/sustainability-disclosures — Columbia Lake Partners

Last updated: October2026

March 2026

Columbia Lake Partners Sustainable Finance Disclosure Reporting (SFDR) Article 8
Product-level Website Disclosure

1. Summary

This sustainability‑related disclosure concerns Columbia Lake Partners Fund III (the “Fund”) and is prepared in accordance with Regulation (EU) 2019/2088 on sustainability‑related disclosures in the financial services sector (“SFDR”). It summarises how the Fund promotes environmental and social characteristics and how these are monitored and measured over time.

2. No sustainable investment objective

3. Environmental or social characteristics of the financial product

The environmental characteristics promoted by the Fund include:

Investing in companies that are committed to monitoring their environmental impact, including the reduction of greenhouse‑gas (GHG) emissions and improving energy efficiency.

The social characteristics promoted by the Fund include:

Investing in companies that uphold strong digital security and data protection standards, support employee wellbeing, and ensure safe and secure working conditions.

4. Investment strategy

The investment strategy integrates responsible business practices and E/S considerations throughout the investment lifecycle. In particular, the strategy:

Considers E/S factors as part of the investment analysis, due diligence and decision‑making through a defined responsible investment process.

Monitors sustainability risks and opportunities through regular engagement and the annual collection of defined E/S metrics, in order to track progress on risk mitigation and positive ESG outcomes.

5. Proportion of investments

The Fund does not have sustainable investment as its objective and does not intend to make investments in economic activities that qualify as environmentally sustainable under the EU Taxonomy. The Fund does not commit to a minimum proportion of investments that qualify as environmentally sustainable under Article 3 of the Taxonomy Regulation and therefore the minimum proportion of such investments is 0%.

6. Monitoring of environmental or social characteristics

To measure and monitor the attainment of the environmental and social characteristics promoted by the Fund, the Investment Manager applies a set of ESG topics and associated sustainability indicators across the portfolio. Throughout the investment cycle, the investee is required to complete the annual set of ESG metrics. The metrics set is a standardised set of six ESG requests that support the Investment Manager in monitoring each investee’s promotion of the Fund’s environmental and social characteristics.

7. Methodologies

i. ESG Due Diligence Methodology

The Investment Manager carries out a high-level ESG due‑diligence process pre‑investment to assess certain risks and review current ESG performance of each potential investee company. As part of this process, companies must provide information linked to the environmental and social characteristics promoted by the Fund. Where gaps are identified, the investment team agrees an action plan with management to enable reporting once in‑fund.

ii. Methodology to monitor environmental and social characteristics of the fund

The metrics set being used to monitor the environmental and social characteristics promoted by the fund comprises a selection of Environmental, Social, Governance (ESG) / Sustainability data informed by industry best practice.

The process is annual and includes coordinating data submissions from each portfolio company, reviewing responses for completeness and consistency, and to identify potential anomalies, inconsistencies or gaps in data.

Performance will be assessed by comparing each company’s year-on-year progress, with any significant gaps or data changes identified and followed up through targeted engagement where necessary.

8. Data sources and processing

While the Investment Manager has a preference for reported data where available, issuer disclosures can be incomplete or inconsistent, which may necessitate the use of estimated data sourced from third‑party providers in certain instances.

9. Limitations to methodologies and data

As most companies globally are not yet legally required to report on a comprehensive set of ESG indicators (with some exceptions for EU‑based issuers), investors determine for themselves which ESG factors are material and what to disclose to their investors. As a result, ESG data quality and availability can vary significantly between companies.

10. Due diligence

The Investment Manager assesses sustainability risks through a high-level pre‑investment ESG due diligence process. This process is designed to identify ESG risks, evaluate the current ESG performance of the target company, and provide clear recommendations to enhance reporting and monitoring performance once in-fund.

11. Engagement policies

ESG metrics collection

The Fund Manager collects and monitors a set of ESG metrics for borrowers. This supports the identification and management of key ESG impacts and risks, enables tracking of progress over time and helps both investee companies and Columbia Lake Partners to prepare robust, transparent reporting based on higher‑quality data.

Escalation

The provision of requested ESG information is treated as a condition of responsible investment. Where issues arise, an escalation approach is applied on a case‑by‑case basis. If a portfolio company is unable or unwilling to provide the ESG information required to measure the environmental and social characteristics or cannot demonstrate good governance principles and practices, the investment team will support the company in implementing improvements.

12. Designated reference benchmark

No index has been designated as a reference benchmark for the purpose of attaining the environmental or social characteristics promoted by the Fund.

13. Principal Adverse Impacts (PAIs)

The Fund does not currently consider the principal adverse impacts (“PAIs”) of its investment decisions on sustainability factors at product level. This reflects current limitations in the availability, consistency and quality of data from portfolio companies, as well as the significant administrative burden associated with reporting across all mandatory indicators under the SFDR Regulatory Technical Standards (“RTS”).