Regulatory Information

This page brings together the legal and regulatory information relating to the funds of the Astanor platform and their respective management companies. Each section states the legal entity responsible for its content.

Astanor Growth funds — Ad-Asta Gestion France

This section concerns Ad-Asta Gestion France SAS, a portfolio management company (société de gestion de portefeuille) authorized by the Autorité des marchés financiers under number GP-20260002, and the funds it manages: Astanor Growth I SLP, Astanor Growth I SCSp and AG I SCA RAIF-SICAV.

Scope

This legal and regulatory information concerns Ad-Asta Gestion France SAS and the Astanor Growth funds it manages. Other funds referenced on this website are managed by other managers and are covered by their own separate disclosures: the Astanor venture capital funds (Good Harvest Ventures SCSp and Astanor Ventures II SCSp) have appointed Gen2 Management Company as their alternative investment fund manager, and the fully allocated legacy vehicles (including GHVI-S SCSp and GHVI-S2 SCSp) are managed by Astanor Co-Investment Platform GP S.à r.l. and Good Harvest Partners Management S.à r.l. under the sub-threshold registration regime of Article 3(2) of Directive 2011/61/EU. The disclosures relating to those funds are available in the dedicated sections of this website or on the relevant manager’s own website.

Publisher

This website section is published by Ad-Asta Gestion France SAS, a société par actions simplifiée with a share capital of EUR 1,881,000, whose registered office is at 2, rue de Laborde, 75008 Paris, France, registered with the Paris Trade and Companies Register under number 948 607 858. The director of publication (directeur de la publication) is Leslie Kapin.

Regulatory status

Ad-Asta Gestion France SAS is a portfolio management company (société de gestion de portefeuille) authorized by the Autorité des marchés financiers (AMF) under number GP-20260002 and acts as an alternative investment fund manager (AIFM) within the meaning of Directive 2011/61/EU.

Funds managed

To date, Ad-Asta Gestion France manages:

  • Astanor Growth I SLP,
  • Astanor Growth I SCSp,
  • AG I SCA RAIF-SICAV.

Personal data and hosting

This website is hosted by WP Engine, Inc., 504 Lavaca Street, Suite 1000, Austin, Texas 78701, United States (telephone: +1 512 273 3906, www.wpengine.com). Personal data is processed in accordance with the Astanor Group Fair Processing Policy, maintained by Astanor GP S.àr.l. and available on this website. For the processing carried out in connection with its own activities, Ad-Asta Gestion France SAS acts as data controller. Data subjects may exercise their rights of access, rectification, erasure and objection by writing to compliance@ad-asta-gestion.com, and have the right to lodge a complaint with the Commission nationale de l’informatique et des libertés (CNIL, www.cnil.fr).

These disclosures are made pursuant to Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR).

Integration of sustainability risks (Article 3)

Ad-Asta Gestion France integrates sustainability risks into its investment decision-making process in accordance with its Responsible Investment Framework, applying a principle of double materiality. A sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment. Sustainability risks are assessed as part of the pre-investment due diligence and monitored throughout the holding period. In accordance with Article L. 533-22-1 of the French Monetary and Financial Code, this policy covers the risks associated with climate change (both physical and transition risks) and the risks associated with biodiversity, which are of particular relevance to the sustainable agri-food value chain.

Principal adverse impacts (Article 4)

Ad-Asta Gestion France considers the principal adverse impacts (PAI) of its investment decisions on sustainability factors. Given the impact strategy of the funds managed, adverse-impact indicators are identified, measured and monitored through the Responsible Investment Framework and the funds’ impact methodology. The statement on principal adverse impacts of investment decisions on sustainability factors is published in a dedicated section of this website, in the format prescribed by Annex I of Commission Delegated Regulation (EU) 2022/1288, and is updated annually by 30 June in respect of the preceding calendar year.

