Sustainability

The following data relates to CYCAP Capital Management GmbH. With regard to greenhouse gas emissions, there is currently no separation between the companies within CYCAP. All greenhouse gas emissions are currently allocated to CYCAP Capital Management GmbH. The figures are rounded to two decimal places. Greenhouse gas emissions are reported in metric tons of CO2 equivalent. The indicators for principal adverse impacts on sustainability factors are recorded in accordance with the requirements of Regulation (EU) 2022/1288 (see https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32022R1288&qid=1702312221878#d1e38-38-1).

The information was published on June 28, 2024. It was updated and published on 16. May 2025.

The following data relates to CYCAP Capital Management GmbH. With regard to greenhouse gas emissions, there is currently no separation between the companies within CYCAP. All greenhouse gas emissions are currently allocated to CYCAP Capital Management GmbH. The figures are rounded to two decimal places. Greenhouse gas emissions are reported in metric tons of CO2 equivalent. The indicators for principal adverse impacts on sustainability factors are recorded in accordance with the requirements of Regulation (EU) 2022/1288 (see https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32022R1288&qid=1702312221878#d1e38-38-1).

The information was published on June 30, 2025. It was updated and published on 21. April 2026

The following data relates to CYCAP Capital Management GmbH. With regard to greenhouse gas emissions, there is currently no separation between the companies within CYCAP. All greenhouse gas emissions are currently allocated to CYCAP Capital Management GmbH. The figures are rounded to two decimal places. Greenhouse gas emissions are reported in metric tons of CO2 equivalent. The indicators for principal adverse impacts on sustainability factors are recorded in accordance with the requirements of Regulation (EU) 2022/1288 (see https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=CELEX:32022R1288&qid=1702312221878#d1e38-38-1).

The information was published on June 26, 2026. 

Sustainable and future-proof investment – that is our claim. By investing in the development and generation of renewable energies, we not only generate attractive returns for our investors, but also secure our future in the long term. Our aim is to support and shape the expansion of the renewable energy market in the long term.

As an investment manager and operator of long-term renewable energy projects, we are committed to achieving a risk-adequate return that is in line with the objectives of our investors. We are convinced that the integration of ESG criteria has a real, positive impact on our environment and our business environment and thus on our actions.

CYCAP Capital Management GmbH also takes sustainability risks into account in its investment decision-making processes, i.e. events or conditions in the environmental, social or corporate governance areas that could have a significant negative impact on the value of an investment if they occur.

The review of sustainability risks is based on the respective investment strategy of the mandates and the type of assets to be acquired and is carried out on the basis of qualitative and/or quantitative factors. The results are incorporated – as part of the risk assessment – together with the results of the other due diligence checks (including legal, technical and commercial) into the overall assessment of the project. Our asset managers accompany the projects right from the start of the due diligence process. This ensures a seamless transition from the acquisition to the operational management of the projects and direct integration into the operational risk processes.

The corresponding requirements are documented as part of the internal ESG, risk and asset management guidelines as well as further process descriptions.

In addition, the company has internal guidelines and specifications (in particular anti-corruption guidelines, code of conduct and ethics and employee remuneration guidelines) for taking sustainability factors into account in our actions and activities as a financial market participant.

The company is subject to the regulatory requirements applicable to capital management companies with regard to the structure of its remuneration system. The Company’s compensation policy is based on the provisions of Directive 2011/61/EU (AIFM Directive) and the corresponding national implementing regulations in the German Capital Investment Code (KAGB).

The documentation takes place within the framework of a corresponding remuneration guideline. The company’s Supervisory Board is responsible for the adoption and maintenance of the remuneration policy and oversees its implementation by the Executive Board.

The remuneration policy is geared towards not encouraging disproportionate risk-taking, particularly in comparison to the investment policy of a mandate.

The remuneration comprises both fixed and variable components. When determining variable remuneration components, the achievement of sustainable business development, the protection of the company and the protection of the mandates and investors under management, including with regard to relevant ESG factors, are also taken into account in the assessment when determining target achievement as part of the personal performance assessment.

Information pursuant to Art. 6 of Regulation (EU) 2019/2088 in relation to the financial products managed by the company is provided in the pre-contractual information. The timing and scope of the respective information depends on the respective product category and classification in relation to Regulation (EU) 2019/2088. CYCAP Capital Management GmbH assesses sustainability risks for all financial products under management as part of its overarching risk management process. Sustainability risks are events or conditions in the areas of the environment, social issues, or corporate governance that—if they occur—could have actual or potential material adverse effects on the value of an investment. Product-specific information regarding how these risks are incorporated and how their expected impact on the returns of the respective financial products is assessed is included in the pre-contractual information

CYCAP Capital Management GmbH takes into account the most significant adverse impacts on sustainability factors (known as “Principal Adverse Impacts,” or “PAI”) in the financial products it manages. PAI indicators are taken into account both at the company level (see PAI Statement) and at the product level as part of pre-contractual disclosures and ongoing reporting (see disclosures pursuant to Article 10 of the SFDR). The timing and scope of the respective product-related disclosures depend on the relevant product category and the classification of the financial product under Regulation (EU) 2019/2088.

Disclosures pursuant to Art. 10 of Regulation (EU) 2019/2088 in relation to the financial products managed by the company that pursue sustainable investments.

CEE Renewable Fund 7 S.C.S., SICAV-RAIF

Name of the financial product: CEE Renewable Fund 7 S.C.S, SICAV-RAIF (“CEE RF7”)

Status of the information: December 31, 2025 (Last updated on April 21, 2026)

Information on how sustainability risks are taken into account in investment decisions and the results of the assessment of the expected impact of sustainability risks on the return of the financial product.

To ensure that the investments do not result in significant harm to one or more of the environmental objectives set out in Article 9 of the Taxonomy Regulation, the criteria set out in Section 4.1 and Section 4.3 of Annex I to Delegated Regulation (EU) 2021/2139 to the Taxonomy Regulation are observed and implemented and indicators for adverse impacts on sustainability factors are taken into account.

