EU SFDR disclosure

HarbourVest – SFDR website disclosures

The present statement contains, in particular, the disclosures which are required to be made on this website by HarbourVest Partners (Ireland) Limited (“HarbourVest Ireland”), as a “financial market participant”, in respect of the AIFs under its management (the “AIFs”) under the Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (the “Sustainability Disclosures Regulation” or “SFDR”

HarbourVest Ireland delegates the portfolio management of the AIFs to its affiliate, HarbourVest Partners LP (“HarbourVest”). HarbourVest is an independent, global private markets firm with over 43 years of experience and more than $146 billion in assets (as of 30 June 2025) under management and provides clients access to global primary funds, secondary transactions, direct co-investments, real assets and infrastructure, and private credit.

Transparency of sustainability risk policies at entity level

(article 3 of the Sustainability Disclosures Regulation)

HarbourVest, as the portfolio manager of the AIFs, views responsible investing, or the incorporation of sustainability and business conduct factors into investment and management decisions, as an important part of its business. HarbourVest has been a proud signatory to the Principles for Responsible Investment (PRI) since 2013 and strongly believes that sustainability risks can affect the performance of investment portfolios, to varying degrees, across companies, sectors, and time periods.

 As an institutional investor, HarbourVest’s commitment to sustainable investing is grounded in its conviction that the policies and processes of the managers that the AIFs invest with to manage sustainability risk can be an indicator for financial performance. HarbourVest has integrated sustainable investing procedures within each of its investment strategies to support sound investment decision-making, which is at the core of how it seeks to create compelling, risk-adjusted returns for investors.

 HarbourVest’s policy on the integration of sustainability risks in its investment decision making process can be found here.

Transparency of sustainability risk policies at entity level

(article 4 of the Sustainability Disclosures Regulation)

HarbourVest Ireland does not currently intend to publish a statement on its consideration of the adverse impacts of investment decisions on sustainability factors in the manner set out in article 4 of the SFDR. Whilst its affiliate HarbourVest integrates sustainability risks in its investment process, as a fund of fund manager making primary investments, secondary investments and minority non-control direct investments, it has limited control over and access to data from underlying fund managers and cannot provide the information in relation to its consideration of the adverse impacts of its investment decisions on sustainability factors in the manner set out in Commission Delegated Regulation (EU) 2022/1288 published by the European Commission on 6 April 2022. HarbourVest Ireland expects to keep this position under review by reference to applicable market developments and future availability of information.

Transparency of remuneration policies in relation to the integration of sustainability risks

(article 5 of the Sustainability Disclosures Regulation)

Both HarbourVest Ireland and HarbourVest require relevant individuals to adhere to their policies and processes regarding the integration of sustainable and business conduct. Specific metrics may be set for relevant individuals based on the priorities and objectives for that individual, as determined by their manager and functional leaders. In addition, HarbourVest considers its commitment to sustainable investing as material to investment performance over the long term and aligned with its remuneration structure which focuses on long term fund performance.

Disclosure in relation to AIFs that are subject to Article 8 or Article 9 of the Sustainability Disclosures Regulation

(link to disclosures required under article 10 of the Sustainability Disclosures Regulation)

HarbourVest Ireland publishes and maintains the information required under Article 10 of the Sustainability Disclosures Regulation for each of the AIFs in scope of Article 8 or Article 9 of the Sustainability Disclosures Regulation through the relevant Intralinks and Investor portals. Access to such Intralinks and investor portals is made available to certain potential and existing investors in the AIFs.

Date of last review: November 2025.

HarbourVest Partners, LLC is a registered investment adviser under the Investment Advisers Act of 1940. The information on this site is intended solely for the benefit of firms and companies seeking private equity investment capital by providing general information on our services and philosophy. The material on this site is for informational purposes only and does not constitute an offer or solicitation to purchase any investment solutions or a recommendation to buy or sell a security nor is it to be construed as legal, tax or investment advice. Unless otherwise indicated, any information available through this site is as of the date indicated therein and may not be updated or otherwise revised to reflect information that subsequently becomes available. HarbourVest is under no obligation to update the information contained on this site. Additionally, the material on this site does not constitute a representation that the solutions described therein are suitable or appropriate for any person and HarbourVest does not accept any liability with respect to the information. By using this site you agree to the Terms of Use.