SFDR Statement

Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):

Date of publication: 10 March 2021.

Date of update: 19 December 2022; addition of HV Capital Fund IX Growth GmbH & Co. geschlossene Investment KG and HV Capital Fund IX Ventures GmbH & Co. geschlossene Investment KG and editorial amendments and clarifications.

Date of update: 30 May 2023; editorial amendments and clarifications.

Date of update: 19 December 2025; addition of HV Capital Fund X Ventures GmbH & Co. geschlossene Investment KG (“Fund X Ventures”); removal of the reference in the Website Disclosures of HV Capital Fund IX Ventures GmbH & Co. geschlossene Investment KG (“Fund IX Ventures”) to HV Capital Fund IX Growth GmbH & Co. geschlossene Investment KG (the “Fund”); and preparation of original disclosures for Fund IX Ventures with materially the same content.

I. Sustainability risks

HV Capital Manager GmbH (“HV”, LEI: 529900N8P7FFJJ113Y02) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. HV considers sustainability risks as part of its due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted through an informal process as appropriate in light of the circumstances of the individual case. The results of such assessment are taken into account when the investment decision is being taken. However, HV remains free in its decision to refrain from investing or to invest despite sustainability risks in which case HV can also apply measures to reduce or mitigate any sustainability risks. At all times, HV will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

II. No consideration of adverse impacts of investment decisions on sustainability factors

HV does not consider any adverse impacts of its investment decisions on sustainability factors and, hence, does not use the indicators listed in Annex I of the Regulatory Technical Standards (Delegated Regulation (EU) 2022/1288, “RTS”) to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. Given that the SFDR, the Regulation (EU) 2020/852 (“Taxonomy”) and the accompanying RTS have now been in force for some time, there is a growing body of regulatory guidance and market practice. However, significant legal and practical uncertainties persist regarding their application to venture capital as an asset class. This is particularly relevant for HV, whose investment strategy focuses on startup companies. Such companies typically have limited experience in ESG reporting and often lack the infrastructure to provide comprehensive ESG data. Moreover, the Fund will only hold minority interests in its portfolio companies. Such minority interests are, however, generally not sufficient to encourage the Fund’s portfolio companies to collect and provide the relevant data. As a result, obtaining the necessary information for full compliance continues to pose considerable challenges in practice. If and to the extent that the legal uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, HV will re-evaluate considering principal adverse impacts of its investment decisions in due course.

III. Remuneration disclosures

Although HV considers sustainability risks as part of its investment decision-making process, such risks are not integrated in HV’s remuneration policies.

IV. Sustainability-related disclosures

1. HV Capital Fund IX Growth GmbH & Co. geschlossene Investment KG

Financial product: HV Capital Fund IX Growth GmbH & Co. geschlossene Investment KG (the “Fund” / der “Fonds”) LEI: 529900QSUU4O7F85TM07

Summary

The Fund considers certain environmental and/or social characteristics as part of its investment decisions and monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The consideration of environmental and/or social characteristics is carried out both before and after an investment. For this purpose, information is initially and regularly obtained from the portfolio companies by means of qualitative queries. The Fund incorporates inclusion (positive screening) as well as exclusion (negative screening) aspects during the decision-making process. Thereby the Fund considers several ESG themes to be the key to responsible investing. The actions and decisions described in the following section are each made by HV for and on behalf of the Fund.

Zusammenfassung

Der Fonds berücksichtigt bestimmte ökologische und/oder soziale Merkmale im Rahmen seiner Investitionsentscheidungen und Monitoring-Prozesse, strebt aber keine nachhaltigen Investitionen im Sinne der SFDR an. Die Berücksichtigung von Umwelt- und/oder Sozialmerkmalen erfolgt sowohl vor als auch nach einer Investition. Zu diesem Zweck werden zunächst und regelmäßig Informationen von den Portfoliounternehmen durch qualitative Abfragen eingeholt. Der Fonds bezieht sowohl Inklusions- (positives Screening) als auch Exklusionsaspekte (negatives Screening) in seinen Entscheidungsprozess ein. Dabei betrachtet der Fonds mehrere ESG-Themen als Schlüssel für verantwortungsvolles Investieren. Die in diesem Abschnitt beschriebenen Handlungen und Entscheidungen erfolgen jeweils durch HV für den Fonds.