The financial product invests in renewable energy plants. The investment focus is on onshore wind energy and solar energy plants. Renewable energy plants refers to one or more plants for the generation of electricity and/or heat through the conversion of onshore wind and/or solar energy into electricity and any associated utilization and/or usage rights as well as infrastructure plants and facilities associated with such plants, e.g. for the conversion and transport of electricity as well as supply plants for such plants. The investment spectrum is accordingly limited to this area, i.e. the acquisition of assets from other, potentially critical asset classes is not part of the investment objective.

Summary

As a sustainable investment objective, this financial product pursues a significant contribution to climate protection through investments in renewable energy generation facilities and associated infrastructure. These investments represent a key element in the transition to a low-carbon, more sustainable, resource-efficient circular economy and directly contribute to reducing CO2 emissions by acting as a substitute for conventional electricity generation sources.

The investment strategy aims for a long-term stable portfolio through balanced diversification of renewable energy facilities, with an investment focus on onshore wind and solar power plants. At least 75% of the assets are invested in the “Sustainable – Ecological – Taxonomy-Compliant” category.

The sustainable investment objective is monitored through the continuous determination of sustainability indicators such as CO2e avoidance, sustainable electricity production, sustainably allocated capital, preservation of biodiversity and ecosystems, and the avoidance of significant negative environmental impacts. In addition, high standards are set with regard to human rights, anti-corruption, occupational and operational safety, and responsible corporate governance.

The main measurement criterion is the determination of CO2e emissions avoided compared to conventional, fossil-fuel-based power generation sources. The data for this purpose comes from public sources as well as the company’s own production data. The methodology considers both direct and indirect emissions according to the principles of life cycle analysis.

Investment decisions are reviewed to ensure that the investments comply with the investment criteria and the relevant minimum protection requirements pursuant to Article 18 of the Taxonomy Regulation are met. A specific participation policy is not part of the sustainable investment objective.

Achievement of the investment objective is not measured using an EU reference value, but is determined directly using CO2e factors, as renewable energies are a direct substitute for climate-damaging conventional power plants.

The information above is provided in accordance with Article 37, in conjunction with Article 38, of Regulation (EU) No. 2022/1288.

No significant harm to the sustainable investment objective

The investments of the financial product are made taking into account corresponding sustainability factors, which are regularly reviewed and evaluated by the capital management company.

With regard to the main adverse impacts on the sustainability factors, the focus is primarily on the indicators listed in Table 2 of Annex I of Delegated Regulation (EU) 2022/1288, here the categories (1) greenhouse gas emissions, (2) biodiversity, (3) water, (4) waste and (5) social and employment. In addition, indicators set out in Table 2 of Annex I to Delegated Regulation (EU) 2022/1288 – Emissions and in Table 3 of Annex I to Delegated Regulation (EU) 2022/1288 – Combating corruption and bribery (together “the PAI indicators”) are used.

The factors are reviewed prior to the acquisition of an investment object and form part of the corresponding acquisition due diligence. The investment objects are continuously monitored over the investment period and the achievement of the set investment targets is reviewed.

By operating the plants, we achieve a reduction in CO2e emissions compared to the operation of conventional, fossil-based power generation sources (including coal and gas). In this respect, renewable energies are an essential element in the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the sustainable development goals to ensure the long-term competitiveness of the European Union’s economy. Renewable energy contributes directly to the reduction of CO2 emissions by acting as a substitute for conventional sources of electricity generation, such as gas and coal-fired power plants.

It is true that the production of individual components and the construction of state-of-the-art wind and PV systems also necessarily cause greenhouse gas emissions. However, the reduction in greenhouse gas emissions through the operation of the renewable energy plants significantly exceeds the emissions caused during production and construction. In this respect, the greenhouse gas emissions caused do not restrict the achievement of the sustainable investment objective of the financial product.

The financial product has defined a minimum proportion of sustainable investments in accordance with Regulation (EU) 2020/852 of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investments (“Taxonomy Regulation”). The aforementioned investments are consistent with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the fundamental principles and rights from the eight core conventions set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights.

The above information is provided in accordance with Article 37 in conjunction with Article 39 of Regulation (EU) 2022/1288.

Sustainable investment objective of the financial product

The investments of the financial product make a significant contribution to climate protection by investing in plants for the generation of electricity from renewable energies and the associated infrastructure (“renewable energies”). Renewable energies are an essential element in the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the Sustainable Development Goals to ensure the long-term competitiveness of the European Union’s economy. Renewable energy contributes directly to the reduction of CO2 emissions by acting as a substitute for conventional sources of electricity generation, such as gas and coal-fired power plants. By generating electricity from renewable energies, the increasing demand for electricity can be met in a climate-friendly manner. In this context, renewable energies represent a sustainable investment within the meaning of Article 2 No. 17 of Regulation (EU) 2019/2088.

The above information is provided in accordance with Article 37 in conjunction with Article 40 of Regulation (EU) 2022/1288.

Investment strategy

Financial product I aims to achieve a long-term stable investment portfolio through a balanced diversification of renewable energy installations (as defined below) in relation to individual energy generation technologies and possible investment locations and regions. The financial product invests in renewable energy plants. The investment focus is on onshore wind energy and solar energy plants.

Renewable energy installations refers to one or more installations for the generation of electricity and/or heat by converting onshore wind and/or solar energy into electricity and any associated utilization and/or usage rights as well as infrastructure installations and facilities associated with such installations, e.g. for the conversion and transport of electricity as well as supply installations for such installations. The financial product does not make any other investments, with the exception of those that serve ongoing liquidity management.

The above information is provided in accordance with Article 37 in conjunction with Article 41 of Regulation (EU) 2022/1288.

Proportion of investments

The assets of the financial product are invested exclusively in assets in the renewable energy sector, in this case onshore wind energy and solar energy plants. In addition, the funds of the financial product are invested exclusively and to a limited extent for liquidity management and hedging purposes.

The relevant investment criteria apply as described in the issue document of the financial product. In accordance with the investment strategy, at least 75% of the assets are to be invested in the Sustainable – Ecological – Taxonomy-compliant category.

