Mandatory disclosures under the Regulation of the European Parliament and of the Council on sustainability-related disclosure requirements in the financial services sector (EU) 2019/2088 (“Disclosure Regulation”):

At ECM Equity Capital Management GmbH (“ECM”, “we”) we have integrated the analysis of sustainability risks into all phases of the investment life cycle – from the initial analysis through the ownership phase to ultimate exit. 

At the initial stage ECM screens investment opportunities for restrictions that prevent its funds under management from investing in certain businesses and sectors. ECM excludes for example businesses that have activities in the sectors gambling, pornography, controversial weapons or tobacco or that operate in violation of the UN Global Compact principles or OECD Guidelines for Multinational Enterprises.

After the initial review the deal team analyses company specific Environmental, Social and Governance (ESG) aspects based on seller documents, management presentations, own research and expert interviews. Prior to the investment decision, an ESG due diligence will be performed by an external consultant. ESG risks and value creation potentials identified in the due diligence are reviewed by the Investment Committee as part of investment decisions.

During the ownership period, we provide support to the management teams of the portfolio companies in developing appropriate measures to achieve ESG goals specifically aligned to their respective business models. Portfolio companies regularly report to their supervisory boards on the development of their defined individual ESG goals and the implementation of strategic measures. Furthermore, a comprehensive external ESG review is conducted on an annual basis to monitor and update the results and recommendations of the initial ESG due diligence, as well as to monitor any actions defined to reduce adverse impacts on sustainability factors. Respective reviews are shared with potential buyers in the exit phase.

ECM’s ESG management approach is documented in detail in its ESG Policy. All investment team members undergo training on its application at least once a year.

Currently, ECM does not consider principle adverse impacts (PAI) of investment decisions on sustainability factors as defined by the SFDR (Art. 4 (1.) (a)). We have started collecting relevant data points from the portfolio companies to calculate the PAI indicators at entity level. However, we cannot currently ensure the necessary level of data coverage and data quality to disclose the “principal adverse sustainability impacts statement” according to the template in annex I table 1 of the Commission Delegated Regulation (EU) 2022/1288. Data collection challenges also relate to (i) the small size of the portfolio companies and (ii) the lack of publicly available sustainability data. We are committed to supporting the portfolio companies in improving data availability and quality further, with the aim of publishing a PAI entity statement here in the future.

Although we currently do not comply with Art. 4 (1.) (a) SFDR, we nevertheless review adverse impacts of investment decisions on sustainability factors by (i) defining certain exclusion criteria for investment opportunities, (ii) performing ESG due diligences and (iii) integrating ESG goals in the value creation strategy.

Neither ECM nor the funds managed by ECM have a formal remuneration policy in accordance with the requirements of the KAGB. However, ECM's remuneration model incorporates ESG-related KPIs in the performance evaluations of the Partners and the Head of ESG.

Last updated in July 2025