{"id":1912,"date":"2026-02-09T16:59:09","date_gmt":"2026-02-09T15:59:09","guid":{"rendered":"https:\/\/maguar.com\/sfdr-disclosure\/"},"modified":"2026-06-16T22:50:08","modified_gmt":"2026-06-16T20:50:08","slug":"sfdr-disclosure","status":"publish","type":"page","link":"https:\/\/maguar.com\/en\/sfdr-disclosure\/","title":{"rendered":"SFDR Disclosure"},"content":{"rendered":"

[vc_row row_padding=”vpt-7 vpb-7″][vc_column col_sticky=”” offset=”vc_col-xl-offset-3 vc_col-xl-6 vc_col-lg-offset-2 vc_col-lg-8 vc_col-md-offset-1 vc_col-md-10″]

SFDR Disclosure<\/a><\/h1><\/div><\/div>[vc_column_text]<\/p>\n

SFDR Disclosure for Maguar Capital GmbH & Co. KG<\/h2>\n

Introduction<\/h3>\n

Sustainability risk management is an integral part of how Maguar Capital GmbH & Co. KG identifies investment opportunities and makes investment decisions, as well as of its ongoing portfolio and asset management activities. While Maguar Capital GmbH & Co. KG recognizes the importance of identifying, assessing, and managing material sustainability risks as part of its business operations, the fund does not promote environmental or social characteristics, nor does it have sustainable investment as its objective, in accordance with Article 6 of the SFDR. <\/p>\n

Maguar Capital GmbH & Co. KG is an internally managed fund and acts as its own Alternative Investment Fund Manager (AIFM). The management and decision-making authority of Maguar Capital GmbH & Co. KG is exercised by its managing limited partner or its general partner (collectively, \u201cMaguar Capital\u201d). Consequently, certain policies and operations are implemented by Maguar Capital in accordance with the requirements and obligations of Maguar Capital GmbH & Co. KG. <\/p>\n

How Are Sustainability Risks Integrated Into the Investment Process?<\/h3>\n

The Sustainability Risk Policy (also referred to as the \u201cESG Policy\u201d) outlines how Maguar Capital GmbH & Co. KG integrates sustainability risks into its investment decision-making processes. The policy applies throughout the investment cycle, from deal sourcing to portfolio monitoring. The deal team considers sustainability risks alongside other financial and operational risks during preliminary and final investment evaluations. This includes assessments made during initial screening, due diligence, and investment risk analysis. <\/p>\n

However, sustainability risks are not the primary focus or determining factors in investment decisions, and Maguar Capital GmbH & Co. KG retains discretion in pursuing investment opportunities, even when sustainability risks have been identified.<\/p>\n

No Promotion of Environmental or Social Characteristics<\/h3>\n

Maguar Capital GmbH & Co. KG does not specifically promote environmental or social characteristics and does not seek to achieve sustainable investment objectives as defined in Articles 8 or 9 of the SFDR. While certain ESG considerations may be taken into account during the investment decision-making process, they do not constitute a binding or primary criterion. <\/p>\n

No Consideration of Principal Adverse Impacts (PAIs)<\/h3>\n

The SFDR requires Maguar Capital GmbH & Co. KG to make a \u201ccomply or explain\u201d decision regarding whether to consider the principal adverse impacts (PAIs) of its investment decisions on sustainability factors, as set forth in Article 4 of the SFDR. Maguar Capital GmbH & Co. KG has chosen not to comply with this requirement, both in general and with respect to the fund. <\/p>\n

Maguar Capital GmbH & Co. KG intends to keep its decision not to comply with the PAI regime under regular review. The Fund supports the policy objectives of the PAI regime to improve transparency regarding how financial market participants account for the adverse impacts of investment decisions on sustainability factors. However, given the current lack of comprehensive and consistent data, Maguar Capital GmbH & Co. KG has determined that full compliance is not feasible at this time. <\/p>\n