The above information is provided in accordance with Article 37 in conjunction with Article 42 of Regulation (EU) 2022/1288.

Monitoring of sustainable investment objective

The financial product’s sustainable investment objective is monitored through the ongoing determination of corresponding sustainability indicators. The following sustainability indicators are used to measure the achievement of the financial product’s sustainable investment objectives:

• CO2e avoidance: CO2 emission savings through the operation of renewable energies compared to the operation of conventional, fossil-fueled power generation sources (including coal and gas)
• Sustainable electricity production: Amount of electricity production from renewable energies
• Sustainably allocated capital: Amount of investment in renewable energy infrastructure
• Preservation of biodiversity and ecosystems: Compliance with environmental regulations and regulations during the construction, operation, and utilization of the facilities
• Avoidance of significant adverse environmental impacts: Review of potential negative environmental impacts (so-called principal adverse impact indicators)

Furthermore, high standards are applied to acquisition, management, and disposal with regard to respect for human rights, the fight against corruption and money laundering, ensuring occupational and operational safety, compliance with national and international labor standards, and sustainable and responsible corporate governance. In this context, CYCAP maintains a comprehensive organizational structure and a dedicated framework consisting of company-wide guidelines, principles, and processes to integrate and consider the aforementioned ESG criteria in our business activities and as asset managers of the renewable energy projects we manage. In this context, it should be noted that the assets – wind and solar power plants and the associated infrastructure – are essentially project companies that do not employ their own personnel and are managed by CYCAP.

The above information is provided in accordance with Article 37 in conjunction with Article 43 of Regulation (EU) 2022/1288.

Methodologies

The main measurement criterion is the determination of CO2e avoidance through the operation of renewable energy plants compared to the operation of conventional, fossil-based electricity generation sources. In this context, the amount of electricity produced is determined for each investment object. Using corresponding emission factors, the avoided greenhouse gas emissions (as CO2- equivalents) are then calculated as well as the existing greenhouse gas emissions according to Scope 1, Scope 2 and Scope 3 as defined by the Greenhouse Gas Protocol.

Emissions from investments are determined using data from public sources, such as the German Federal Environment Agency and Fraunhofer ISE, as well as production data from CYCAP’s wind and PV portfolio. In line with the methodological principles of life cycle analysis, both the direct emissions caused by the conversion of primary energy sources, e.g. the combustion of fossil or biogenic fuels, and the indirect emissions generated outside the conversion processes in the so-called upstream chains, e.g. in the manufacture of energy conversion plants or the extraction and provision of primary and secondary energy sources, are taken into account. In addition, emissions from externally sourced auxiliary energy that are directly linked to the generation path are also taken into account.

The above information is provided in accordance with Article 37 in conjunction with Article 44 of Regulation (EU) 2022/1288.

Data sources and processing

In the aforementioned methods for determining CO2e avoidance or CO2e emissions, third-party data is used in addition to our own data. In addition, comparative or estimated values are used in the event of missing or incomplete data. In this respect, the data sources and methods used are subject to uncertainties and may also be subject to change in the future.

The proportion of data based on estimated values, comparative values or third-party sources and thus subject to uncertainties amounts to a non-negligible share for the reporting year 2025, which is estimated at less than 5% for the reporting year 2025. This proportion relates in particular to the emission factors for Scope 3 emissions as well as certain technology-specific life cycle data based on studies by the Federal Environment Agency and the Fraunhofer ISE. Own production data of the wind and PV plants (electricity volumes) are not subject to any material uncertainties and are taken directly from the operational data of the plants.

The above information is provided in accordance with Article 37 in conjunction with Article 45 of Regulation (EU) 2022/1288.

Limitations to methodologies and data

The third-party data used to determine sustainability indicators may be subject to limitations regarding their availability (e.g., due to a reduction in update frequency), their usability for each specific case (e.g., in the case of only partial coverage with regard to individual technologies), their methodological completeness (e.g., due to missing, incorrect, or insufficient data sources), and their accuracy (e.g., in the case of methodological errors). Nevertheless, it should be noted that the third-party providers currently used are recognized and reputable institutes, and the studies and analyses used are generally regularly updated and further developed. Likewise, this primarily concerns data that usually only needs to be updated annually or, in individual cases, can be used over longer periods to determine sustainability indicators. Furthermore, data from wind and PV plants can be accessed directly in many places.

The above information is provided in accordance with Article 37 in conjunction with Article 46 of Regulation (EU) 2022/1288.

Due diligence

When acquiring assets, the investment decisions will include a review of the extent to which the investment is in line with the AIF’s investment criteria and whether the relevant minimum protection requirements pursuant to Article 18 of the Taxonomy Regulation are met; i.e., to the extent that no significant impairments pursuant to Article 2(17) of Regulation (EU) 2019/2088 are identified. Throughout the holding period, ongoing monitoring of the investment assets is carried out.

The above information is provided in accordance with Article 37 in conjunction with Article 47 of Regulation (EU) 2022/1288.

Engagement policies

A corresponding engagement policy is not part of the sustainable investment objective. Accordingly, no separate engagement policy has been formulated.

The above information is provided in accordance with Article 37 in conjunction with Article 48 of Regulation (EU) 2022/1288.

Attainment of the sustainable investment objective

No EU reference value is used to measure the sustainable investment objective. Renewable energy plants – in this case wind and solar power plants and the associated infrastructure – have a comparatively small and immaterial carbon footprint during their construction and ongoing operation. They produce electricity from non-fossil, sustainable energy sources (wind and solar), so that a corresponding expansion and operation of such plants leads to a corresponding CO2e avoidance compared to conventional power plants that rely on fossil fuels. In this respect, renewable energies are a direct substitute for otherwise climate-damaging conventional power plants. The investment goal of CO2 avoidance can be determined and measured directly via corresponding CO2e factors.

The above information is provided in accordance with Article 37 in conjunction with Article 49 of Regulation (EU) 2022/1288.

