, the Fund does not commit to a minimum proportion of investments aligned with the EU Taxonomy.
6. Monitoring of environmental or social characteristics
Compliance with the environmental and social characteristics promoted by the Fund is monitored as part of the investment process and throughout the holding period.
The sustainability indicators used include, in particular, the proportion of investments assessed against the binding exclusion criteria prior to the investment decision and the proportion of investments for which an ESG due diligence has been conducted.
Monitoring is carried out as part of the Fund management's internal investment and portfolio management processes.
7. Methodologies
The attainment of the environmental and social characteristics promoted by the Fund is assessed on the basis of compliance with the binding exclusion criteria and the performance of the envisaged ESG assessments.
For this purpose, the results of the ESG screening and ESG due diligence are documented and taken into account in the investment decision.
8. Data sources and processing
The ESG assessment is based in particular on information and documentation provided by target and portfolio companies, publicly available information and internal assessments by the Fund management.
The information used is subject to plausibility checks and processed internally as part of the investment and portfolio management process. Where required information is unavailable or is not available in sufficient quality, estimates may be used as a supplement.
The proportion of data that are estimated cannot be reliably quantified in advance and depends in particular on the availability and quality of information provided by the respective target and portfolio companies.
9. Limitations to methodologies and data
The availability and comparability of standardised ESG data may be limited, particularly in the case of growth companies. The ESG assessment may therefore partly rely on qualitative information and estimates.
These limitations do not generally affect the attainment of the environmental and social characteristics promoted by the Fund, as compliance with those characteristics is assessed in particular on the basis of the binding exclusion criteria and the ESG assessments conducted as part of the investment process.
10. Due diligence
Prior to each investment decision, a structured ESG due diligence is conducted. Depending on their relevance to the respective target company, this includes in particular environmental aspects such as emissions and resource use, social aspects such as working conditions, diversity, human rights and product safety, and governance aspects such as compliance, corporate governance, risk management and data and IT security.
The results of the ESG due diligence are documented as part of the internal investment process and taken into account in the investment decision.
11. Engagement policies
The Fund engages with its portfolio companies throughout the holding period and addresses identified material ESG risks as part of its ongoing portfolio management. This is done in particular through dialogue with management and, where necessary and proportionate, by agreeing on or supporting appropriate improvement measures.
12. Designated reference benchmark
No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the Fund.
Publication date: 09 October 2026