Integration of Sustainability Risks into Compensation Policy<\/h3>\n

While Maguar Capital (together with its subsidiaries and controlled affiliates, \u201cMaguar Capital\u201d) integrates sustainability risks into its investment process, the compensation policy does not specifically link compensation to the achievement of environmental or social targets. Instead, the compensation framework is aligned with the overall business strategy and aims to support sound risk management across all relevant risks, including sustainability risks. <\/p>\n

Conclusion<\/h3>\n

Maguar Capital GmbH & Co. KG incorporates sustainability risks into its overall investment and risk assessment process. However, the fund does not promote specific environmental or social characteristics, nor does it pursue sustainable investment objectives as defined under Article 8 or 9 of the SFDR. Disclosures comply with the requirements of Article 6 of the SFDR to provide transparency regarding the consideration of sustainability risks without implying any binding ESG objectives or systematic monitoring of principal adverse impacts. <\/p>\n

<\/div>\n

SFDR Disclosure for Maguar Capital II GmbH & Co. KG<\/h2>\n

Introduction<\/h3>\n

Sustainability risk management is an integral part of how Maguar Capital II GmbH & Co. KG identifies investment opportunities and makes investment decisions, as well as of its ongoing portfolio and asset management activities. Maguar Capital II GmbH & Co. KG recognizes the importance of identifying, assessing, and managing material sustainability risks as an integral part of its business operations. <\/p>\n

Maguar Capital II GmbH & Co. KG is an internally managed fund and, as such, also acts as its own alternative investment fund manager (AIFM). The management and decision-making authority of Maguar Capital II GmbH & Co. KG is exercised by its managing limited partner, Maguar Capital Management GmbH, or its general partner, Maguar Administration II GmbH (collectively, \u201cMaguar Capital\u201d). Consequently, certain policies and operations are implemented by Maguar Capital in accordance with the requirements and obligations of Maguar Capital II GmbH & Co. KG. <\/p>\n

Maguar Capital\u2019s sustainability risk policy (also referred to as the \u201cESG Policy\u201d) provides a comprehensive framework for integrating sustainability risk management into Maguar Capital II GmbH & Co. KG\u2019s investment decision-making processes.<\/p>\n

How does this Sustainability Risk Policy work?<\/h3>\n

The Sustainability Risk Policy outlines how sustainability risks are integrated into Maguar Capital\u2019s investment decision-making processes. The policy applies throughout Maguar Capital\u2019s entire investment cycle. The deal team uses this policy as a key consideration in the deal-flow process, from sourcing to completion. In addition, Maguar places great importance on this policy in the ongoing monitoring of its portfolio of existing investments. The investment committee takes sustainability risk factors into account when deciding on the exit from an investment. <\/p>\n

Our policy addresses the key sustainability risk factors related to environmental, social, and governance issues. Within each category, we identify relevant subcategories pertaining to our operations and target industries. The following non-exhaustive list of sustainability risks is considered: climate change resilience, pollution, biodiversity, carbon emissions, human rights in supply chains, health and safety, community relations, cultural heritage, labor and employment practices, and resource efficiency. The materiality of each risk will be determined on a case-by-case basis for each investment. <\/p>\n

Integration of Sustainability Risks into Investment Decision-Making Processes<\/h3>\n

Sustainability risks are taken into account at all stages of each product\u2019s investment process, with respect to each individual investment opportunity.<\/p>\n

    \n
  1. Initial Screening<\/strong>:
    \no Determine whether the potential investment aligns with the Sustainability Risk Policy during preliminary investment committee meetings.<\/li>\n
  2. Due Diligence<\/strong>:
    \no Conduct an in-depth assessment of sustainability risks during the due diligence process.
    \no Complete a summary ESG questionnaire as part of the investment committee paper. This questionnaire assesses initial sustainability risks and identifies areas requiring further investigation or due diligence. <\/li>\n
  3. Risk Assessment<\/strong>:
    \no Complete the sustainability risk matrix and due diligence questionnaires twice during the investment process: at the Preliminary Investment Approval stage and at the Final Investment Approval stage.
    \no Engage external specialists for complex industries or sensitive environments.
    \no Score and rate identified risks as Low, Medium, or High, with a narrative comment on each area.<\/li>\n<\/ol>\n