Annual reports in accordance with Art. 11 of Regulation (EU) 2019/2088

Retrieval of the regular reports (including the annual reports) via the investor portal at https://cycap.odoo.com/de/web/login

Name of the financial product: CEE Renewable Fund 8 S.C.S, SICAV-RAIF (“CEE RF8”)

Status of the information: December 31, 2025 (Last updated on April 21, 2026)

Information on the way in which sustainability risks are included in investment decisions and the results of the assessment of the expected impact of sustainability risks on the return of the financial product.

To ensure that the investments do not result in significant harm to one or more of the environmental objectives set out in Article 9 of the Taxonomy Regulation, the criteria set out in Section 4.1 and Section 4.3 of Annex I to Delegated Regulation (EU) 2021/2139 to the Taxonomy Regulation are observed and implemented and indicators for adverse impacts on sustainability factors are taken into account.

The financial product invests in renewable energy plants. The investment focus is on onshore wind energy and solar energy plants. Renewable energy plants refers to one or more plants for the generation of electricity and/or heat through the conversion of onshore wind and/or solar energy into electricity and any associated utilization and/or usage rights as well as infrastructure plants and facilities associated with such plants, e.g. for the conversion and transport of electricity as well as supply plants for such plants. The investment spectrum is accordingly limited to this area, i.e. the acquisition of assets from other, potentially critical asset classes is not part of the investment objective.

Summary

As a sustainable investment objective, this financial product pursues a significant contribution to climate protection through investments in renewable energy generation facilities and associated infrastructure. These investments represent a key element in the transition to a low-carbon, more sustainable, resource-efficient circular economy and directly contribute to reducing CO2 emissions by acting as a substitute for conventional electricity generation sources.

The investment strategy aims for a long-term stable portfolio through balanced diversification of renewable energy facilities, with an investment focus on onshore wind and solar power plants. At least 75% of the assets are invested in the “Sustainable – Ecological – Taxonomy-Compliant” category.

The sustainable investment objective is monitored through the continuous determination of sustainability indicators such as CO2e avoidance, sustainable electricity production, sustainably allocated capital, preservation of biodiversity and ecosystems, and the avoidance of significant negative environmental impacts. In addition, high standards are set with regard to human rights, anti-corruption, occupational and operational safety, and responsible corporate governance.

The main measurement criterion is the determination of CO2e emissions avoided compared to conventional, fossil-fuel-based power generation sources. The data for this purpose comes from public sources as well as the company’s own production data. The methodology considers both direct and indirect emissions according to the principles of life cycle analysis.

Investment decisions are reviewed to ensure that the investments comply with the investment criteria and the relevant minimum protection requirements pursuant to Article 18 of the Taxonomy Regulation are met. A specific participation policy is not part of the sustainable investment objective.

Achievement of the investment objective is not measured using an EU reference value, but is determined directly using CO2e factors, as renewable energies are a direct substitute for climate-damaging conventional power plants.

The above information is provided in accordance with Article 37 in conjunction with Article 38 of Regulation (EU) 2022/1288.

No significant harm to the sustainable investment objective

The investments of the financial product are made taking into account corresponding sustainability factors, which are regularly reviewed and evaluated by the capital management company.

With regard to the main adverse impacts on the sustainability factors, the focus is primarily on the indicators listed in Table 2 of Annex I of Delegated Regulation (EU) 2022/1288, here the categories (1) greenhouse gas emissions, (2) biodiversity, (3) water, (4) waste and (5) social and employment. In addition, indicators set out in Table 2 of Annex I to Delegated Regulation (EU) 2022/1288 – Emissions and in Table 3 of Annex I to Delegated Regulation (EU) 2022/1288 – Combating corruption and bribery (together “the PAI indicators”) are used.

The factors are reviewed prior to the acquisition of an investment object and form part of the corresponding acquisition due diligence. The investment objects are continuously monitored over the investment period and the achievement of the set investment targets is reviewed.

By operating the plants, we achieve a reduction in CO2e emissions compared to the operation of conventional, fossil-based power generation sources (including coal and gas). In this respect, renewable energies are an essential element in the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the sustainable development goals to ensure the long-term competitiveness of the European Union’s economy. Renewable energy contributes directly to the reduction of CO2 emissions by acting as a substitute for conventional sources of electricity generation, such as gas and coal-fired power plants.

It is true that the production of individual components and the construction of state-of-the-art wind and PV systems also necessarily cause greenhouse gas emissions. However, the reduction in greenhouse gas emissions through the operation of the renewable energy plants significantly exceeds the emissions caused during production and construction. In this respect, the greenhouse gas emissions caused do not restrict the achievement of the sustainable investment objective of the financial product.

The financial product has defined a minimum proportion of sustainable investments in accordance with Regulation (EU) 2020/852 of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investments (“Taxonomy Regulation”). The aforementioned investments are consistent with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the fundamental principles and rights from the eight core conventions set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights.

The above information is provided in accordance with Article 37 in conjunction with Article 39 of Regulation (EU) 2022/1288.

Sustainable investment objective of the financial product

The investments of the financial product make a significant contribution to climate protection by investing in plants for the generation of electricity from renewable energies and the associated infrastructure (“renewable energies”). Renewable energies are an essential element in the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the Sustainable Development Goals to ensure the long-term competitiveness of the European Union’s economy. Renewable energy contributes directly to the reduction of CO2 emissions by acting as a substitute for conventional sources of electricity generation, such as gas and coal-fired power plants. By generating electricity from renewable energies, the increasing demand for electricity can be met in a climate-friendly manner. In this context, renewable energies represent a sustainable investment within the meaning of Article 2 No. 17 of Regulation (EU) 2019/2088.

The above information is provided in accordance with Article 37 in conjunction with Article 40 of Regulation (EU) 2022/1288.

Investment strategy

Financial product I aims to achieve a long-term stable investment portfolio through a balanced diversification of renewable energy installations (as defined below) in relation to individual energy generation technologies and possible investment locations and regions. The financial product invests in renewable energy plants. The investment focus is on onshore wind energy and solar energy plants.