No sustainable investment objective.

The Fund promotes environmental or social characteristics, but does not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

The Fund promotes environmental and/or social characteristics by implementing certain investment exclusions (see section ‘Investment strategy’) during the decision-making process. Furthermore, whilst identifying suitable investment opportunities, the Fund takes into consideration certain ESG criteria such as the Guideline on EIF’s criteria for Climate Action and Environmental Sustainability (CA&ES) operations in EIF’s intermediated SME and mid-cap financing (April 2022) (the “CA&ES”) as well as diversity targets during the decision-making process.

Investment strategy

The purpose of the Fund is to build, hold and manage (including to divest) a portfolio of equity and equity-related investments in portfolio companies. The Fund will invest in new portfolio companies, i.e., portfolio companies where no other investment vehicle managed or advised by HV is already invested, as well as in existing portfolio companies, i.e., portfolio companies in which another investment vehicle managed or advised by HV is invested. It will target investments in the internet, technology, software mobile and digital media market with consumer internet, b2b, or digital content business models. The Fund intends to make its initial investments in the growth stage, i.e., series B and later stages.

As part of the investment strategy, the Fund also implements investment exclusions and has defined certain ESG criteria to be considered in the investment decision-making process, both laid down in the Fund’s limited partnership agreement.

The Fund is bound by the investment restrictions and limitations and shall procure that such requirements, restrictions and limitations are complied with at all times. It will screen each investment opportunity against its investment exclusions and no investments will be made in the area of such exclusions.

The Fund shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including portfolio companies, or other entities whose business activity consists of:

a) an illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Fund or the relevant portfolio company, including without limitation, human cloning for reproduction purposes);

b) the production of and trade in tobacco and distilled alcoholic beverages and related products;

c) the financing of the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies;

d) casinos and equivalent enterprises;

e) the research, development or technical applications relating to electronic data programs or solutions, which:

- aim specifically at: (i) supporting any activity referred to under no. 2 through no. 4; (ii) internet gambling and online casinos; or (iii) pornography; or

- are intended to enable to illegally (i) enter into electronic data net-works; or (ii) download electronic data;

f) fossil fuel-based energy production and related activities, as follows:

- coal mining, processing, transport and storage;

- oil exploration & production, refining, transport, distribution and storage;

- natural gas exploration & production, liquefaction, regasification, transport, distribution and storage; and

- electric power generation exceeding the Emissions Performance Standard (i.e., 250 grams of CO2e per kWh of electricity), applicable to fossil fuel-fired power and cogeneration plants, geothermal and hydropower plants with large reservoirs;

g) energy-intensive and/or high CO2-emitting industries, as follows:

- manufacture of other inorganic basic chemicals (NACE 20.13);

- manufacture of other organic basic chemicals (NACE 20.14);

- manufacture of fertilizers and nitrogen compounds (NACE 20.15);

- manufacture of plastics in primary forms (NACE 20.16);

- manufacture of cement (NACE 23.51);

- manufacture of basic iron and steel and of ferro-alloys (NACE 24.10);

- manufacture of tubes, pipes, hollow profiles and related fittings, of steel (NACE 24.20);

- manufacture of other products of first processing of steel (NACE 24.30, incl. 24.31-24.34);

- aluminum production (NACE 24.42);

- manufacture of conventionally-fueled aircraft and related machinery (sub-activity of NACE 30.30); and

- conventionally-fueled air transport and airports and service activities incidental to conventionally-fueled air transportation (sub-activities of NACE 51.10, 51.21 and 52.23).

Furthermore, the Fund has bindingly set the following ESG criteria in its limited partnership agreement:

a) The Fund targets to invest at least 30 % of its aggregate invested capital at some point during the term of the Fund, but not before the end of the investment period, in companies which are classified as contributing to CA&ES objectives in accordance with the latest criteria as of the date of the limited partnership agreement.

b) The Fund aims to achieve at some point during the term of the Fund one-third (33%) female representation at senior management level across the portfolio.

Good governance practices are assessed through an informal process as appropriate in light of the circumstances of each individual case. Such practices include, in particular, sound management structures, employee relations, remuneration of staff and tax compliance within the portfolio companies. Moreover, the Fund will conduct regular monitoring of the good governance practices in its portfolio companies during the holding period. If the Fund becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution.