    Governance<\/h3>\n

    At Maguar Capital, the Compliance Officer is responsible for overseeing sustainability and ESG risks and reports directly to the management of Maguar Capital Management GmbH. All members of Maguar Capital are required to comply with and operate in accordance with the ESG policy. As the firm grows in terms of employees and assets under management, additional roles such as a Sustainability Officer and an ESG committee are planned to be implemented. <\/p>\n

    No Consideration of Adverse Impacts<\/h3>\n

    The SFDR requires Maguar Capital II GmbH & Co. KG to make a \u201ccomply or explain\u201d decision regarding whether to consider the principal adverse impacts (PAIs) of its investment decisions on sustainability factors. Maguar Capital II GmbH & Co. KG has chosen not to comply with that requirement. <\/p>\n

    Maguar Capital II GmbH & Co. KG intends to keep its decision not to comply with the PAI regime under regular review. Maguar Capital has carefully evaluated the requirements of the PAI regime set forth in Article 4 of the SFDR and in the draft Regulatory Technical Standards published in April 2020. Maguar Capital supports the policy objectives of the PAI regime but is concerned about the lack of readily available data to meet many of the reporting requirements. Companies and market data providers are not yet prepared to make all the necessary data for the PAI regime available. <\/p>\n

    Notwithstanding Maguar Capital II GmbH & Co. KG\u2019s decision not to comply with the PAI regime, Maguar Capital has implemented positive ESG-related initiatives and policies as part of its overall commitment to ESG matters. For the avoidance of doubt, none of the following information is intended to imply that Maguar Capital II GmbH & Co. KG complies with the PAI regime. <\/p>\n

    Compensation Policy<\/h3>\n

    Maguar Capital (together with its subsidiaries and controlled affiliates, \u201cMaguar Capital\u201d) has established a compensation policy (the \u201cPolicy\u201d) applicable to all Maguar Capital entities. The Policy is developed, approved, implemented, and monitored by various bodies within the Maguar Capital organization. The Policy applies to all employees of Maguar Capital, with limited exceptions. <\/p>\n

    The Policy has been developed to support Maguar Capital\u2019s business strategy, corporate values, and long-term interests, including by facilitating the identification, assessment, and management of sustainability risks when determining individual compensation packages. The key principles of the Policy include fostering an appropriate risk culture (including with respect to the management of actual and potential conflicts of interest) and compliance with applicable laws and regulations. <\/p>\n

    The performance management and rewards framework envisioned by the Policy has been designed to promote effective risk management, in particular by:<\/p>\n

      \n
    1. Ensuring that performance assessments fully take into account compliance with risk management requirements, covering all relevant types of current and future risks, including sustainability risks.<\/li>\n
    2. Implementing deferral arrangements through co-investment and carried interest arrangements for senior personnel, thereby aligning the interests of staff members with those of third-party investors. If the value of the relevant underlying investment portfolio were to decrease (whether as a result of a sustainability risk or otherwise), the value of the employee\u2019s holdings would be reduced accordingly. <\/li>\n
    3. Providing for the reduction of deferred variable compensation awards to senior personnel under certain circumstances, such as in the event that the entity where the relevant employee works experiences a significant failure in risk management or a significant decline in its financial performance (as determined in the sole discretion of Maguar Capital), including in connection with a sustainability risk related to an investment.<\/li>\n<\/ol>\n

      I. Summary<\/h3>\n

      Maguar Capital II GmbH & Co. KG intends to promote environmental and social criteria and consider the adverse impact of its investment decisions on certain sustainability factors across its portfolio companies. Maguar Capital II GmbH & Co. KG will continue to focus on investing in B2B software and technology companies in the DACH region. <\/p>\n

      II. No Sustainable Investment Objectives<\/h3>\n

      Maguar Capital II GmbH & Co. KG intends to promote environmental and social characteristics (Article 8 of the SFDR) but does not aim to make any sustainable investments (Article 9 of the SFDR).<\/p>\n