Remuneration policy (Article 5)

The remuneration policy of Ad-Asta Gestion France is consistent with the integration of sustainability risks. It does not encourage risk-taking that would be inconsistent with the sustainability profile of the funds managed, and the long-term incentive arrangements (including carried interest) are aligned with the funds’ sustainable investment objective and impact performance. In accordance with Directive 2011/61/EU and the AMF General Regulation, the remuneration policy combines a fixed component, a variable component assessed against financial and non-financial criteria, including the ESG and impact objectives embedded in annual performance reviews, and long-term carried-interest arrangements. It is reviewed annually by senior management; further detail is provided in the funds’ annual reports and is available to investors on request.

Product-level disclosures (Article 10)

All funds managed by Ad-Asta Gestion France pursue a sustainable investment objective and are financial products within the meaning of Article 9 SFDR. Their pre-contractual sustainability disclosures (Annex III of Commission Delegated Regulation (EU) 2022/1288), each dated 30 September 2026, are published below: Astanor Growth I SLP (LEI 6367009YDOXZ2MCP8V26), Astanor Growth I SCSp (LEI 6367000709K591OTOH96) and AG I SCA RAIF-SICAV (LEI 636700TD7M7VNRRZQP69). The periodic sustainability disclosures (Annex V of the same Regulation) will be published together with the funds’ annual reports. The disclosures relating to the other funds of the Astanor platform (the venture capital funds managed by Gen2 Management Company and the legacy vehicles managed by Astanor Co-Investment Platform GP S.à r.l. and Good Harvest Partners Management S.à r.l.) are available in the dedicated sections of this website or from their respective managers.

Effective as of 30 September 2026, the date on which Ad-Asta Gestion France took over the management of the Astanor Growth funds. Last updated: 1 October 2026.

This policy is published pursuant to Articles L. 533-22 and R. 533-16 of the French Monetary and Financial Code, transposing Directive (EU) 2017/828 (SRD II).

Engagement

Ad-Asta Gestion France integrates shareholder engagement into its investment strategy. As a private-equity manager investing predominantly in unlisted companies, engagement is exercised principally through board representation, shareholders’ agreements and ongoing dialogue with portfolio companies. The Management Company monitors investee companies on their strategy, financial and non-financial performance, risks, capital structure, social and environmental impact and corporate governance.

Exercise of voting rights

Voting rights are exercised in the best interests of the funds and their investors, in accordance with the constitutive documents of the funds and the portfolio companies. Where the funds hold listed securities on an ancillary basis, voting is exercised consistently with the same principles.

Cooperation with other shareholders and communication with stakeholders

The Management Company cooperates with the other shareholders of its portfolio companies where doing so serves the best interests of the funds, in particular through shareholders’ agreements, participation in investor syndicates and coordinated dialogue with co-investors. It communicates with the relevant stakeholders of portfolio companies (including founders and management teams, co-investors and, where appropriate, employees, customers, lenders and local communities) principally through board representation, the ongoing dialogue described above and the annual impact and ESG reporting process.

Conflicts of interest and annual report

Conflicts of interest arising in connection with engagement or voting are managed under the Management Company’s conflicts-of-interest policy. In accordance with Article R. 533-16 of the French Monetary and Financial Code, the Management Company publishes on this website, on an annual basis, a report on the implementation of this policy, including a general description of voting behaviour and, where applicable, an explanation of the most significant votes and of any use of proxy advisers. As the funds invest almost exclusively in unlisted companies, certain items of the shareholder-engagement regime, which concerns shares admitted to trading on a regulated market, may not be applicable; where that is the case, the report says so, in accordance with the comply-or-explain mechanism provided by law.

Ad-Asta Gestion France handles complaints in accordance with AMF Instruction DOC-2012-07 and the AMF Position-Recommendation on the processing of complaints.

How to file a complaint

A complaint may be sent, free of charge, to: Ad-Asta Gestion France SAS, Compliance (RCCI), 2, rue de Laborde, 75008 Paris, France, or by e-mail to compliance@ad-asta-gestion.com.

Handling times

  • Acknowledgement of receipt within ten (10) business days of receipt of the complaint, unless a response is provided within that period;
  • Response provided within two (2) months of receipt of the complaint, save in duly justified exceptional circumstances.