Proportion of investments

The Fund will invest fully in line with its investment strategy and investment restrictions, i.e., will only make investments which are aligned with its environmental or social characteristics (i.e., its investment exclusions and ESG criteria). The Fund does not make and does not intend to make sustainable investments within the meaning of article 2 no. 17 SFDR or environmentally sustainable investments within the meaning of Art. 3 Taxonomy; hence, no portion of its investments will be aligned with the Taxonomy.

Monitoring of environmental or social characteristics

The Fund has an increased awareness on the impact of environmental or social characteristics on risk management and thus on the value potential of investments. In order to monitor the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions and ESG criteria), the Fund consults with the portfolio companies in regular intervals and will carry out further checks in order to identify potential issues with such characteristics. Moreover, the Fund obtains further information in quarterly reports from its portfolio companies. Therefore, the Fund monitors compliance with its environmental or social characteristics (i.e., its investment exclusions and ESG criteria) on an ongoing basis. External monitoring mechanisms are not in place.

Methodologies for environmental or social characteristics

The Fund applies qualitative and quantitative assessments with regard to its environmental or social characteristics (i.e., its investment exclusions and ESG criteria).

The Fund conducts an initial assessment of the promoted environmental or social characteristics in the course of its due diligence. During the holding period, the so conducted assessment forms the basis to measure and monitor if the characteristics are continuously being met.

Data sources and processing

In order to attain each of the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions and ESG criteria), a checklist is completed by the (potential) portfolio companies in the course of the due diligence conducted prior to each investment. The data collected is then assessed for quality and analyzed to be integrated into the investment decision-making process. Moreover, during the holding period, the portfolio companies provide the Fund with quarterly reports for monitoring purposes as well as improvement opportunities. Hence, data is obtained only from the (potential) portfolio companies. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected.

Limitations to methodologies and data

The information collected from the (potential) portfolio companies via the checklist as part of the due diligence through the informal process carried out by the Fund is internally or externally verified if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may remain undetected in certain cases. As the Fund’s investments are made for several years, the Fund considers it a priority to establish and maintain a trustful working relationship with its portfolio companies in order to ensure compliance with the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions and ESG criteria). Further limitations, in particular with regard to the accuracy of the data and reliability of the data sources used, are not apparent at this time.

Due diligence

An initial assessment of how an investment relates to the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions and ESG criteria) is carried out as part of the due diligence process using the checklist through the informal process and taking into account the inherent ESG risk of the portfolio company. An enhanced analysis is carried out where required, depending on the (potential) portfolio company’s risk profile and its stage. As a rule, at least qualitative statements of an environmental or social nature or relating to corporate governance are requested from the portfolio companies and then taken into account in the investment decision-making process. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected.

Engagement policies

Engagement forms part of the environmental or social investment strategy of the Fund. The Fund intends to engage in managing ESG across its portfolio companies, e.g., through an ESG onboarding process followed by regular, customized conversations around material ESG topics.

Designated reference benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by the Fund.

2. HV Capital Fund IX Ventures GmbH & Co. geschlossene Investment KG

HV Capital Fund IX Ventures GmbH & Co. geschlossene Investment KG (“Fund IX Ventures” / Fonds IX Ventures”) LEI: 529900R9FDWJYVEX2B57

Summary

Fund IX Ventures considers certain environmental and/or social characteristics as part of its investment decisions and monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The consideration of environmental and/or social characteristics is carried out both before and after an investment. For this purpose, information is initially and regularly obtained from the portfolio companies by means of qualitative queries. Fund IX Ventures incorporates inclusion (positive screening) as well as exclusion (negative screening) aspects during the decision-making process. Thereby Fund IX Ventures considers several ESG themes to be the key to responsible investing. The actions and decisions described in the following section are each made by HV for and on behalf of Fund IX Ventures.

Zusammenfassung

No sustainable investment objective.

