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Sustainability Disclosures

Sustainability Disclosures (SFDR)

Regulation (EU) 2019/2088

Article 9 — Sustainable Investment Objective

Last updated: May 2026

01 · Fund Overview

Fund Overview & Classification

Anara Impact Capital (“the Fund”) is classified as an Article 9 fund under the Sustainable Finance Disclosure Regulation (SFDR), Regulation (EU) 2019/2088. This classification reflects the Fund’s commitment to making sustainable investments as its primary objective, in line with EU taxonomy-aligned and internationally recognised impact frameworks.

The Fund is domiciled in the Netherlands and managed by an external Alternative Investment Fund Manager (AIFM) authorised under the Alternative Investment Fund Managers Directive (AIFMD), Directive 2011/61/EU. All investments are made in accordance with the Fund’s investment strategy and the binding elements described in this disclosure.

Classification: Article 9 — Sustainable Investment Objective (SFDR). The Fund commits to making all of its investments in companies whose core business activities contribute to measurable social or environmental outcomes across learning, wellbeing and climate resilience.

02 · Sustainable Objective

Sustainable Investment Objective

The Fund’s primary objective is to generate measurable positive social and environmental impact for underserved populations in the MENA region and its diaspora, while delivering competitive risk-adjusted financial performance to its investors.

The Fund focuses on three thematic pillars that represent both an acute regional need and a compelling market opportunity:

Learning & Skills: Expanding access to quality education, vocational training and lifelong learning for underserved populations — particularly youth and women — in markets where the education sector remains largely undigitised.

Wellbeing: Empowering individuals to improve financial inclusion, mental health and physical wellbeing through scalable technology-enabled solutions across communities where formal health and financial infrastructure is limited.

Climate Resilience: Supporting startups that mitigate, adapt to, or reverse climate change in MENA — a region among the world’s most vulnerable to climate risk — addressing a significant and fast-growing market opportunity.

Each portfolio company must demonstrate that its core business model directly addresses one or more of these pillars as a primary activity, not as a secondary or ancillary consideration.

03 · Investment Strategy

Investment Strategy & ESG Integration

Anara employs a positive-screening and impact-first investment strategy. The Fund invests at the Seed and Series A stage, with capital reserved for follow-on, and targets a focused portfolio of companies.

Screening Criteria

All prospective investments undergo a dual-lens assessment: financial viability (market size, business model, team quality, path to scale) and impact integrity (theory of change, target beneficiary alignment, measurable outcome indicators). Investments failing either screen are excluded from consideration.

Binding Impact Conditions

The following conditions are binding at the time of investment and are embedded in the Fund’s legal subscription documents:

The investee’s core product or service must directly address learning, wellbeing or climate resilience outcomes.

A measurable impact thesis with defined indicators (KPIs) must be agreed at deal close and embedded in investment documentation.

The investee must agree to participate in the Fund’s annual impact reporting process throughout the holding period.

No investment shall be made in companies whose primary activities conflict with the SFDR’s list of activities inconsistent with sustainable investment (see Section 4).

ESG Integration in Investment Process

Environmental, social and governance (ESG) factors are integrated at every stage of the investment process:

Sourcing: Deal flow is actively sourced through impact-aligned networks including Alfanar Venture Philanthropy, regional accelerators and sector-specialist intermediaries.

Diligence: ESG due diligence is conducted alongside commercial due diligence. The Fund uses a proprietary Impact Scorecard covering: theory of change robustness, additionality, outcome evidence, stakeholder inclusion and governance maturity.

Structuring: Impact covenants, reporting obligations and material ESG disclosure requirements are embedded in term sheets and shareholder agreements.

Post-investment: The Fund actively supports portfolio companies in improving ESG practices, measurement frameworks and governance standards as part of ongoing value creation.

04 · Do No Significant Harm

Do No Significant Harm (DNSH)

In accordance with Article 2(17) SFDR, the Fund applies a Do No Significant Harm (DNSH) assessment to all investments. A sustainable investment must not significantly harm any other environmental or social objective.

The following categories of business activity are excluded from the Fund’s investable universe:

Production, distribution or sale of weapons, defence products or dual-use technologies

Fossil fuel extraction, refining or distribution (coal, oil, gas)

Tobacco manufacturing or distribution

Gambling, adult content or activities with demonstrable addictive harm profiles

Activities involving forced labour, child labour or exploitation of vulnerable populations

Businesses with primary activities causing deforestation, habitat destruction or biodiversity loss

Products or services that exacerbate financial exclusion or predatory lending

DNSH Process: A formal DNSH checklist is completed by the investment team for each prospective investment prior to Investment Committee review. Any investment flagging a potential harm requires a written mitigation rationale approved by the IC Chair before proceeding.

05 · Principal Adverse Impacts

Principal Adverse Impacts (PAI)

Anara Impact Capital considers Principal Adverse Impacts (PAI) on sustainability factors in its investment decision-making, in accordance with Article 4 SFDR and the Regulatory Technical Standards (RTS) developed by the Joint Committee of the European Supervisory Authorities (ESAs).

The Fund monitors mandatory PAI indicators to the extent data is available from portfolio companies at the early stage. Recognised data limitations for Seed/Series A-stage companies are acknowledged; the Fund actively works with portfolio companies to improve data quality over the holding period.