AMF Mediator

If you are not satisfied with the response, you may refer the matter, free of charge, to the AMF Ombudsman (Médiateur de l’AMF): online at www.amf-france.org/mediateur, or by post to Autorité des marchés financiers, Le Médiateur, 17 place de la Bourse, 75082 Paris Cedex 02, France. Mediation before the AMF Ombudsman is governed by the AMF mediation charter (Charte de la médiation de l’AMF), available on the AMF website. Referral to the AMF Ombudsman does not deprive you of the right to bring the matter before the competent courts. Investors in funds managed by a member of France Invest may also have access to the France Invest mediation process.

Ad-Asta Gestion France identifies, prevents and manages conflicts of interest in accordance with the AMF General Regulation and its internal Company Rules (Chapter 1, Part B).

Governance

The RCCI (Head of Compliance and Internal Control) is responsible for the conflicts-of-interest framework, which comprises a conflicts-of-interest mapping, a conflicts-of-interest register, documented management measures and second-level review by an independent external firm (IQ EQ Consulting Services). Structural safeguards apply to any cumulation of functions.

Situations addressed

  • Allocation of investment opportunities between funds and co-investment vehicles;
  • Related-party transactions and transactions involving group entities;
  • Carried interest and personal-account dealing;
  • Relationships with service providers and delegates.

Disclosure

Where organisational and administrative arrangements are not sufficient to ensure, with reasonable confidence, that the risk of damage to investor interests will be prevented, the residual conflict is disclosed to the investors concerned before acting on their behalf. This summary is provided for information; the full policy is available on request from compliance@ad-asta-gestion.com.

Ad-Asta Gestion France reports on the consideration of environmental, social and governance criteria and of climate- and biodiversity-related risks pursuant to Article L. 533-22-1 of the French Monetary and Financial Code (Article 29 of the Energy-Climate Law and Decree No. 2021-663). As its assets under management are below EUR 500 million, the Management Company applies the simplified reporting regime.

Investment approach

The funds managed pursue a sustainable investment objective within the meaning of Article 9 SFDR: impact private equity in the sustainable agri-food value chain. The funds target a minimum of 60% of sustainable investments with an environmental objective and 20% with a social objective, apply the “Do No Significant Harm” principle under the EU Taxonomy Regulation, and observe the exclusions set out in the Responsible Investment Framework (including a coal exclusion).

Impact approach and indicators

The Management Company’s impact approach and its impact indicators (greenhouse gas emissions, biodiversity, water, social, health and impact intelligence), together with the annual impact reports, are set out on the Astanor impact page and in the Responsible Investment Framework, which form part of these disclosures.

Reporting

The impact page and impact reports referred to above are narrative disclosures; the structured regulatory report required under Article L. 533-22-1 (governance, means, ESG-risk integration, EU Taxonomy and fossil-fuel exposure, climate and biodiversity strategy) will be published on this website with the FY2026 annual reporting, together with the funds’ SFDR periodic sustainability disclosures.

Financial market participant: Ad-Asta Gestion France SAS (LEI: 636700U9RMD1F4E6QH05). Published pursuant to Article 4 of Regulation (EU) 2019/2088 (SFDR) and Annex I of Commission Delegated Regulation (EU) 2022/1288 (the “SFDR RTS”). Last updated: 1 October 2026.

Summary

Ad-Asta Gestion France SAS (LEI 636700U9RMD1F4E6QH05) considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated statement on principal adverse impacts on sustainability factors of Ad-Asta Gestion France SAS. This statement on principal adverse impacts on sustainability factors covers the reference period from 1 January 2026 to 31 December 2026. Ad-Asta Gestion France was authorized by the AMF in 2026 and took over the management of the Astanor Growth funds on 30 September 2026; principal adverse impacts are accordingly considered from that date.

As at the date of this statement, the first reference period is in progress and the funds’ portfolio-company data for that period has not yet been collected. The quantitative summary of the principal adverse impacts identified over the reference period, and of the actions taken and planned, will be published by 30 June 2027 in respect of the 2026 reference period and updated annually thereafter.