Fund IX Ventures promotes environmental or social characteristics, but does not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

Fund IX Ventures promotes environmental and/or social characteristics by implementing certain investment exclusions (see section ‘Investment strategy’) during the decision-making process. Furthermore, whilst identifying suitable investment opportunities, Fund IX Ventures takes into consideration certain ESG criteria such as the Guideline on EIF’s criteria for Climate Action and Environmental Sustainability (CA&ES) operations in EIF’s intermediated SME and mid-cap financing (April 2022) (the “CA&ES”) as well as diversity targets during the decision-making process.

Investment strategy

The purpose of Fund IX Ventures is to build, hold and manage (including to divest) a portfolio of equity and equity-related investments in portfolio companies. Fund IX Ventures will invest in new portfolio companies, i.e., portfolio companies where no other investment vehicle managed or advised by HV is already invested. It will target investments in the internet, technology, software mobile and digital media market with consumer internet, b2b, or digital content business models. Fund IX Ventures intends to make its initial investments in the early stage, i.e., angel, seed and series A. As part of the investment strategy, Fund IX Ventures also implements investment exclusions and has defined certain ESG criteria to be considered in the investment decision-making process.

Fund IX Ventures is bound by the investment restrictions and limitations as well as the ESG targets as set out in Fund IX Ventures’ limited partnership agreement. Fund IX Ventures shall procure that such requirements, restrictions and limitations are complied with at all times.

In particular, Fund IX Ventures will screen each investment opportunity against the following investment exclusions and no investments will be made in the area of such exclusions.

Fund IX Ventures shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including portfolio companies, or other entities:

whose business activity consists of any illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to Fund IX Ventures or the relevant portfolio company, including without limitation, human cloning for reproduction purposes);
or whose main business activity consists of
a. the production of tobacco and distilled alcoholic beverages and related products;
b. the financing of the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies;
c. casinos and equivalent enterprises;
d. the research, development or technical applications relating to electronic data programs or solutions, which:
i. aim specifically at: (A) supporting any activity referred to under numbers 2.a. to 2.c.; (B) internet gambling and online casinos; or (C) pornography;
or which:
ii. are intended to enable to illegally (A) enter into electronic data networks; or (B) download electronic data;
e. fossil fuel-based energy production, as follows:
i. coal mining, processing, transport and storage;
ii. oil exploration & production, refining, transport, distribution and storage;
iii. natural gas exploration & production, liquefaction, regasification, transport, distribution and storage; and
iv. electric power generation exceeding the Emissions Performance Standard (i.e., 250 grams of CO2e per kWh of electricity), applicable to fossil fuel-fired power and cogeneration plants, geothermal and hydropower plants with large reservoirs;
f. energy-intensive and/or high CO2-emitting industries, as follows:
i. manufacture of other inorganic basic chemicals (NACE 20.13);
ii. manufacture of other organic basic chemicals (NACE 20.14);
iii. manufacture of fertilizers and nitrogen compounds (NACE 20.15);
iv. manufacture of plastics in primary forms (NACE 20.16);
v. manufacture of cement (NACE 23.51);
vi. manufacture of basic iron and steel and of ferro-alloys (NACE 24.10);
vii. manufacture of tubes, pipes, hollow profiles and related fittings, of steel (NACE 24.20);
viii. manufacture of other products of first processing of steel (NACE 24.30, incl. 24.31-24.34);
ix. aluminum production (NACE 24.42);
x. manufacture of conventionally-fueled aircraft and related machinery (sub-activity of NACE 30.30); and
xi. conventionally-fueled air transport and airports and service activities incidental to conventionally-fueled air transportation (sub-activities of NACE 51.10, 51.21 and 52.23).

Whereas investments in sectors mentioned in limb. f shall be allowed if the Managing Limited Partner confirms that the specific final recipient transaction either (A) qualifies as environmentally sustainable investments, or (B) is eligible under the CA&ES criteria.

Furthermore, Fund IX Ventures has bindingly set the following ESG criteria in its limited partnership agreement:

Fund IX Ventures targets to invest at least 30 % of its aggregate invested capital at some point during the term of Fund IX Ventures, but not before the end of the investment period, in companies which are classified as contributing to CA&ES objectives in accordance with the latest criteria as of the date of the limited partnership agreement.
Fund IX Ventures aims to achieve at some point during the term of Fund IX Ventures one-third (33%) female representation at senior management level across the portfolio.

