NO SUCH FUND — SFDR Art. 8 disclosure

Pre-contractual disclosure pursuant to Article 8 of Regulation (EU) 2019/2088 and Commission Delegated Regulation (EU) 2022/1288. This disclosure applies to No Such Fund Coöperatief U.A. (“No Such Fund”), managed by No Such Ventures II B.V., registered with the Dutch Authority for the Financial Markets (AFM).

SDG 8
SDG 9
SDG 11
SDG 12
​Summary

No Such Fund is classified as an Article 8 financial product under the EU Sustainable Finance Disclosure Regulation (“SFDR”). The fund promotes environmental and social characteristics by integrating ESG considerations into its investment selection, legal documentation, and post-investment support. The fund does not have sustainable investment as its primary objective and makes no claim to sustainable investments within the meaning of Article 2(17) of the SFDR. The promoted characteristics include contribution to selected UN Sustainable Development Goals, good governance practices, and diversity and inclusion commitments in portfolio companies.



No sustainable investment objective

This financial product promotes environmental and social characteristics but does not have sustainable investment as its objective. No portion of the fund's investments is committed as sustainable investments within the meaning of Article 2(17) of the SFDR. No reference benchmark has been designated to measure the attainment of the environmental and social characteristics promoted by this financial product.



Environmental and social characteristics promoted

No Such Fund promotes the following environmental and social characteristics across its portfolio:


SDG Contribution: Each investment is assessed on its contribution to the United Nations Sustainable Development Goals, with a primary focus on SDG 8 (Decent Work and Economic Growth), SDG 9 (Industry, Innovation and Infrastructure), SDG 11 (Sustainable Cities and Communities), and SDG 12 (Responsible Consumption and Production)


Good governance

Portfolio companies are assessed pre-investment using the SASB (Sustainability Accounting Standards Board) standards framework, covering core business practices and company-level governance policies. Governance quality is a binding consideration in every investment decision.


Diversity and inclusion

Portfolio companies are contractually required to evaluate and implement best practices with respect to diversity in their employee base within 12 months of investment. This commitment is embedded in the fund's term sheet and shareholder agreement.


Principal Adverse Impacts

A Principal Adverse Impact (PAI) assessment is conducted for each investment as part of the pre-investment due diligence process, identifying potential negative effects on sustainability factors.


Exclusion policy

The following activities are excluded from the investment universe:

  • Fossil fuel production and distribution

  • Gambling and gaming

  • Web3

  • Activities that cause material harm to biodiversity



Investment strategy

No Such Fund invests in European technology companies across two vehicles: a main fund targeting Seed and Series A stage companies, and a seed fund targeting earlier-stage opportunities. Combined, the vehicles target 20 to 25 portfolio companies, with initial tickets ranging from €250,000 to €5 million. Investments are made across three themes: unifying fragmented European markets; strengthening European sovereignty in infrastructure, energy, Industry 4.0, and security; and digitizing and automating European businesses through SaaS, AI, and data solutions. The primary geography is the Netherlands and Benelux, with selective investments across Europe.


ESG considerations are integrated at every stage of the investment process. Prior to investment, companies are screened against the exclusion list, assessed on SDG contribution, evaluated on governance quality using the SASB framework, and subject to a PAI assessment. Findings are documented in the Information Memorandum for each investment proposal and form part of the investment committee decision.



Proportion of investments

At least 90% of the fund's investments, measured by net asset value, will meet the environmental and social characteristics described in this disclosure. The remaining portion may include cash, cash equivalents, and short-term liquidity instruments held between investment periods, which are not subject to ESG screening.



Monitoring of environmental or social characteristics

No Such Fund monitors adherence to the promoted characteristics on an ongoing basis through active portfolio ownership. Post-investment, No Such Ventures II B.V. supports portfolio companies in implementing their Sustainability Risk Policy and diversity commitments, and monitors ESG practices through regular engagement with founders and management teams. Portfolio company compliance with contractual ESG commitments is tracked as part of the fund's standard reporting cycle.



Methodologies

The UN SDG framework serves as the primary methodology for assessing positive environmental and social contribution. Governance quality is assessed using SASB standards. PAI potential is assessed using a proprietary framework applied pre-investment and documented in each investment proposal.