      III. Environmental or Social Characteristics of Maguar Capital II GmbH & Co. KG<\/h3>\n

      Maguar Capital II GmbH & Co. KG promotes environmental and social criteria by incorporating ESG considerations into its investment processes.<\/p>\n

        \n
      • Environment<\/strong>: Climate change, pollution, waste management, resource management, the environmental footprint in the supply chain, and energy use for technological infrastructure.<\/li>\n
      • Social<\/strong>: Employee well-being, health and safety, supply chain, and human rights; product integrity, safety, and quality; community impact; employee diversity; and data protection and cybersecurity.<\/li>\n
      • Governance<\/strong>: Business ethics, code of conduct, board and management structure, internal controls, supply chain governance, stakeholder engagement, and reporting.<\/li>\n<\/ul>\n

        IV. Investment Strategy<\/h3>\n

        Maguar intends to continue its successful strategy into the second generation (Maguar Capital II GmbH & Co. KG), which centers on identifying, negotiating, executing, monitoring, and realizing equity-related investments in businesses. Maguar Capital II GmbH & Co. KG\u2019s strategy focuses on small and mid-size software, software-based services, and technology platform companies, with a particular focus on the DACH region. <\/p>\n

        Maguar Capital believes that sustainable business practices go hand in hand with fund-level performance. ESG considerations are integrated into the investment process through the implementation of Maguar Capital\u2019s ESG Policy, which is consistent with the requirements and recommendations of established industry standards such as the United Nations Principles for Responsible Investment (UN PRI). <\/p>\n

        Maguar Capital II GmbH & Co. KG will not invest in, guarantee, or otherwise provide financial or other support, directly or indirectly, to companies or other entities that generate significant revenue from direct involvement in:<\/p>\n

          \n
        • Tobacco, alcoholic beverages, weapons, ammunition, gambling, casinos, pornography, illegal activities, real estate holdings, asset stripping, genetically modified organisms (GMOs), or related sectors.<\/li>\n<\/ul>\n

          V. Proportion of Investments<\/h3>\n

          Maguar Capital II GmbH & Co. KG does not commit to making sustainable investments with an environmental objective aligned with the EU Taxonomy, and therefore will not commit to a minimum level of sustainable investment.<\/p>\n

          VI. Monitoring of Environmental or Social Characteristics \/ Asset Allocation<\/h3>\n

          The Maguar Capital II GmbH & Co. KG portfolio is intended to have the potential to contribute positively to addressing climate change and\/or to assist in the transition to a \u201cnet-zero\u201d economy. Investments may include sustainable investments as defined by the SFDR; however, there will be no minimum allocation to sustainable investments. <\/p>\n

          \n
          \"\"<\/figure>\n<\/div>\n

          \u201c#1 Aligned with E\/S characteristics\u201d includes the investments of the financial product used to achieve the environmental or social characteristics promoted by the financial product. Category #1 Aligned with E\/S characteristics includes subcategory #1B Other E\/S characteristics, which covers investments aligned with environmental or social characteristics that do not qualify as sustainable investments. <\/p>\n

          VII. Methodologies for Environmental or Social Characteristics<\/h3>\n

          Any investment by Maguar Capital II GmbH & Co. KG will undergo ESG due diligence in accordance with Maguar\u2019s ESG policy, specifically its ESG due diligence checklist.<\/p>\n

          The following areas will be evaluated:<\/p>\n

            \n
          • Available internal policies and awareness-raising measures related to ESG topics.<\/li>\n
          • Implemented reporting and monitoring processes.<\/li>\n
          • Recent ESG incidents and the responses to them.<\/li>\n
          • Supplier selection, interactions, and ongoing evaluation.<\/li>\n
          • Data protection guidelines, processes, and incidents.<\/li>\n
          • Current state of cybersecurity, monitoring procedures.<\/li>\n
          • Guidelines for using open-source software and monitoring processes.<\/li>\n<\/ul>\n

            VIII. Data Sources and Processing<\/h3>\n

            Maguar Capital II GmbH & Co. KG relies on a variety of data sources to assess and monitor the sustainability performance of its investments. These sources include: <\/p>\n