Good governance practices are assessed through an informal process as appropriate in light of the circumstances of each individual case. Such practices include, in particular, sound management structures, employee relations, remuneration of staff and tax compliance within the portfolio companies. Moreover, Fund IX Ventures will conduct regular monitoring of the good governance practices in its portfolio companies during the holding period. If Fund IX Ventures becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution.

Proportion of investments

Fund IX Ventures will invest fully in line with its investment strategy and investment restrictions, i.e., will only make investments which are aligned with its environmental or social characteristics (i.e., its investment exclusions and ESG criteria). Fund IX Ventures does not make and does not intend to make sustainable investments within the meaning of article 2 no. 17 SFDR or environmentally sustainable investments within the meaning of Art. 3 Taxonomy; hence, no portion of its investments will be aligned with the Taxonomy.

Monitoring of environmental or social characteristics

Fund IX Ventures has an increased awareness on the impact of environmental or social characteristics on risk management and thus on the value potential of investments. In order to monitor the environmental or social characteristics promoted by Fund IX Ventures (i.e., its investment exclusions and ESG criteria), Fund IX Ventures consults with the portfolio companies in regular intervals and will carry out further checks in order to identify potential issues with such characteristics. Moreover, Fund IX Ventures obtains further information in quarterly reports from its portfolio companies. Therefore, Fund IX Ventures monitors compliance with its environmental or social characteristics (i.e., its investment exclusions and ESG criteria) on an ongoing basis. External monitoring mechanisms are not in place.

Methodologies for environmental or social characteristics

Fund IX Ventures applies qualitative and quantitative assessments with regard to its environmental or social characteristics (i.e., its investment exclusions and ESG criteria).

Fund IX Ventures conducts an initial assessment of the promoted environmental or social characteristics in the course of its due diligence. During the holding period, the so conducted assessment forms the basis to measure and monitor if the characteristics are continuously being met.

Data sources and processing

In order to attain each of the environmental or social characteristics promoted by Fund IX Ventures (i.e., its investment exclusions and ESG criteria), a checklist is completed by the (potential) portfolio companies in the course of the due diligence conducted prior to each investment. The data collected is then assessed for quality and analyzed to be integrated into the investment decision-making process. Moreover, during the holding period, the portfolio companies provide Fund IX Ventures with quarterly reports for monitoring purposes as well as improvement opportunities. Hence, data is obtained only from the (potential) portfolio companies. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected.

Limitations to methodologies and data

The information collected from the (potential) portfolio companies via the checklist as part of the due diligence through the informal process carried out by Fund IX Ventures is internally or externally verified if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may remain undetected in certain cases. As Fund IX Ventures’ investments are made for several years, Fund IX Ventures considers it a priority to establish and maintain a trustful working relationship with its portfolio companies in order to ensure compliance with the environmental or social characteristics promoted by Fund IX Ventures (i.e., its investment exclusions and ESG criteria). Further limitations, in particular with regard to the accuracy of the data and reliability of the data sources used, are not apparent at this time.

Due diligence

An initial assessment of how an investment relates to the environmental or social characteristics promoted by Fund IX Ventures (i.e., its investment exclusions and ESG criteria) is carried out as part of the due diligence process using the checklist through the informal process and taking into account the inherent ESG risk of the portfolio company. An enhanced analysis is carried out where required, depending on the (potential) portfolio company’s risk profile and its stage. As a rule, at least qualitative statements of an environmental or social nature or relating to corporate governance are requested from the portfolio companies and then taken into account in the investment decision-making process. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected.

Engagement policies

Engagement forms part of the environmental or social investment strategy of Fund IX Ventures. Fund IX Ventures intends to engage in managing ESG across its portfolio companies, e.g., through an ESG onboarding process followed by regular, customized conversations around material ESG topics.

Designated reference benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by Fund IX Ventures.

3. HV Capital Fund X Ventures GmbH & Co. geschlossene Investment KG

Financial product: HV Capital X Ventures GmbH & Co. geschlossene Investment KG (“Fund X Ventures Ventures” / “Fonds X Ventures”) LEI: 5299007KBZD3WLLWKZ16

Summary

Fund X Ventures considers certain environmental and/or social characteristics as part of its investment decisions and monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The consideration of environmental and/or social characteristics is carried out both before and after an investment. For this purpose, information is initially and regularly obtained from the portfolio companies by means of qualitative queries. Fund X Ventures incorporates exclusion (negative screening) aspects during the decision-making process. Thereby Fund X Ventures considers several ESG themes to be the key to responsible investing. The actions and decisions described in the following section are each made by HV for and on behalf of Fund X Ventures.