Binding ESG commitments are structured into two legal documents executed at the time of investment: the term sheet and the shareholder agreement. Within 12 months of closing, portfolio companies are contractually required to:

  1. Integrate a Sustainability Risk Policy to identify, assess, control, and report on ESG risks, enhancing transparency and recognising the importance of sustainability in investment decisions; and

  2. Evaluate and implement best business practices with respect to SFDR, including efforts to promote diversity in the employee base.



Data sources and limitations

ESG data is sourced primarily through direct engagement with portfolio companies during pre-investment due diligence and through ongoing portfolio monitoring. The fund uses the UN SDG framework and SASB standards as structured frameworks for data collection and assessment. No third-party ESG data providers are used at this time.


Limitations: Portfolio companies at Seed and Series A stage are typically not yet subject to mandatory sustainability reporting obligations under EU or national law. As a result, standardised or externally verified ESG data is generally not available at the time of investment. The fund addresses this limitation through direct engagement, proprietary due diligence, and the contractual requirement for portfolio companies to implement formal sustainability practices within 12 months of investment. Data quality and comparability are expected to improve as portfolio companies mature.



Due diligence

ESG due diligence is conducted as an integral part of the pre-investment process for every investment. This includes screening against the exclusion list, assessing SDG contribution, evaluating governance quality against SASB standards, and conducting a PAI assessment. Findings are documented in the Information Memorandum of each investment proposal and presented to the investment committee as part of the investment decision.



Engagement policies

No Such Fund takes an active ownership approach. Post-investment, No Such Ventures II B.V. works closely with portfolio companies to support the implementation of their Sustainability Risk Policy and diversity commitments. ESG matters are addressed through regular contact with founders and management teams, consistent with the fund's hands-on support model. Portfolio companies are expected to incorporate sustainability considerations into their operational and governance practices over time.



Reference benchmark

No reference benchmark has been designated to measure the attainment of the environmental and social characteristics promoted by this financial product.



This disclosure is published pursuant to Article 8 of Regulation (EU) 2019/2088 (SFDR) and Commission Delegated Regulation (EU) 2022/1288. It will be reviewed and updated at least annually, or when material changes to the fund's approach occur. No Such Ventures II B.V. — AFM registration numbers 15604700 and 50035601. Last updated: September 2026.

​Summary

No Such Fund is classified as an Article 8 financial product under the EU Sustainable Finance Disclosure Regulation (“SFDR”). The fund promotes environmental and social characteristics by integrating ESG considerations into its investment selection, legal documentation, and post-investment support. The fund does not have sustainable investment as its primary objective and makes no claim to sustainable investments within the meaning of Article 2(17) of the SFDR. The promoted characteristics include contribution to selected UN Sustainable Development Goals, good governance practices, and diversity and inclusion commitments in portfolio companies.



No sustainable investment objective

This financial product promotes environmental and social characteristics but does not have sustainable investment as its objective. No portion of the fund's investments is committed as sustainable investments within the meaning of Article 2(17) of the SFDR. No reference benchmark has been designated to measure the attainment of the environmental and social characteristics promoted by this financial product.



Environmental and social characteristics promoted

No Such Fund promotes the following environmental and social characteristics across its portfolio:


SDG Contribution: Each investment is assessed on its contribution to the United Nations Sustainable Development Goals, with a primary focus on SDG 8 (Decent Work and Economic Growth), SDG 9 (Industry, Innovation and Infrastructure), SDG 11 (Sustainable Cities and Communities), and SDG 12 (Responsible Consumption and Production)


Good governance

Portfolio companies are assessed pre-investment using the SASB (Sustainability Accounting Standards Board) standards framework, covering core business practices and company-level governance policies. Governance quality is a binding consideration in every investment decision.


Diversity and inclusion

Portfolio companies are contractually required to evaluate and implement best practices with respect to diversity in their employee base within 12 months of investment. This commitment is embedded in the fund's term sheet and shareholder agreement.


Principal Adverse Impacts

A Principal Adverse Impact (PAI) assessment is conducted for each investment as part of the pre-investment due diligence process, identifying potential negative effects on sustainability factors.


