SFDR Declaration

Background

LUMO Fund, under the management of LUMO Labs B.V. and in alignment with the EU’s Finance Disclosure Regulation (SFDR) 2019/2088 on sustainability-related disclosures in the financial services sector, publishes its policy on the integration of sustainability aspects in the investment strategies and management practices.

LUMO, in line with SFDR 2019/2088, publishes its policies on the integration of sustainability aspects into its investment strategies and management practices. We recognize the pivotal role responsible investment plays in shaping a more sustainable future, and we welcome the SFDR’s emphasis on transparency and accountability.

Since inception, we have been committed to building investment practices that empower stakeholders to make informed decisions and direct capital towards ventures that generate positive contributions.

Article 8+ to Article 9 Fund

Until May 2025, the LUMO Rise Fund was classified as an SFDR Article 8+ Fund, reflecting our commitment to aligning with sustainable investment objectives,  in particular, with the UN Sustainable Development Goals (SDGs 3, 4, and 11), while acknowledging that our reporting frameworks were still maturing. We adopted the Article 8+ designation to avoid premature claims, ensure transparency, and signal the direction of our journey.

As of May 2025, the Fund is formally classified as an Article 9 Fund under SFDR. This transition represents the natural progression of our journey, supported by strengthened ESG and impact frameworks and enhanced reporting processes.

Our Strategy Under Article 9

Our strategy is built on investing in companies that contribute to the United Nations Sustainable Development Goals (SDGs 3: Good Health and Well-being, 4: Quality Education, 11: Sustainable Cities and Communities, and 13: Climate Action). We embed sustainability throughout the investment lifecycle: applying ESG and impact screening during due diligence, integrating “Do No Significant Harm” principles, monitoring Principal Adverse Impact (PAI) indicators and working closely with portfolio companies to build capacity for measurable and transparent impact performance over time.

A Journey of Continuous Improvement

We view our Article 9 classification not as an endpoint but as part of a continuous journey. As an early-stage impact Fund, we recognize that impact data often matures over time. We therefore apply a best-efforts approach: helping companies define their Theory of Change, track progress against impact indicators, and align with good governance and DNSH principles.

Our transition demonstrates our belief that responsible investing is dynamic. We remain intentional, adaptable, and transparent, consistently enhancing our practices and supporting portfolio companies as they grow, with the goal of directing capital toward ventures that deliver lasting positive change for people and the planet.

We will continue to strengthen our frameworks, evolve our reporting, and ensure compliance with SFDR requirements in forthcoming disclosures.

Contact us

If you have any questions about our SFDR disclosure, please feel free to contact us at meron@lumolabs.io