Disclosures required under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088

212 Management III S.à r.l. (the “AIFM”) is a Luxembourg-based registered alternative investment fund manager and a financial market participant under Regulation (EU) 2019/2088 (SFDR). It manages 212 Regional Fund III SCS (the “Fund”), which is classified under Article 6 of SFDR.

1. Integration of sustainability risks (Article 3 of SFDR)

Sustainability risks are environmental, social or governance events or conditions that could cause a material negative impact on the value of an investment, including climate-related physical, transition and litigation risks. The AIFM considers relevant and material sustainability risks as part of its due diligence and investment decision-making, alongside other risks, as described in Section D.

2. Principal adverse impacts (Article 4 of SFDR)

The AIFM is not required to consider principal adverse impacts (PAIs) under Article 4(3) of SFDR, as it has fewer than 500 employees, and does not currently consider the PAIs of its investment decisions on sustainability factors. Given the Fund’s early-stage venture capital focus, sustainability data of sufficient quality and comparability is not currently available, and the cost of PAI reporting would be disproportionate to the nature and scale of the AIFM’s activities. The AIFM will keep this position under review.

3. Remuneration (Article 5 of SFDR)

As a registered AIFM, the AIFM is not required to maintain, and does not currently maintain, a formal remuneration policy, and has therefore not adopted specific arrangements regarding the integration of sustainability risks into remuneration.

4. Environmental and social due diligence and monitoring

The Fund invests in early-stage, asset-light technology companies, primarily B2B software, so its environmental and social (E&S) risk, including climate-related risk, is expected to be generally low. It manages these risks through a proportionate Environmental and Social Management System (ESMS).

Every qualified prospective investment is screened against the Fund’s Exclusion List and rated Low, Medium or Higher E&S risk. Investments likely to cause significant, complex or potentially irreversible E&S impacts are not eligible. Scaled to the company’s size, stage and risk, the review covers governance and business ethics, employment practices, data privacy and cybersecurity, health and safety, and environmental and climate-related risks, where relevant. Where a material risk is identified, the Fund may agree on mitigation actions with the company or decline to invest.

After investment, the Fund monitors material E&S matters, including climate-related risks, through regular portfolio and Board engagement, normally at least once a year. Portfolio companies are expected to report material E&S incidents without undue delay, and investors receive annual E&S reporting. E&S concerns can be raised with 212 at esg@212.vc. The ESMS is reviewed at least once a year, and any updates are approved by the Board of Managers.

The Fund does not invest in activities on its Exclusion List, which include weapons and defence, tobacco, gambling, fossil fuel extraction or generation, child or forced labour, and activities that are illegal or subject to an international phase-out or ban. The full Exclusion List is available on request.