Exclusion policy

The following activities are excluded from the investment universe:

  • Fossil fuel production and distribution

  • Gambling and gaming

  • Web3

  • Activities that cause material harm to biodiversity



Investment strategy

No Such Fund invests in European technology companies across two vehicles: a main fund targeting Seed and Series A stage companies, and a seed fund targeting earlier-stage opportunities. Combined, the vehicles target 20 to 25 portfolio companies, with initial tickets ranging from €250,000 to €5 million. Investments are made across three themes: unifying fragmented European markets; strengthening European sovereignty in infrastructure, energy, Industry 4.0, and security; and digitizing and automating European businesses through SaaS, AI, and data solutions. The primary geography is the Netherlands and Benelux, with selective investments across Europe.


ESG considerations are integrated at every stage of the investment process. Prior to investment, companies are screened against the exclusion list, assessed on SDG contribution, evaluated on governance quality using the SASB framework, and subject to a PAI assessment. Findings are documented in the Information Memorandum for each investment proposal and form part of the investment committee decision.



Proportion of investments

At least 90% of the fund's investments, measured by net asset value, will meet the environmental and social characteristics described in this disclosure. The remaining portion may include cash, cash equivalents, and short-term liquidity instruments held between investment periods, which are not subject to ESG screening.



Monitoring of environmental or social characteristics

No Such Fund monitors adherence to the promoted characteristics on an ongoing basis through active portfolio ownership. Post-investment, No Such Ventures II B.V. supports portfolio companies in implementing their Sustainability Risk Policy and diversity commitments, and monitors ESG practices through regular engagement with founders and management teams. Portfolio company compliance with contractual ESG commitments is tracked as part of the fund's standard reporting cycle.



Methodologies

The UN SDG framework serves as the primary methodology for assessing positive environmental and social contribution. Governance quality is assessed using SASB standards. PAI potential is assessed using a proprietary framework applied pre-investment and documented in each investment proposal.

Binding ESG commitments are structured into two legal documents executed at the time of investment: the term sheet and the shareholder agreement. Within 12 months of closing, portfolio companies are contractually required to:

  1. Integrate a Sustainability Risk Policy to identify, assess, control, and report on ESG risks, enhancing transparency and recognising the importance of sustainability in investment decisions; and

  2. Evaluate and implement best business practices with respect to SFDR, including efforts to promote diversity in the employee base.



Data sources and limitations

ESG data is sourced primarily through direct engagement with portfolio companies during pre-investment due diligence and through ongoing portfolio monitoring. The fund uses the UN SDG framework and SASB standards as structured frameworks for data collection and assessment. No third-party ESG data providers are used at this time.


Limitations: Portfolio companies at Seed and Series A stage are typically not yet subject to mandatory sustainability reporting obligations under EU or national law. As a result, standardised or externally verified ESG data is generally not available at the time of investment. The fund addresses this limitation through direct engagement, proprietary due diligence, and the contractual requirement for portfolio companies to implement formal sustainability practices within 12 months of investment. Data quality and comparability are expected to improve as portfolio companies mature.



Due diligence

ESG due diligence is conducted as an integral part of the pre-investment process for every investment. This includes screening against the exclusion list, assessing SDG contribution, evaluating governance quality against SASB standards, and conducting a PAI assessment. Findings are documented in the Information Memorandum of each investment proposal and presented to the investment committee as part of the investment decision.



Engagement policies

No Such Fund takes an active ownership approach. Post-investment, No Such Ventures II B.V. works closely with portfolio companies to support the implementation of their Sustainability Risk Policy and diversity commitments. ESG matters are addressed through regular contact with founders and management teams, consistent with the fund's hands-on support model. Portfolio companies are expected to incorporate sustainability considerations into their operational and governance practices over time.



Reference benchmark

No reference benchmark has been designated to measure the attainment of the environmental and social characteristics promoted by this financial product.



This disclosure is published pursuant to Article 8 of Regulation (EU) 2019/2088 (SFDR) and Commission Delegated Regulation (EU) 2022/1288. It will be reviewed and updated at least annually, or when material changes to the fund's approach occur. No Such Ventures II B.V. — AFM registration numbers 15604700 and 50035601. Last updated: September 2026.

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