              \n
            • Internal Data<\/strong>: Information provided by portfolio companies, such as ESG reports, completed ESG questionnaires, and compliance documentation.<\/li>\n
            • External Data Providers<\/strong>: Data from third-party ESG rating agencies and sustainability data providers to ensure comprehensive and accurate assessments.<\/li>\n
            • Publicly Available Data<\/strong>: Information from public disclosures, regulatory filings, and industry reports.<\/li>\n<\/ul>\n

              To ensure the quality and reliability of the data, Maguar Capital employs rigorous data processing methodologies. This involves cross-verifying information from multiple sources, using advanced data analytics tools, and conducting regular audits of data management processes. The proportion of estimated data is minimized and clearly identified when used. <\/p>\n

              IX. Limitations of Methodologies and Data<\/h3>\n

              The EU Taxonomy establishes a \u201cdo no significant harm\u201d principle, under which investments aligned with the Taxonomy should not significantly harm the objectives of the EU Taxonomy, and is accompanied by specific EU criteria. The \u201cdo no significant harm\u201d principle applies to the investments underlying the Fund, which take into account the EU criteria for environmentally sustainable economic activities. <\/p>\n

              Maguar Capital II GmbH & Co. KG\u2019s investment strategy focuses primarily on majority buyout investments; however, the Fund may participate as a minority stakeholder in some portfolio companies. As a minority stakeholder, legal restrictions would prevent Maguar Capital II GmbH & Co. KG from guaranteeing full compliance with all requirements outlined by the SFDR and the EU Taxonomy for sustainable investments with an environmental objective aligned with the EU Taxonomy. <\/p>\n

              X. Due Diligence<\/h3>\n

              Sustainability is embedded in Maguar Capital II GmbH & Co. KG through Maguar\u2019s ESG policy. ESG considerations are taken into account throughout the entire investment lifecycle, including the due diligence phase for all new acquisitions. Maguar Capital requires its deal teams to include ESG screening analysis in investment memoranda when seeking final approval from the Investment Committee. In addition to due diligence screening, ongoing ESG monitoring, and regular communication between Maguar Capital and the portfolio companies, Maguar Capital does not conduct further research or investigations on a regular basis, at least as long as the data reported by the portfolio companies do not give rise to any reasonable doubts. <\/p>\n

              XI. Engagement Policy<\/h3>\n

              Maguar Capital\u2019s engagement policy is an integral part of its environmental and social investment strategy. This policy includes: <\/p>\n

                \n
              • Active Engagement<\/strong>: Engaging with portfolio companies to promote the adoption and improvement of sustainable practices.<\/li>\n
              • Management Procedures<\/strong>: Implementing management procedures to address sustainability-related controversies at companies in which the firm has invested.<\/li>\n
              • Monitoring and Reporting<\/strong>: Regularly monitoring and reporting on the progress and effectiveness of engagement activities.<\/li>\n<\/ul>\n

                The engagement policy aims to ensure that portfolio companies adhere to high standards of business ethics, environmental responsibility, and social governance, in line with the overall sustainability objectives of Maguar Capital II GmbH & Co. KG.<\/p>\n

                XI. Designated Reference Benchmark<\/h3>\n

                Maguar Capital II GmbH & Co. KG does not use benchmarks when making investment decisions. Instead, we use absolute values to assess the sustainability performance of our investments. This approach allows us to focus on the actual impact and improvements made by each portfolio company rather than comparing them to an external standard that may not fully capture the unique aspects of our investments. <\/p>\n

                <\/div>\n

                SFDR Disclosure for Maguar Continuation Fund I GmbH & Co. KG<\/h2>\n

                Introduction<\/h3>\n

                Sustainability risk management is an integral part of how Maguar Continuation Fund I GmbH & Co. KG identifies investment opportunities and makes investment decisions, as well as in its ongoing portfolio and asset management activities. Maguar Continuation Fund I GmbH & Co. KG recognizes the importance of identifying, assessing, and managing material sustainability risks as an integral part of its business operations. <\/p>\n

