SFDR Disclosure

Transparency of Sustainability Risk Policy

Thoma Bravo seeks to integrate sustainability risks into its investment process through the consideration of responsible growth and governance (RGo) factors. For software and technology prospective and current portfolio companies, Thoma Bravo has found that these factors typically converge around five key focus areas: (i) cybersecurity and data privacy, (ii) artificial intelligence, (iii) operations and oversight, (iv) human capital, and (v) sustainability and stewardship. When evaluating investment opportunities, Thoma Bravo generally considers sustainability risks associated with such opportunities with reference to RGo factors. In particular, where applicable, Thoma Bravo generally seeks to evaluate material RGo risks, mitigating factors and opportunities applicable for the asset type. Thoma Bravo tracks certain relevant data, and where appropriate, integrates such data into the investment research, acquisition and post-acquisition monitoring process. The Management Committee generally considers material sustainability risks raised during due diligence as part of the decision-making process to invest.

Please see Thoma Bravo’s latest RGo report for recent developments and initiatives.

No consideration of principal adverse sustainability impacts

Thoma Bravo aims to manage the risk connected to adverse impacts from its investments in several ways, including during investment due diligence and as part of monitoring during the period of ownership of a portfolio company. Thoma Bravo has considered, and continues to consider, RGo factors in its investment process to help deliver risk-adjusted returns but it does not consider adverse impacts of investment decisions on sustainability factors as specifically set out in Regulation 2019/2088 on sustainability-related disclosures in the financial services sector dated 27 November 2019 (SFDR). Thoma Bravo has chosen not to do so for the present time as it considers that its existing RGo policies and procedures are appropriate, proportional and tailored to the investment strategies of the funds managed by Thoma Bravo. Thoma Bravo continues to closely monitor regulatory developments with respect to the SFDR and other applicable ESG-focused laws and regulations, including the implementation of related and secondary legislation and regulatory guidance, and will, where required or otherwise appropriate, make changes to its existing policies and procedures.