Sustainability-Related Disclosures

Firm-level disclosures

Last reviewed October 2026.

Article 3: Integration of sustainability risks in investment decision-making

“Sustainability risk” means an environmental, social, or governance event or condition that, were it to occur, could cause an actual or potential material negative impact on the value of an investment.

Sustainability oversight sits with Senior Leadership, the Managing Partner and the Firm's Advisory Board which reviews the Firm's sustainability initiatives, policies, processes, and communications, and sets overall strategy. The investment team is responsible for day-to-day implementation, monitored by Senior Leadership and the Investment Committee.

Thematic research and sourcing incorporate sustainability-related trends and risks relevant to target sectors.

Due diligence assesses a target company's awareness of and sensitivity to sustainability and impact factors, including internal culture, employee and stakeholder treatment, and external environmental and community impact. A negative finding weighs materially against making an investment.

Post-close management monitors sustainability risk on an ongoing basis through portfolio company engagement and Firm-level review (Investment Committee and, for Fund IV, tracking toward the Article 9 sustainable investment objective).

Portfolio company sustainability data is collected through a standing annual data request issued to each portfolio company, covering the indicators the relevant fund has committed to consider.

This sustainability risk approach applies Firm-wide. Individual funds may apply additional, fund-specific frameworks, for example the Article 9 sustainable investment objectives and environmental exclusions of InterAlpen Partners Growth Fund III and InterAlpen Partners Fund IV, set out in their respective fund-level disclosures.

Article 4: Principal adverse impacts

Article 4 SFDR requires EU financial market participants either to publish an entity-level statement on their due diligence policies in respect of principal adverse impacts, or to give clear reasons for why they do not consider them. By way of derogation, participants exceeding 500 employees must publish the statement and the explain option is not available to them. InterAlpen Partners LLC is (i) a US-domiciled manager not directly subject to Article 4, and (ii) well under the 500-employee threshold in any event.

The Firm does not currently publish a consolidated, entity-level (i.e., across all funds and AUM) statement on the consideration of principal adverse impacts, for the following reasons:

• Non-EU status. The Firm is not an EU financial market participant. Article 4 applies to EU financial market participants, so entity-level PAI reporting is not a requirement for the Firm, and neither the comply route nor the explain route is required of it. The Firm sets out its position voluntarily.
• Product-level approach preferred. The Firm considers PAI indicators at the individual fund level, where it has made a specific commitment to do so, rather than at entity level. Both InterAlpen Partners Growth Fund III and InterAlpen Partners Fund IV are Article 9 products and each considers the mandatory and relevant additional indicators.
• Legacy vehicles. A Firm-wide statement would also have to cover Funds I and II, which pre-date the Firm’s sustainability data collection. Reporting indicators for those portfolios would mean retrofitting processes that were not in place at the time of investment, and the result would not accurately describe how those earlier, non-Article 8/9 vehicles were managed.

Both InterAlpen Partners Growth Fund III and InterAlpen Partners Fund IV are Article 9 products and consider principal adverse impacts at the product level, using the mandatory indicators and the fund-specific environmental exclusions set out in their respective disclosures.

Each fund considers the mandatory and relevant additional principal adverse impact indicators set out in the SFDR Regulatory Technical Standards, covering environmental, social and employment, human rights and anti-corruption topics. The analysis undertaken in due diligence and monitoring considers internationally recognised principles including the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

The Firm will revisit this position at least annually, and sooner if it establishes an EU-authorised management entity, begins marketing into the EU in a way that brings it within scope, or concludes that a Firm-wide statement would be more representative and useful to investors.

Article 5: Remuneration

The Firm's compensation arrangements for investment professionals (base compensation, discretionary bonus, and carried interest participation) are tied to overall fund and Firm performance, which for InterAlpen Fund IV includes attainment of the Fund's Article 9 sustainable investment objective and adherence to its environmental exclusions, since these are contractual commitments to investors that affect the Fund's standing and future fundraising. Sustainability due diligence findings that weigh materially against an investment (Section 2.3) are a factor the Investment Committee considers in investment decisions, and therefore indirectly in the outcomes on which compensation is based.

The investment team is accountable for integrating sustainable impact across all phases of the investment process. That accountability forms part of the annual performance assessment and feeds into variable remuneration.

InterAlpen Partners Growth Fund III

Last reviewed October 2026.