PAI Indicators Monitored

The Fund tracks the following indicators, reported annually in the Fund’s Impact Report:

GHG Emissions: Carbon footprint and GHG intensity of investee operations, where data is available or estimable.

Fossil Fuel Exposure: No Fund investments involve fossil fuel-related revenue streams (binding exclusion).

Social & Employee Matters: Board gender diversity, living wage compliance, workforce composition and labour standards.

Human Rights: Absence of operations in conflict-affected areas without due diligence protocols; supply chain oversight.

Anti-Corruption & Anti-Bribery: Presence of anti-corruption policies in portfolio companies, monitored annually.

Water & Biodiversity: Where relevant to investee operations (e.g. climate resilience and agricultural-tech companies).

A consolidated PAI Statement is published annually and made available to investors upon request.

06 · Governance

Governance & Due Diligence

Investment Committee

Investment decisions require approval from the Fund’s Investment Committee (IC), which includes members with expertise in impact investing, MENA markets and the Fund’s three thematic sectors. The IC reviews the impact scorecard alongside the investment memorandum for each proposed investment.

Impact Function

The Fund maintains a dedicated impact function responsible for designing impact frameworks, conducting impact due diligence, tracking portfolio-level outcomes and producing annual impact reports. The impact function operates independently of the deal team, with direct reporting to the managing partner.

Third-Party Oversight

The Fund’s impact framework and portfolio impact data are subject to periodic third-party review to ensure credibility, consistency and alignment with SFDR RTS requirements. Reviews are conducted by qualified independent parties with relevant impact measurement expertise.

Data & Methodology

Impact data is collected through standardised annual portfolio company surveys, aligned with established frameworks including IRIS+ (Impact Reporting and Investment Standards), the UN Sustainable Development Goals (SDGs) and the Operating Principles for Impact Management (OPIM). Where company-level data is unavailable, the Fund uses proxy indicators and discloses the methodology applied.

07 · Impact Monitoring

Impact Monitoring & Reporting

The Fund publishes an annual Impact Report covering:

Portfolio-level aggregated impact indicators (beneficiaries reached, outcomes delivered, environmental metrics)

Company-by-company impact highlights (with company consent)

Fund-level PAI statement

Progress against the Fund’s theory of change

Assessment of additionality and counterfactual considerations

Alignment with the UN SDGs, primarily SDG 3, 4, 7, 8, 10, 13 and 17

Investors receive the annual Impact Report alongside financial reporting. Summary impact data is published on the Fund’s website following each reporting period.

Impact Indicators (Examples): Number of learners reached (Learning) · Households accessing financial services (Wellbeing) · Tonnes of CO₂ avoided or sequestered (Climate) · Share of beneficiaries from low-income segments · Jobs created in target geographies.

08 · Engagement

Engagement Policy

As an active impact investor, Anara engages with portfolio companies beyond financial capital. The Fund’s value-creation model includes:

Board Representation: Anara seeks board or observer seats in portfolio companies to enable direct governance participation and impact accountability.

Impact Capacity Building: The Fund provides portfolio companies with frameworks, tools and advisory support to build their impact measurement capabilities over time.

Network Access: Portfolio companies benefit from the Alfanar network and Anara’s ecosystem of operators, advisors and co-investors across MENA and internationally.

Escalation Protocol: If a portfolio company materially fails to meet its impact commitments or breaches DNSH conditions, the Fund’s investment documentation provides escalation rights including accelerated reporting, board resolutions and, in extreme cases, exit provisions.

09 · Reference Benchmark

Reference Benchmark

The Fund does not designate a specific financial index as a reference benchmark. Impact performance is measured against the Fund’s defined theory of change and sector-specific outcome targets agreed at the time of investment, rather than against a financial index.

Financial performance is assessed against relevant private market benchmarks for the purposes of investor reporting, but these do not constitute SFDR reference benchmarks.

10 · Regulatory Information

Regulatory Information

Anara Impact Capital is managed by an external AIFM authorised under the AIFMD (Directive 2011/61/EU). The Fund is domiciled in the Netherlands. This document constitutes the pre-contractual disclosure required by Article 10 of SFDR and the associated Regulatory Technical Standards.

This disclosure is subject to annual review and will be updated to reflect any material changes to the Fund’s investment strategy, impact framework or applicable regulatory requirements.

AFM Disclaimer: Attention: This investment falls outside AFM supervision. No license required for this activity. This website and its contents are for informational purposes only and do not constitute an offer to buy or sell any security. Prospective investors should seek independent professional advice before making any investment decision.

Questions about our sustainability approach?

For investor queries about our SFDR disclosures, impact reporting, or investment strategy, please contact us directly.

hello@anaraimpact.com →

An early-stage impact fund investing in learning, wellbeing and climate resilience — built on two decades of regional conviction.

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Domiciled in the Netherlands · External AIFM under EU Directive 2011/61/EU

Anara is part of the broader efforts under the Social Entrepreneurship Fund (SEF) – a catalyst financing initiative for the social economy started by remarkable group of institutional investors such as BMZ and EU.

Attention: This investment falls outside AFM supervision. No license required for this activity. This website is for informational purposes only and does not constitute an offer to buy or sell any security. Prospective investors should consult their own professional advisers before any investment decision.

An early-stage impact fund investing in learning, wellbeing and climate resilience — built on two decades of regional conviction.

Explore

Engage

Careers

Compliance

Sustainability Disclosures (SFDR)

Grievance Mechanism & Feedback