Zusammenfassung

Fonds X Ventures berücksichtigt bestimmte ökologische und/oder soziale Merkmale im Rahmen seiner Investitionsentscheidungen und Monitoring-Prozesse, strebt aber keine nachhaltigen Investitionen im Sinne der SFDR an. Die Berücksichtigung von Umwelt- und/oder Sozialmerkmalen erfolgt sowohl vor als auch nach einer Investition. Zu diesem Zweck werden zunächst und regelmäßig Informationen von den Portfoliounternehmen durch qualitative Abfragen eingeholt. Fonds X Ventures bezieht Exklusionsaspekte (negatives Screening) in seinen Entscheidungsprozess ein. Dabei betrachtet Fonds X Ventures mehrere ESG-Themen als Schlüssel für verantwortungsvolles Investieren. Die in diesem Abschnitt beschriebenen Handlungen und Entscheidungen erfolgen jeweils durch HV für Fonds X Ventures.

No sustainable investment objective

Fund X Ventures promotes environmental or social characteristics, but does not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

Fund X Ventures promotes environmental and/or social characteristics by implementing certain investment exclusions (see section ‘Investment strategy’) during the decision-making process.

Investment strategy

The purpose of Fund X Ventures is to is to build, hold and manage (including to divest) a portfolio of equity and equity-related investments in portfolio companies. Fund X Ventures will invest in new portfolio companies, i.e., portfolio companies where no other investment vehicle managed or advised by HV is already invested. It will target investments in the internet, technology, health, deeptech, software, mobile and digital media market with consumer internet, b2b, or digital content business models. Fund X Ventures intends to make its initial investments in the early stage, i.e. pre-seed, seed and series A. As part of the investment strategy, Fund X Ventures also implements investment exclusions and has defined certain ESG criteria to be considered in the investment decision-making process.

Fund X Ventures’ investment strategy is implemented in the investment process on a continuous basis: Every investment opportunity will be tested against Fund X Ventures’ investment strategy (i.e. its investment exclusions) as part of the due diligence prior to any investment made by Fund X Ventures.

Fund X Ventures is bound by the investment restrictions and limitations set out in Fund X Ventures limited partnership agreement and shall procure that such requirements, restrictions and limitations are complied with at all times. In particular, Fund X Ventures will screen each investment opportunity against the following investment exclusions and no investments will be made in the area of such exclusions. Fund X Ventures shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including portfolio companies, or other entities

whose business activity consists of any illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to Fund X Ventures or the relevant portfolio company, including without limitation, human cloning for reproduction purposes);
or whose main business activity consists of:
a. the production of tobacco, distilled alcoholic beverages or related products;
b. the financing and production of, and trade in, weapons and ammunition of any kind, it being understood that this restriction shall not apply to investments in Portfolio Companies whose activities contribute to the European Union’s security, defense readiness, or strategic resilience, even if such alignment is not based on a formally designated European Union policy or funding program. This shall, in particular, be deemed to be the case if the relevant portfolio company is headquartered in a Member State of the European Union and derives, or intends to derive, more than 50 % of its revenues from within the European Union;

Notwithstanding the foregoing, Fund X Ventures shall in no event invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, or other entities whose main business activity consists in the financing and production of, and trade in, controversial weapons (as defined under Commission Delegated Regulation (EU) 2022/1288 of April 6, 2022 (Sustainable Finance Disclosure Regulation – Regulatory Technical Standards)) (i.e., nuclear weapons and radioactive ammunition, biological and chemical weapons of mass destruction, cluster bombs, anti-personnel mines, enriched uranium, lethal autonomous weapons systems) or critical components thereof;

c. casinos and equivalent enterprises;

d. the research, development or technical applications relating to electronic data programs or solutions, which:

i. aim specifically at: (A) supporting any activity referred to under limb. a through limb. d; (B) internet gambling and online casinos; or (C) pornography; or