Résumé : Ad-Asta Gestion France SAS (LEI 636700U9RMD1F4E6QH05) prend en considération les principales incidences négatives de ses décisions d’investissement sur les facteurs de durabilité. La présente déclaration est la déclaration consolidée d’Ad-Asta Gestion France SAS à cet égard et couvre la période de référence du 1er janvier 2026 au 31 décembre 2026. Ad-Asta Gestion France a repris la gestion des fonds Astanor Growth le 30 septembre 2026 ; les données quantitatives relatives aux indicateurs d’incidences négatives seront publiées au plus tard le 30 juin 2027 au titre de la période de référence 2026, puis mises à jour chaque année.

Description of the principal adverse impacts on sustainability factors

The Management Company considers the fourteen mandatory indicators set out in Table 1 of Annex I of the SFDR RTS and, where data is available and material to the agri-food sector, selected additional indicators from Tables 2 and 3 of Annex I. The completed Table 1 of Annex I (adverse sustainability indicators, metrics, impact for the reference period, explanations, and actions taken and planned) will be published by 30 June 2027 in respect of the 2026 reference period. In addition to the fourteen mandatory indicators of Table 1, the Management Company has selected the following additional indicators: “Investments in companies producing chemicals” (Table 2 of Annex I) and “Lack of a supplier code of conduct” (Table 3 of Annex I).

Indicator data is collected through the annual ESG questionnaire completed by portfolio companies (via the Sweep platform) and through direct engagement with portfolio companies. Where portfolio-company data is unavailable, the Management Company uses best available proxies, estimates or sector averages, which are disclosed as such.

Description of policies to identify and prioritise principal adverse impacts on sustainability factors

The policies used to identify and prioritise principal adverse impacts are set out in the Management Company’s Sustainability and ESG Risk Policy and in the Responsible Investment Framework, initially approved by Astanor’s Managing Partners in 2021, most recently updated in August 2025 and adopted by the senior management of Ad-Asta Gestion France with effect from 1 October 2026. The RCCI is responsible for their implementation, with input from the portfolio managers. Principal adverse impacts are identified and assessed on the basis of the SFDR RTS indicators, applying a materiality approach that takes into account the probability of occurrence, the severity and the potentially irremediable character of each impact within the sustainable agri-food value chain. Data sources comprise the annual ESG questionnaire, portfolio-company reporting and external data providers; the margins of error associated with these methods and the estimation methodologies used are disclosed together with the indicator data in the section above.

Engagement policies

The Management Company’s shareholder engagement policy, published pursuant to Articles L. 533-22 and R. 533-16 of the French Monetary and Financial Code (transposing Directive (EU) 2017/828, SRD II), is available on this website. Engagement is exercised principally through board representation, shareholders’ agreements and ongoing dialogue with portfolio companies, including on the adverse-impact indicators considered in this statement. Where the indicators reveal significant adverse impacts, ESG improvement plans are agreed with the portfolio company concerned and monitored by the Management Company. Where principal adverse impacts are not reduced over more than one reference period, the Management Company escalates the matter through its engagement framework, including board-level action and revised improvement plans and, ultimately, reflects it in its investment and divestment decisions.

References to international standards

The Management Company adheres to the following responsible business conduct codes and internationally recognised standards for due diligence and reporting: the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the International Labour Organization Declaration on Fundamental Principles and Rights at Work and the International Bill of Human Rights. The Management Company is also a signatory, through the Astanor group, of the Operating Principles for Impact Management (OPIM) and the UN Principles for Responsible Investment (PRI), and its exclusion list is aligned with the IFC Exclusion List (2007). The indicators used to measure adherence to or alignment with these standards are the indicators set out in the section “Description of the principal adverse impacts on sustainability factors” above, including the greenhouse-gas indicators and the indicators relating to violations of, and lack of processes and compliance mechanisms to monitor compliance with, the UN Global Compact principles and the OECD Guidelines for Multinational Enterprises (Table 1, indicators 10 and 11).