Renewable energy installations refers to one or more installations for the generation of electricity and/or heat by converting onshore wind and/or solar energy into electricity and any associated utilization and/or usage rights as well as infrastructure installations and facilities associated with such installations, e.g. for the conversion and transport of electricity as well as supply installations for such installations. The financial product does not make any other investments, with the exception of those that serve ongoing liquidity management.

As part of the investment strategy, it is ensured that the companies invested in apply good governance practices. The assessment is based on the following criteria: (i) sound management structures, (ii) appropriate relations with employees, (iii) market-conforming remuneration, and (iv) compliance with tax regulations. The invested companies are generally special purpose vehicles for the management of the renewable energy installations or the infrastructure installations and facilities associated with such installations. The companies do not have their own employees. CYCAP has company-wide standards and regulations in place to ensure compliance with the aforementioned frameworks, standards and principles.

The review of these criteria is part of the acquisition due diligence. Throughout the holding period, compliance with these principles is ensured through the regular review of annual financial statements as well as the monitoring of the tax reporting obligations of the portfolio companies.

The above information is provided in accordance with Article 37 in conjunction with Article 41 of Regulation (EU) 2022/1288.

Proportion of investments

The assets of the financial product are invested exclusively in assets in the renewable energy sector, in this case onshore wind energy and solar energy plants. In addition, the funds of the financial product are invested exclusively and to a limited extent for liquidity management and hedging purposes.

The relevant investment criteria apply as described in the issue document of the financial product. In accordance with the investment strategy, at least 75% of the assets are to be invested in the Sustainable – Ecological – Taxonomy-compliant category.

The above information is provided in accordance with Article 37 in conjunction with Article 42 of Regulation (EU) 2022/1288.

Monitoring of sustainable investment objective

The financial product’s sustainable investment objective is monitored through the ongoing determination of corresponding sustainability indicators. The following sustainability indicators are used to measure the achievement of the financial product’s sustainable investment objectives:

• CO2e avoidance: CO2 emission savings through the operation of renewable energies compared to the operation of conventional, fossil-fueled power generation sources (including coal and gas)
• Sustainable electricity production: Amount of electricity production from renewable energies
• Sustainably allocated capital: Amount of investment in renewable energy infrastructure
• Preservation of biodiversity and ecosystems: Compliance with environmental regulations and regulations during the construction, operation, and utilization of the facilities
• Avoidance of significant adverse environmental impacts: Review of potential negative environmental impacts (so-called principal adverse impact indicators)

Furthermore, high standards are applied to acquisition, management, and disposal with regard to respect for human rights, the fight against corruption and money laundering, ensuring occupational and operational safety, compliance with national and international labor standards, and sustainable and responsible corporate governance. In this context, CYCAP maintains a comprehensive organizational structure and a dedicated framework consisting of company-wide guidelines, principles, and processes to integrate and consider the aforementioned ESG criteria in our business activities and as asset managers of the renewable energy projects we manage. In this context, it should be noted that the assets – wind and solar power plants and the associated infrastructure – are essentially project companies that do not employ their own personnel and are managed by CYCAP.

The above information is provided in accordance with Article 37 in conjunction with Article 43 of Regulation (EU) 2022/1288.

Methodologies

The main measurement criterion is the determination of CO2e avoidance through the operation of renewable energy plants compared to the operation of conventional, fossil-based electricity generation sources. In this context, the amount of electricity produced is determined for each investment object. Using corresponding emission factors, the avoided greenhouse gas emissions (as CO2- equivalents) are then calculated as well as the existing greenhouse gas emissions according to Scope 1, Scope 2 and Scope 3 as defined by the Greenhouse Gas Protocol.

Emissions from investments are determined using data from public sources, such as the German Federal Environment Agency and Fraunhofer ISE, as well as production data from CYCAP’s wind and PV portfolio. In line with the methodological principles of life cycle analysis, both the direct emissions caused by the conversion of primary energy sources, e.g. the combustion of fossil or biogenic fuels, and the indirect emissions generated outside the conversion processes in the so-called upstream chains, e.g. in the manufacture of energy conversion plants or the extraction and provision of primary and secondary energy sources, are taken into account. In addition, emissions from externally sourced auxiliary energy that are directly linked to the generation path are also taken into account.

The above information is provided in accordance with Article 37 in conjunction with Article 44 of Regulation (EU) 2022/1288.

Data sources and processing

In the aforementioned methods for determining CO2e avoidance or CO2e emissions, third-party data is used in addition to our own data. In addition, comparative or estimated values are used in the event of missing or incomplete data. In this respect, the data sources and methods used are subject to uncertainties and may also be subject to change in the future.

The proportion of data based on estimated values, comparative values or third-party sources and thus subject to uncertainties amounts to a non-negligible share for the reporting year 2025, which is estimated at less than 5% for the reporting year 2025. This proportion relates in particular to the emission factors for Scope 3 emissions as well as certain technology-specific life cycle data based on studies by the Federal Environment Agency and the Fraunhofer ISE. Own production data of the wind and PV plants (electricity volumes) are not subject to any material uncertainties and are taken directly from the operational data of the plants.

The above information is provided in accordance with Article 37 in conjunction with Article 45 of Regulation (EU) 2022/1288.

Limitations to methodologies and data

The third-party data used to determine sustainability indicators may be subject to limitations regarding their availability (e.g., due to a reduction in update frequency), their usability for each specific case (e.g., in the case of only partial coverage with regard to individual technologies), their methodological completeness (e.g., due to missing, incorrect, or insufficient data sources), and their accuracy (e.g., in the case of methodological errors). Nevertheless, it should be noted that the third-party providers currently used are recognized and reputable institutes, and the studies and analyses used are generally regularly updated and further developed. Likewise, this primarily concerns data that usually only needs to be updated annually or, in individual cases, can be used over longer periods to determine sustainability indicators. Furthermore, data from wind and PV plants can be accessed directly in many places.

The above information is provided in accordance with Article 37 in conjunction with Article 46 of Regulation (EU) 2022/1288.