ii.are intended to enable to illegally (A) enter into electronic data networks or (B) download electronic data;

e. fossil fuel-based energy production, as follows:

i. coal mining, processing, transport or storage;

ii. oil exploration & production, refining, transport, distribution or storage;

iii. natural gas exploration & production, liquefaction, regasification, transport, distribution or storage; or

iv. electric power generation exceeding the applicable Emissions Performance Standard applicable to fossil fuel-fired power and cogeneration plants, geothermal and hydropower plants with large reservoirs;

f. energy-intensive and/or high CO2-emitting industries, as follows:

i. manufacture of other inorganic basic chemicals (NACE 20.13);

ii. manufacture of other organic basic chemicals (NACE 20.14);

iii. manufacture of fertilizers and nitrogen compounds (NACE 20.15);

iv. manufacture of plastics in primary forms (NACE 20.16);

v. manufacture of cement (NACE 23.51);

vi. manufacture of basic iron and steel and of ferro-alloys (NACE 24.10);

vii. manufacture of tubes, pipes, hollow profiles and related fittings, of steel (NACE 24.20);

viii. manufacture of other products of first processing of steel (NACE 24.30, incl. 24.31-24.34);

ix. aluminum production (NACE 24.42);

x. manufacture of conventionally-fueled aircraft and related machinery (sub-activity of NACE 30.30); or

xi. conventionally-fueled air transport and airports and service activities incidental to conventionally-fueled air transportation (sub-activities of NACE 51.10, 51.21 and 52.23),

In addition, when providing support to the financing of the research, development or technical applications relating to (a) human cloning for research or therapeutic purposes, or (b) genetically modified organisms (“GMOs”), Fund X Ventures shall ensure the appropriate control of legal, regulatory and ethical issues linked to such human cloning for research or therapeutic purposes and/or GMOs. Notwithstanding the aforementioned, research activities (i) aiming at human cloning for reproductive purposes, (ii) intended to modify the genetic heritage of human beings which could make such changes heritable (excluding research relating to cancer treatment of gonads), or (iii) intended to create human embryos solely for the purpose of research or for the purpose of stem cell procurement, including by means of somatic cell nuclear transfer, are also excluded.

Good governance practices are assessed through an informal process as appropriate in light of the circumstances of each individual case as part of the due diligence prior to any investment made by Fund X Ventures. Such practices include, in particular, sound management structures, employee relations, remuneration of staff and tax compliance within the portfolio companies. Moreover, Fund X Ventures will conduct regular monitoring of the good governance practices in its portfolio companies during the holding period. If Fund X Ventures becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution.

Proportion of investments

Fund X Ventures will invest fully in line with its investment strategy and investment restrictions, i.e., will only make investments which are aligned with its environmental and/or social characteristics. Fund X Ventures does not make and does not intend to make sustainable investments within the meaning of Art. 2 no. 17 SFDR or environmentally sustainable investments within the meaning of Art. 3 of Regulation (EU) 2020/852 (“EU Taxonomy”); hence, no portion of its investments will be aligned with the EU Taxonomy.

Monitoring of environmental or social characteristics

Fund X Ventures has an increased awareness on the impact of environmental or social characteristics (i.e., its investment exclusions) on risk management and thus on the value potential of investments. Accordingly, Fund X Ventures undertakes to monitor (compliance with) its environmental and/or social characteristics on an ongoing basis. Prior to making an investment, Fund X Ventures assesses the attainment of its environmental and/or social characteristics (i.e., its investment exclusions) with respect to every (potential) portfolio company. In order to monitor the environmental or social characteristics during the holding period, Fund X Ventures consults with the portfolio companies in regular intervals and will carry out further checks in order to identify potential issues with such characteristics. Moreover, Fund X Ventures obtains further information in quarterly reports from its portfolio companies and will carry out further checks if there are indications of potential issues with Fund X Ventures’ ESG approach. External monitoring mechanisms are not in place.

Methodologies for environmental or social characteristics

Fund X Ventures applies qualitative and quantitative assessments with respect to its environmental and/or social characteristics (i.e., its investment exclusions ). Fund X Ventures conducts an initial assessment of such characteristics in the course of its due diligence process prior to any investment by providing its (potential) portfolio companies with a checklist. Through this checklist, the investment exclusions and good governance practices are identified and evaluated. Based on the results of this assessment, Fund X Ventures identifies whether the environmental and/or social characteristics promoted by Fund X Ventures (through its investment exclusions) are met before making an investment. During the holding period, the so conducted assessment forms the basis to measure and monitor if the characteristics are continuously being met.