Alignment with the objectives of the Paris Agreement is assessed through the climate strategy applied to portfolio companies under the Responsible Investment Framework: growth-stage portfolio companies commit to setting science-based emission-reduction targets aligned with the Paris Agreement, in line with the Science Based Targets initiative (SBTi), targeting at least a 90% reduction in absolute emissions by 2050 and reporting annually on progress, while early-stage portfolio companies measure their annual carbon footprint (scopes 1, 2 and 3) and are supported through a climate onboarding programme. Coverage, data sources (the annual ESG questionnaire and portfolio-company carbon-footprint analyses) and the associated limitations are disclosed together with the indicator data. The Management Company does not currently use a forward-looking climate scenario, as it considers that such scenarios are not yet relevant to its portfolio of early- and growth-stage companies in the sustainable agri-food value chain; this position is reviewed annually.

Fund documents (SFDR Article 10)

Ad-Asta Gestion France SAS — 2, rue de Laborde, 75008 Paris, France — RCS Paris 948 607 858 — AMF GP-20260002.

Astanor venture capital funds

Good Harvest Ventures SCSp and Astanor Ventures II SCSp are managed by Gen2 Management Company as their alternative investment fund manager. The regulatory and sustainability-related disclosures relating to these funds and to their manager are available on the website of Gen2 Management Company.

Legacy and co-investment vehicles

Astanor Co-Investment Platform GP S.à r.l. and Good Harvest Partners Management S.à r.l. manage a number of fully allocated legacy alternative investment funds, including GHVI-S SCSp and GHVI-S2 SCSp. Both entities operate under the sub-threshold registration regime of Article 3(2)(b) of Directive 2011/61/EU (AIFMD), as implemented in Luxembourg by Article 3 of the law of 12 July 2013 on alternative investment fund managers: the funds they manage are unleveraged and closed-ended, their assets under management are below the EUR 500 million threshold, and the overall net asset value of all Astanor funds, whether managed by Ad-Asta Gestion France or by these entities, likewise remains below EUR 500 million.

These vehicles and their managers were in place before Ad-Asta Gestion France obtained its AMF authorization. They are governed by their own independent boards, distinct from Ad-Asta Gestion France, and are no longer actively investing: the remaining holdings are legacy investments in the process of orderly disposal. Any conflict of interest arising from existing cross-investments between funds is strictly framed by the contractual provisions of each fund’s legal documentation, which require at least the approval of the relevant LP Advisory Committee. The sustainability-related disclosures of these funds remain available below.

Group policies

Responsible Investment Framework

All investment entities affiliated to the Astanor universe, including the fund managers, abide by the Astanor Responsible Investment Framework. The purpose of this Responsible Investment Framework is to illustrate the guiding principles which help Astanor achieve its sustainable investment objectives and impact KPIs. It encompasses consideration of sustainability factors across organizations, from the implication of implementing purposeful ESG and scaling impact standards with investees. This document forms Astanor’s core ESG and impact management system and helps assess, adapt, and manage the ESG and impact performance as an investor and as a firm.

Group complaints handling

Complaints relating to Ad-Asta Gestion France or to the funds it manages are handled under the procedure set out in the section “Astanor Growth funds” above. For any other entity of the Astanor group, complaints must be sent using the complaints filing form (in appendix to the Group Complaints Handling Policy shared below) to compliance@astanor.com or to: Astanor Ventures, c/o Compliance Department, 480 Avenue Louise, 1050 Brussels, Belgium. An acknowledgement will be sent within ten (10) business days of receipt, an update every four weeks thereafter, and a final letter upon the outcome of the investigation. Where no response is received within one (1) month, the complainant may refer the complaint to the relevant financial authorities of the jurisdiction where the fund operates.

Privacy — personal data

The Astanor personal data fair processing policy (the “Privacy Policy”) is maintained by Astanor GP S.àr.l. and is applicable to all the Astanor Entities. It explains how Astanor collects, stores, shares, protects and uses the personal information of website visitors, business contacts, investment advisors, investors and management teams involved in a business relationship or a potential business relationship with Astanor. For the processing carried out in connection with its own activities, Ad-Asta Gestion France SAS acts as data controller (see the section “Astanor Growth funds” above). Data subjects may exercise their rights as described in the Privacy Policy and have the right to lodge a complaint with the competent supervisory authority.