Due diligence

When acquiring assets, the investment decisions will include a review of the extent to which the investment is in line with the AIF’s investment criteria and whether the relevant minimum protection requirements pursuant to Article 18 of the Taxonomy Regulation are met; i.e., to the extent that no significant impairments pursuant to Article 2(17) of Regulation (EU) 2019/2088 are identified. Throughout the holding period, ongoing monitoring of the investment assets is carried out.

The above information is provided in accordance with Article 37 in conjunction with Article 47 of Regulation (EU) 2022/1288.

Engagement policies

A corresponding engagement policy is not part of the sustainable investment objective. Accordingly, no separate engagement policy has been formulated.

The above information is provided in accordance with Article 37 in conjunction with Article 48 of Regulation (EU) 2022/1288.

Attainment of the sustainable investment objective

No EU reference value is used to measure the sustainable investment objective. Renewable energy plants – in this case wind and solar power plants and the associated infrastructure – have a comparatively small and immaterial carbon footprint during their construction and ongoing operation. They produce electricity from non-fossil, sustainable energy sources (wind and solar), so that a corresponding expansion and operation of such plants leads to a corresponding CO2e avoidance compared to conventional power plants that rely on fossil fuels. In this respect, renewable energies are a direct substitute for otherwise climate-damaging conventional power plants. The investment goal of CO2 avoidance can be determined and measured directly via corresponding CO2e factors.

The above information is provided in accordance with Article 37 in conjunction with Article 49 of Regulation (EU) 2022/1288.

Annual reports in accordance with Art. 11 of Regulation (EU) 2019/2088 Retrieval of the regular reports (including the annual reports) via the investor portal at https://cycap.odoo.com/de/web/login

Name of the financial product: CEE Renewable Fund 9 S.A., SICAV-RAIF (“CEE RF9”)

Status of the information: December 31, 2025 (Last updated on April 21, 2026)

Information on the way in which sustainability risks are taken into account in investment decisions and the results of the assessment of the expected impact of sustainability risks on the return of the financial product.

In order to ensure that the financial product’s investments in renewable energies or renewable energy installations do not lead to a significant impairment of one or more environmental of Article 9 of the EU Taxonomy,objectives of the EU Taxonomy, the criteria for “avoidance of significant impairments” specified in Annex I, Section 4.1 (photovoltaic technology) and Section 4.3 (wind power) of the Climate Delegated Act to the Taxonomy Regulation are observed and implemented and indicators for adverse impacts on sustainability factors are taken into account. The same criteria are applied to all renewable energy installations of the financial product (onshore wind energy and solar energy installations) (Annex I, Section 4.3 of the Climate Delegated Act only provides for additional requirements for offshore wind installations).

The financial product invests in renewable energy plants. The investment focus is on onshore wind energy and solar energy plants. The investment spectrum is accordingly limited to this area, i.e. the acquisition of assets from other, potentially critical asset classes is not part of the investment objective.

Summary

The financial product pursues a sustainable investment objective of making a significant contribution to climate protection through investments in an existing portfolio of renewable energy plants, consisting of onshore wind and solar power plants. The financial product aims to achieve a portfolio-wide repowering of 29 projects (18 PV and 11 wind project companies) in order to optimize the existing portfolio and operate it long-term.

The renewable energy plants represent a key element in the transition to a low-carbon, more sustainable, resource-efficient circular economy and contribute directly to reducing CO2 emissions by acting as a substitute for conventional power generation sources. Project development within the framework of the repowering will achieve a significant increase in the performance of the existing plants (land densification) without significant additional land consumption.

In accordance with the investment strategy, at least 75% of the assets are invested in the “Sustainable – Ecological – Taxonomy-Compliant” category. In addition, the funds of the financial product are invested exclusively and to a limited extent for liquidity management and hedging.

The sustainable investment objective is monitored through the continuous determination of sustainability indicators such as CO2e avoidance, sustainable electricity production and sustainably allocated capital. In addition, high standards are applied regarding human rights, anti-corruption, occupational and operational safety, and responsible corporate governance.

The main measurement criterion is the determination of CO2e emissions avoided compared to conventional, fossil-fuel-based power generation sources. The data for this purpose comes from public sources as well as the company’s own production data. The methodology considers both direct and indirect emissions according to the principles of life cycle analysis.

Investment decisions are reviewed to ensure that the investments comply with the investment criteria and the relevant minimum protection requirements pursuant to Article 18 of the Taxonomy Regulation are met. A specific participation policy is not part of the sustainable investment objective.

The achievement of the investment objective is not measured using an EU reference value, but is determined directly using CO2e factors, as renewable energies are a direct substitute for climate-damaging conventional power plants. Repowering significantly increases the efficiency of existing plants and thus makes an additional contribution to CO2e emissions avoidance.

No significant harm to the sustainable investment objective

The investments of the financial product are made taking into account corresponding sustainability factors, which are regularly reviewed and evaluated by the capital management company.

With regard to the main adverse impacts on the sustainability factors, the focus is primarily on the indicators listed in Table 2 of Annex I of Delegated Regulation (EU) 2022/1288, here the categories (1) greenhouse gas emissions, (2) biodiversity, (3) water, (4) waste and (5) social and employment. In addition, indicators set out in Table 2 of Annex I to Delegated Regulation (EU) 2022/1288 – Emissions and in Table 3 of Annex I to Delegated Regulation (EU) 2022/1288 – Combating corruption and bribery (together “the PAI indicators”) are used.

The factors are reviewed prior to the acquisition of an investment object and form part of the corresponding acquisition due diligence. The investment objects are continuously monitored over the investment period and the achievement of the set investment targets is reviewed.

By operating the plants, we achieve a reduction in CO2e emissions compared to the operation of conventional, fossil-based power generation sources (including coal and gas). In this respect, renewable energies are an essential element in the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the sustainable development goals to ensure the long-term competitiveness of the European Union’s economy. Renewable energy contributes directly to the reduction of CO2 emissions by acting as a substitute for conventional sources of electricity generation, such as gas and coal-fired power plants.