Data sources and processing

In order to attain each of the environmental and/or social characteristics promoted by Fund X Ventures (i.e., its investment exclusions), a checklist is completed by the (potential) portfolio companies in the course of the due diligence process conducted prior to each investment. Moreover, during the holding period, the portfolio companies provide Fund X Ventures with quarterly reports for monitoring purposes as well as improvement opportunities. Further, mostly qualitative statements of an environmental or social nature or relating to corporate governance are requested from the (potential) portfolio companies and then taken into account in the investment decision-making and monitoring processes. Hence, data is obtained exclusively from the (potential) portfolio companies. An internal or external review or verification of the data obtained will be carried out if misrepresentations are suspected.

Limitations to methodologies and data

The data collected exclusively from the (potential) portfolio companies is internally or externally verified only if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may remain undetected in certain cases. Further limitations, in particular with regard to the accuracy of the data and reliability of the data sources used, are currently not foreseeable. As Fund X Ventures’ investments are made for several years, Fund X Ventures considers it a priority to establish and maintain a trustful working relationship with its portfolio companies in order to ensure data quality and compliance with the environmental and/or social characteristics promoted by Fund X Ventures.

Due diligence

In order to attain the aforementioned environmental and/or social characteristics, Fund X Ventures carefully selects its portfolio companies during the investment decision-making process. Fund X Ventures conducts a due diligence on every (potential) portfolio company. As part of this due diligence, Fund X Ventures carefully reviews how a (potential) investment relates to the environmental and/or social characteristics promoted by Fund X Ventures. Fund X Ventures incorporates exclusion (negative screening with respect to its investment exclusions) as well as good governance aspects during the decision-making process. This assessment is conducted by using a checklist and, where required based on the inherent ESG risk of the portfolio company, through an enhanced analysis. An internal or external review or verification of the information obtained will only be carried out if misrepresentations are suspected.

Engagement policies

Engagement forms part of the environmental or social investment strategy of Fund X Ventures. Fund X Ventures intends to engage in managing ESG across its portfolio companies, e.g., through an ESG onboarding process followed by regular, customized conversations around material ESG topics.

Designated reference benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by Fund X Ventures.

Kurzfassung der Strategie für die Ausübung von Stimmrechten nach § 3 Abs. 2 KAVerOV

Die HV Capital Manager GmbH (KVG) hat eine Strategie für die Ausübung von Stimmrechten in den Portfolien der durch sie extern verwalteten AIF festgelegt, um sicherzustellen, dass die Stimmrechtsausübung ausschließlich zum Nutzen der AIF und ihrer Anleger erfolgt.

Die Ausübung von Stimmrechten auf Ebene der Vermögensgegenstände, insbesondere als Gesellschafter der Portfoliounternehmen, ist integraler Bestandteil der ordnungsgemäßen kollektiven Vermögensverwaltung durch die KVG. Die KVG übt die Stimmrechte grundsätzlich unmittelbar und fristgerecht aus. Entsprechend eingerichtete Geschäftsprozesse ermöglichen der KVG hierbei eine Verfolgung maßgeblicher Kapitalmaßnahmen.

Die KVG entscheidet über die Ausübung von Stimmrechten für jeden extern verwalteten AIF unabhängig und allein anhand objektiver Gründe, im Einklang mit den Anlagezielen und der Anlagepolitik des jeweiligen AIF, unabhängig von den Interessen Dritter und unter Berücksichtigung der Integrität des Marktes. Hierbei kann grundsätzlich keine Einzelperson Entscheidungen über die Ausübung von Stimmrechten treffen. Beim Auftreten von Interessenkonflikten sind betroffene Personen von der Entscheidung ausgeschlossen.

Die KVG überprüft regelmäßig und gegebenenfalls anlassbezogen, ob die Strategie für die Ausübung von Stimmrechten weiterhin angemessen, wirksam und somit gültig ist und nimmt soweit erforderlich entsprechende Anpassungen vor.