                Maguar Continuation Fund I GmbH & Co. KG is an internally managed fund and, as such, also acts as its own alternative investment fund manager (AIFM). The management and decision-making authority of Maguar Continuation Fund I GmbH & Co. KG is exercised by its managing limited partner, Maguar Capital Management GmbH, or its general partner, Maguar Continuation Fund I Administration GmbH (collectively, \u201cMaguar Capital\u201d). Consequently, certain policies and operations are implemented by Maguar Capital in accordance with the requirements and obligations of Maguar Continuation Fund I GmbH & Co. KG. <\/p>\n

                Maguar Capital\u2019s sustainability risk policy (also referred to as the \u201cESG Policy\u201d) provides a comprehensive framework for integrating sustainability risk management into Maguar Continuation Fund I GmbH & Co. KG\u2019s investment decision-making processes.<\/p>\n

                How does this Sustainability Risk Policy work?<\/h3>\n

                The Sustainability Risk Policy outlines how sustainability risks are integrated into Maguar Capital\u2019s investment decision-making processes. The policy applies throughout Maguar Capital\u2019s entire investment cycle. The deal team uses this policy as a key consideration in the deal-flow process, from sourcing to completion. In addition, Maguar places great importance on this policy in the ongoing monitoring of its portfolio of existing investments. The investment committee takes sustainability risk factors into account when deciding on the exit of an investment. <\/p>\n

                Our policy addresses the key sustainability risk factors related to environmental, social, and governance issues. Within each category, we identify relevant subcategories pertaining to our operations and target industries. The following non-exhaustive list of sustainability risks is considered: climate change resilience, pollution, biodiversity, carbon emissions, human rights in supply chains, health and safety, community relations, cultural heritage, labor and employment practices, and resource efficiency. The materiality of each risk will be determined on a case-by-case basis for each investment. <\/p>\n

                Integration of Sustainability Risks into Investment Decision-Making Processes<\/h3>\n

                Sustainability risks are taken into account at all stages of each product\u2019s investment process, with respect to each individual investment opportunity.<\/p>\n

                  \n
                1. Initial Screening<\/strong>:
                  \no Determine whether the potential investment aligns with the Sustainability Risk Policy during preliminary investment committee meetings.<\/li>\n
                2. Due Diligence<\/strong>:
                  \no Conduct an in-depth assessment of sustainability risks during the due diligence process.
                  \no Complete a summary ESG questionnaire as part of the investment committee paper. This questionnaire assesses initial sustainability risks and identifies areas requiring further investigation or due diligence. <\/li>\n
                3. Risk Assessment<\/strong>:
                  \no Complete the sustainability risk matrix and due diligence questionnaires twice during the investment process: at the Preliminary Investment Approval stage and at the Final Investment Approval stage.
                  \no Engage external specialists for complex industries or sensitive environments.
                  \no Score and rate identified risks as Low, Medium, or High, with a narrative comment on each area.<\/li>\n<\/ol>\n

                  Governance<\/h3>\n

                  At Maguar Capital, the ESG Officer is responsible for overseeing sustainability and ESG risks and reports directly to the management of Maguar Capital Management GmbH. All members of Maguar Capital are required to comply with and operate in accordance with the ESG policy. As the firm grows in terms of employees and assets under management, additional roles such as a Sustainability Officer and an ESG committee are planned to be established. <\/p>\n

                  No Consideration of Adverse Impacts<\/h3>\n

                  The SFDR requires Maguar Continuation Fund I GmbH & Co. KG to make a \u201ccomply or explain\u201d decision regarding whether to consider the principal adverse impacts (PAIs) of its investment decisions on sustainability factors. Maguar Continuation Fund I GmbH & Co. KG has chosen not to comply with that requirement. <\/p>\n

                  Maguar Continuation Fund I GmbH & Co. KG will keep its decision not to comply with the PAI regime under regular review. Maguar Capital has carefully evaluated the requirements of the PAI regime set forth in Article 4 of the SFDR and in the draft Regulatory Technical Standards published in April 2020. Maguar Capital supports the policy objectives of the PAI regime but is concerned about the lack of readily available data to meet many of the reporting requirements. Companies and market data providers are not yet prepared to make all the necessary data for the PAI regime available. <\/p>\n