It is true that the production of individual components and the construction of state-of-the-art wind and PV systems also necessarily cause greenhouse gas emissions. However, the reduction in greenhouse gas emissions through the operation of the renewable energy plants significantly exceeds the emissions caused during production and construction. In this respect, the greenhouse gas emissions caused do not restrict the achievement of the sustainable investment objective of the financial product.

The financial product has defined a minimum proportion of sustainable investments in accordance with Regulation (EU) 2020/852 of the European Parliament and of the Council on the establishment of a framework to facilitate sustainable investments (“Taxonomy Regulation”). The aforementioned investments are consistent with the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights, including the fundamental principles and rights from the eight core conventions set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights.

The above information is provided in accordance with Article 37 in conjunction with Article 39 of Regulation (EU) 2022/1288.

Sustainable investment objective of the financial product

The financial product has invested in an existing portfolio of renewable energy plants. The existing portfolio consists of onshore wind energy and solar energy plants. The financial product aims to repower 29 projects (18 PV and 11 wind project companies) across the portfolio in order to optimize the existing portfolio and operate it in the long term. The investments of the financial product make a significant contribution to climate protection by investing in plants for the generation of electricity from renewable energies and the associated infrastructure.

Renewable energy is an essential element in the transition to a low-carbon, more sustainable, resource-efficient circular economy in line with the Sustainable Development Goals to ensure the long-term competitiveness of the European Union’s economy. Renewable energy contributes directly to the reduction of CO2 emissions by acting as a substitute for conventional sources of electricity generation, such as gas and coal-fired power plants. By generating electricity from renewable energies, the increasing demand for electricity can be met in a climate-friendly manner. In this context, renewable energies represent a sustainable investment within the meaning of Article 2 No. 17 of Regulation (EU) 2019/2088.

The above information is provided in accordance with Article 37 in conjunction with Article 40 of Regulation (EU) 2022/1288.

Investment strategy

The financial product has invested in an existing portfolio of renewable energy plants. The existing portfolio consists of onshore wind energy and solar energy plants. The financial product aims to repower (“project development”) 29 projects (18 PV and 11 wind project companies) across the portfolio in order to optimize the existing portfolio and operate it in the long term.

Renewable energy installations means one or more installations for the generation of electricity and/or heat through the conversion of onshore wind and/or solar energy into electricity and any associated utilization and/or usage rights as well as infrastructure installations and facilities in connection with such installations , e.g. for the conversion and transport of electricity as well as supply installations for such installations

Project development in the context of repowering means that the output of existing renewable energy plants is significantly increased without using any additional land (land consolidation):

• With regard to solar energy systems, this is possible as modern modules require significantly less space for the same generation capacity. The space this frees up can be used for additional modules to increase the overall capacity of the renewable energy systems. Parts of the infrastructure can also continue to be used here.
• This is possible with regard to wind turbines, as modern turbines are considerably larger. Existing areas can continue to be used for the construction of new turbines. Individual elements of the local infrastructure can also continue to be used.

The financial product does not make any other investments, with the exception of those that serve ongoing liquidity management.

As part of the investment strategy, it is ensured that the companies invested in apply good governance practices. The assessment is based on the following criteria: (i) sound management structures, (ii) appropriate relations with employees, (iii) market-conforming remuneration, and (iv) compliance with tax regulations. The invested companies are generally special purpose vehicles for the management of the renewable energy installations or the infrastructure installations and facilities associated with such installations. The companies do not have their own employees. CYCAP has company-wide standards and regulations in place to ensure compliance with the aforementioned frameworks, standards and principles.

The review of these criteria is part of the acquisition due diligence. Throughout the holding period, compliance with these principles is ensured through the regular review of annual financial statements as well as the monitoring of the tax reporting obligations of the portfolio companies.

The above information is provided in accordance with Article 37 in conjunction with Article 41 of Regulation (EU) 2022/1288.

Proportion of investments

The assets of the financial product are invested exclusively in assets in the renewable energy sector, in this case onshore wind energy and solar energy plants. In addition, the funds of the financial product are invested exclusively and to a limited extent for liquidity management and hedging purposes.

The relevant investment criteria apply as described in the issue document of the financial product. In accordance with the investment strategy, at least 75% of the assets are to be invested in the Sustainable – Ecological – Taxonomy-compliant category.

The above information is provided in accordance with Article 37 in conjunction with Article 42 of Regulation (EU) 2022/1288.

Monitoring of sustainable investment objective

The financial product’s sustainable investment objective is monitored through the ongoing determination of corresponding sustainability indicators. The following sustainability indicators are used to measure the achievement of the financial product’s sustainable investment objectives:

• CO2e avoidance: CO2 emission savings through the operation of renewable energies compared to the operation of conventional, fossil-fueled power generation sources (including coal and gas)
• Sustainable electricity production: Amount of electricity production from renewable energies
• Sustainably allocated capital: Amount of investment in renewable energy infrastructure

The sustainability indicators are determined annually. The ESG department of CYCAP Capital Management GmbH is responsible for carrying out the monitoring. Should the review reveal that an indicator is not being achieved, appropriate measures will be initiated by the ESG department in coordination with fund management.

Furthermore, high standards are applied to acquisition, management, and disposal with regard to respect for human rights, the fight against corruption and money laundering, ensuring occupational and operational safety, compliance with national and international labor standards, and sustainable and responsible corporate governance. In this context, CYCAP maintains a comprehensive organizational structure and a dedicated framework consisting of company-wide guidelines, principles, and processes to integrate and consider the aforementioned ESG criteria in our business activities and as asset managers of the renewable energy projects we manage. In this context, it should be noted that the assets – wind and solar power plants and the associated infrastructure – are essentially project companies that do not employ their own personnel and are managed by CYCAP.

The above information is provided in accordance with Article 37 in conjunction with Article 43 of Regulation (EU) 2022/1288.