                  Notwithstanding Maguar Continuation Fund I GmbH & Co. KG\u2019s decision not to comply with the PAI regime, Maguar Capital has implemented positive ESG-related initiatives and policies as part of its overall commitment to ESG matters. For the avoidance of doubt, none of the following information is intended to suggest that Maguar Continuation Fund I GmbH & Co. KG complies with the PAI regime. <\/p>\n

                  Compensation Policy<\/h3>\n

                  Maguar Capital (together with its subsidiaries and controlled affiliates, \u201cMaguar Capital\u201d) has established a compensation policy (the \u201cPolicy\u201d) applicable to all Maguar Capital entities. The Policy is developed, approved, implemented, and monitored by various bodies within the Maguar Capital organization. The Policy applies to all Maguar Capital employees, with limited exceptions. <\/p>\n

                  The Policy has been developed to support Maguar Capital\u2019s business strategy, corporate values, and long-term interests, including by facilitating the identification, assessment, and management of sustainability risks when determining individual compensation packages. The key principles of the Policy include fostering an appropriate risk culture (including with respect to the management of actual and potential conflicts of interest) and compliance with applicable laws and regulations. <\/p>\n

                  The performance management and rewards framework outlined in the Policy has been designed to promote effective risk management, in particular by:<\/p>\n

                    \n
                  1. Ensuring that performance assessments fully take into account compliance with risk management requirements, covering all relevant types of current and future risks, including sustainability risks.<\/li>\n
                  2. Implementing deferral arrangements through co-investment and carried interest arrangements for senior personnel, thereby aligning the interests of staff members with those of third-party investors. If the value of the relevant underlying investment portfolio were to decrease (whether as a result of a sustainability risk or otherwise), the value of the employee\u2019s holdings would be reduced accordingly. <\/li>\n
                  3. Providing for the reduction of deferred variable compensation awards to senior personnel under certain circumstances, such as in the event that the entity where the relevant employee works experiences a significant failure in risk management or a significant decline in its financial performance (as determined in the sole discretion of Maguar Capital), including in connection with a sustainability risk related to an investment.<\/li>\n<\/ol>\n

                    I. Summary<\/h3>\n

                    Maguar Continuation Fund I GmbH & Co. KG (\u201cMaguar Continuation Fund I\u201d) promotes environmental and social characteristics within its investment processes, particularly in relation to its single-asset investment in HR WORKS. However, it does not set sustainable investment as its primary objective. Although the fund operates under Article 8 of the SFDR, it is not fully compliant with all Article 8 requirements. <\/p>\n

                    II. No Sustainable Investment Objectives<\/h3>\n

                    Maguar Continuation Fund I promotes environmental and social characteristics but does not have sustainable investments (Article 9 of the SFDR) as its objective.<\/p>\n

                    III. Environmental or Social Characteristics of Maguar Continuation Fund I<\/h3>\n

                    The fund incorporates ESG considerations into its investment in HR WORKS, with a focus on promoting responsible business practices, including governance structures, social responsibility, and environmental risk management. However, the ESG characteristics promoted by Maguar Continuation Fund I are not binding and do not constitute the fund\u2019s primary objective. <\/p>\n

                    IV. Investment Strategy<\/h3>\n

                    Maguar Continuation Fund I is a single-asset continuation fund focused exclusively on its investment in HR WORKS, a provider of HR software and technology solutions headquartered in Freiburg, Germany. While ESG factors are considered and encouraged in HR WORKS\u2019 business practices, the primary focus remains on financial performance and strategic growth. The fund employs an ownership approach to enhance value creation in HR WORKS\u2019
                    \n, applying ESG best practices where appropriate, without binding sustainability targets. <\/p>\n

                    V. Proportion of Investments<\/h3>\n

                    The fund is invested solely in HR WORKS, and all considerations regarding environmental and social characteristics are directly related to this single asset. The fund does not commit to making sustainable investments with an environmental objective aligned with the EU Taxonomy. <\/p>\n

                    VI. Monitoring of Environmental or Social Characteristics \/ Asset Allocation<\/h3>\n

                    Maguar Continuation Fund I regularly engages with HR WORKS to assess and promote responsible business conduct and monitor ESG-related risks and performance. Monitoring activities focus on the business model and industry practices relevant to HR WORKS. There are no external monitoring mechanisms in place, and the fund does not adhere to specific asset allocations aligned with sustainable investments. <\/p>\n

                    \n
                    \"\"<\/figure>\n<\/div>\n

                    VII. Methodologies for Environmental or Social Characteristics<\/h3>\n

                    The methodologies used by Maguar Continuation Fund I to assess environmental and social characteristics are tailored to HR WORKS\u2019 operations and strategy. The fund conducts qualitative assessments during the investment process and through ongoing engagement to ensure that ESG considerations are integrated into HR WORKS\u2019 business practices and risk management. <\/p>\n

                    VIII. Data Sources and Processing<\/h3>\n

                    The fund primarily relies on data obtained directly from HR WORKS to assess and monitor sustainability-related performance. This includes internal reports, ESG-related documentation, and company disclosures. Publicly available data may also be used to supplement the internal information. The data is verified as necessary to ensure its accuracy and relevance to the fund\u2019s investment objectives. <\/p>\n

                    IX. Limitations of Methodologies and Data<\/h3>\n

                    Given that Maguar Continuation Fund I is a single-asset fund, there are limitations on the scope and diversity of the available ESG data. The fund relies on HR WORKS\u2019 direct engagement and transparency to obtain relevant information. While every effort is made to verify the accuracy of the data, there may be some limitations in terms of data completeness and consistency. <\/p>\n

                    X. Due Diligence<\/h3>\n

                    Maguar Continuation Fund I conducts due diligence in accordance with its Sustainability Risk Policy, with a focus on understanding the environmental, social, and governance practices of HR WORKS. This assessment is part of the overall investment process and continues throughout the holding period to ensure ongoing alignment with ESG considerations. <\/p>\n

                    XI. Engagement Policy<\/h3>\n

                    The fund actively engages with HR WORKS to promote responsible business practices and address any sustainability-related controversies. Regular monitoring and dialogue with HR WORKS aim to align the company\u2019s operations with the environmental and social principles promoted by Maguar Continuation Fund I, while ensuring that financial performance remains the primary objective. <\/p>\n

                    XII. Designated Reference Benchmark<\/h3>\n

                    Maguar Continuation Fund I does not use a benchmark to assess the sustainability performance of its investments. Instead, the fund relies on qualitative assessments and ongoing engagement with HR WORKS to track the progress and implementation of ESG considerations. <\/p>\n

                    [\/vc_column_text][\/vc_column][\/vc_row]<\/p>\n<\/div>","protected":false},"excerpt":{"rendered":"

                    [vc_row row_padding=”vpt-7 vpb-7″][vc_column col_sticky=”” offset=”vc_col-xl-offset-3 vc_col-xl-6 vc_col-lg-offset-2 vc_col-lg-8 vc_col-md-offset-1 vc_col-md-10″][vc_column_text] SFDR Disclosure for Maguar Capital GmbH & Co. KG Introduction Sustainability risk management is an integral part of how Maguar Capital GmbH & Co. KG identifies investment opportunities and makes investment decisions, as well as of its ongoing portfolio and asset management activities. While Maguar […]<\/p>\n","protected":false},"author":1,"featured_media":0,"parent":0,"menu_order":10,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":""},"class_list":["post-1912","page","type-page","status-publish","hentry"],"acf":[],"_links":{"self":[{"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/pages\/1912","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/comments?post=1912"}],"version-history":[{"count":2,"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/pages\/1912\/revisions"}],"predecessor-version":[{"id":1914,"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/pages\/1912\/revisions\/1914"}],"wp:attachment":[{"href":"https:\/\/maguar.com\/en\/wp-json\/wp\/v2\/media?parent=1912"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}