Methodologies

The main measurement criterion is the determination of CO2e avoidance through the operation of renewable energy plants compared to the operation of conventional, fossil-based electricity generation sources. In this context, the amount of electricity produced is determined for each investment object. Using corresponding emission factors, the avoided greenhouse gas emissions (as CO2- equivalents) are then calculated as well as the existing greenhouse gas emissions according to Scope 1, Scope 2 and Scope 3 as defined by the Greenhouse Gas Protocol.

Emissions from investments are determined using data from public sources, such as the German Federal Environment Agency and Fraunhofer ISE, as well as production data from CYCAP’s wind and PV portfolio. In line with the methodological principles of life cycle analysis, both the direct emissions caused by the conversion of primary energy sources, e.g. the combustion of fossil or biogenic fuels, and the indirect emissions generated outside the conversion processes in the so-called upstream chains, e.g. in the manufacture of energy conversion plants or the extraction and provision of primary and secondary energy sources, are taken into account. In addition, emissions from externally sourced auxiliary energy that are directly linked to the generation path are also taken into account.

The above information is provided in accordance with Article 37 in conjunction with Article 44 of Regulation (EU) 2022/1288.

Data sources and processing

In the aforementioned methods for determining CO2e avoidance or CO2e emissions, third-party data is used in addition to our own data. In addition, comparative or estimated values are used in the event of missing or incomplete data. In this respect, the data sources and methods used are subject to uncertainties and may also be subject to change in the future.

The proportion of data based on estimated values, comparative values or third-party sources and thus subject to uncertainties amounts to a non-negligible share for the reporting year 2025, which is estimated at less than 5% for the reporting year 2025. This proportion relates in particular to the emission factors for Scope 3 emissions as well as certain technology-specific life cycle data based on studies by the Federal Environment Agency and the Fraunhofer ISE. Own production data of the wind and PV plants (electricity volumes) are not subject to any material uncertainties and are taken directly from the operational data of the plants.

The above information is provided in accordance with Article 37 in conjunction with Article 45 of Regulation (EU) 2022/1288.

Limitations to methodologies and data

The third-party data used to determine sustainability indicators may be subject to limitations regarding their availability (e.g., due to a reduction in update frequency), their usability for each specific case (e.g., in the case of only partial coverage with regard to individual technologies), their methodological completeness (e.g., due to missing, incorrect, or insufficient data sources), and their accuracy (e.g., in the case of methodological errors). Nevertheless, it should be noted that the third-party providers currently used are recognized and reputable institutes, and the studies and analyses used are generally regularly updated and further developed. Likewise, this primarily concerns data that usually only needs to be updated annually or, in individual cases, can be used over longer periods to determine sustainability indicators. Furthermore, data from wind and PV plants can be accessed directly in many places.

The above information is provided in accordance with Article 37 in conjunction with Article 46 of Regulation (EU) 2022/1288.

Due diligence

When acquiring assets, the investment decisions will include a review of the extent to which the investment is in line with the AIF’s investment criteria and whether the relevant minimum protection requirements pursuant to Article 18 of the Taxonomy Regulation are met; i.e., to the extent that no significant impairments pursuant to Article 2(17) of Regulation (EU) 2019/2088 are identified. Throughout the holding period, ongoing monitoring of the investment assets is carried out.

The above information is provided in accordance with Article 37 in conjunction with Article 47 of Regulation (EU) 2022/1288.

Engagement policies

A corresponding engagement policy is not part of the sustainable investment objective. Accordingly, no separate engagement policy has been formulated.

The above information is provided in accordance with Article 37 in conjunction with Article 48 of Regulation (EU) 2022/1288.

Attainment of the sustainable investment objective

No EU reference value is used to measure the sustainable investment objective. Renewable energy plants – in this case wind and solar power plants and the associated infrastructure – have a comparatively small and immaterial carbon footprint during their construction and ongoing operation. They produce electricity from non-fossil, sustainable energy sources (wind and solar), so that a corresponding expansion and operation of such plants leads to a corresponding CO2e avoidance compared to conventional power plants that rely on fossil fuels. In this respect, renewable energies are a direct substitute for otherwise climate-damaging conventional power plants. The investment goal of CO2 avoidance can be determined and measured directly via corresponding CO2e factors.

The above information is provided in accordance with Article 37 in conjunction with Article 49 of Regulation (EU) 2022/1288.

Annual reports in accordance with Art. 11 of Regulation (EU) 2019/2088

Retrieval of the regular reports (including the annual reports) via the investor portal at https://cycap.odoo.com/de/web/login

Article 3

Date	Amendment
April 2022	Initial publication

Artikel 4

Date	Amendment
April 2022	Initial publication
December 2023	– Extension of the definition of sustainability risks – Adjustment regarding the technical regulatory standards (Delegated Regulation (EU) 2022/1288)
March 2025	Inclusion of additional information on combating corruption and bribery
May 2025	Omission of the information (here: PAI declaration) according to Art. 4 and Art. 7 of Regulation (EU) 2019/2088 in connection with the update of the PAI statement of the AIFM

Article 5

Date	Amendment
April 2022	Initial publication
July 2026	The compensation policy has been updated to include a reference to the AIFM Directive and the KAGB.

Article 6

Date	Amendment
April 2022	Initial publication
July 2026	The compensation policy has been updated to include a reference to the AIFM Directive and the KAGB.

Article 10

Date	Amendment
Juni 2024	Initial publication
March 2025	– Updates in relation to the CEE Renewable Fund 7 – First publication of information on the CEE Renewable Fund 8 – First publication of information on the CEE Renewable Fund 9
May 2025	– Updates in relation to the CEE Renewable Fund 7 – Updates in relation to the CEE Renewable Fund 8 – Updates in relation to the CEE Renewable Fund 9
April 2026	– Updates in relation to the CEE Renewable Fund 7 – Updates in relation to the CEE Renewable Fund 8 – Updates in relation to the CEE Renewable Fund 9

Article 11

Date	Amendment
June 2024	Initial publication
March 2025	Subsequent adjustment of the disclosures relating to the initial publications of CEE Renewable Fund 8 and CEE Renewable Fund 9