Environmental, Social and Governance Policy

We believe that financially driven startups with a holistic sustainable approach along their value chain have the potential to not only change industries but also to have a positive impact on the world we want to live in.

As a financial investor, we are aware of the impact we have with the decisions we make. We have thus developed a framework to integrate ESG across all areas of our business practice and would like to make our actions transparent to foster collaboration with the community.

Investment
Decision Making:
Partner with the right companies

Our Actions

As part of every due diligence, we assess the “Impact Score” of the startup along the 17 SDGs of the United Nations. The startup is given a scoring between -2 (very negative impact) and +2 (very positive impact) where applicable, addressing both the current and the expected SDG development in the future. We exclude any potential investment with a negative aggregate score or with a single SDG-rating equal to -2 (“red flag”).

Impact Score

download our dd template
Portfolio Companies:
Bring them to the next level

We include a Sustainability Clause in all term sheets and investment agreements. This contract states that each portfolio company shall, within reasonable time following the signing, adopt and maintain an ESG policy. Such policies and measures shall be discussed with and reported to the Board. We support the management with the commitments and recommend frameworks to enable the management to establish this ESG policy.

To help portfolio companies with implementing an ESG policy, we have initiated and designed an ESG workshop format for startups which currently pilots the concepts with selected portfolio firms.

Download our esg term sheet clause
Internal Procedures:
Lead by example

We are active supporters of Leaders for Climate Action and are ClimatePartner-certified climate-neutral by reducing our carbon footprint through internal food and travel policies, and by compensating the remaining.

We are active supporters of Women Start.up! Initiative and Female Founders. We regularly host events together to encourage more female founders in our startup community and support female founders in getting access to capital.

We constantly want to learn and exchange with other VCs to develop our approach further. Together with TechFounders, we host monthly best practice sharing sessions with impact VCs and financially driven VCs.

Reach out to Lisa Liu if you want to learn more

Sustainability Playbooks

Together with the sustainability consulting company akzente and the startup accelerator TechFounders, we have published the Sustainability Playbooks for startups and VCs. The playbooks provide guidelines and pragmatic tips to tackle the topic in a targeted manner.

learn more

SFDR

UVC Partners is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”).

Unless information is explicitly provided in relation to a specific fund managed by UVC Partners, the following statements refer to the management and investment decision-making processes of UVC Partners in general. UVC Partners addresses sustainability risks in its investment decision-making process. ‘Sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. The main concerns UVC Partners pays attention to are the 17 Sustainable Development Goals (“SDG”) published by the United Nations.

UVC Partners documents, assesses, and publishes the ESG-related information to its investors on a regular basis (i.e., quarterly reports, annual general meetings, etc.). Further, UVC Partners regularly reviews the implemented policies to ensure that they address new and emerging risks as well as investors’ concerns.  

UVC Partners does not consider principal adverse impacts of investment decisions on sustainability factors. ‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. UVC Partners does not use sustainability indicators. Considering the numerous legal uncertainties currently related to the application of the provisions of the SFDR and the Regulatory Technical Standards (“RTS”) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, UVC Partners is not in a position to commit to such standard in light of its fiduciary duty to the fund and its investors. UVC Partners will constantly monitor and review the evolution around such regulations and standards and intends to change its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to UVC Partners.

In addition to the recognition and compliance with applicable law, all employees of UVC Partners undertake in accordance with Article 7 of Regulation No. 345/2013 of the European Parliament and of the Council of April 17, 2013, on European venture capital funds to comply with internally developed ethical and professional standards (“code of conduct”). The wording is based on the code of conduct of the Federal Association of German Equity Investment Companies (Bundesverband Deutscher Kapitalbeteiligungsgesellschaften) and the European Private Equity & Venture Capital Association of October 2008 and April 2009. Further, UVC Partners incorporates guidelines as endorsed and/or published by Invest Europe from time to time which, as at the date of this publication, are the international private equity and venture capital valuation guidelines as published by the IPEV and which are constantly amended to address ESG-related issues. Moreover, UVC Partners is a member of the Leaders for Climate Action (“LFCA”) and hence includes provisions promoted by LFCA into contracts for prospective portfolio companies in addition to the internally developed ranking methodology. In particular, our investment contracts state that each portfolio company shall, within a reasonable time following the signing, adopt and thereafter maintain in effect an ESG policy. In detail, these activities include the following:  

Adopting a climate policy and implementing measures to become climate neutral within latest 12 months. Evaluating and establishing best practices of its business activities regarding environment, society and governance. Such policy and measures shall be discussed with and reported to the Board. UVC Partners will support the management with the commitments mentioned above. To specify, UVC Partners will recommend a framework and workshop format to enable the management to approach and establish this ESG policy. The funds managed by UVC Partners (“UVC Funds”) promote Startups with a holistic sustainability approach along their value chain, because UVC Partners believes that those have the potential to not only change entire industries, but to shape the world we want to live in.

This disclosure was published in March 2021 and last updated in February 2022.

Fund III

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Product disclosure for financial products referred to in Article 8(1) and 10 of Regulation (EU) 2019/2088 (SFDR) for Unternehmertum VC Fonds III GmbH & Co. KG

Unternehmertum Venture Capital Partners GmbH (“UVC Partners”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”).

UVC Partners has updated its ESG-Policies since the establishment of Unternehmertum VC Fonds III GmbH & Co. KG. The following disclosure describes the updated ESG-Policy of as of February 2022.

I. Summary

UVC Partners considers certain environmental and social characteristics as part of its investment decisions but does not seek to make sustainable investments as defined in the SFDR. UVC Partners aspires to integrate responsible investment practices into its entire investment process from origination to exit. The consideration of environmental and social characteristics is therefore carried out through certain sector exclusions as well as the integration of ESG factors in the investment decision-making process, the investment agreements and as part of an active ownership. UVC Partners monitors and reviews the ESG-Policy as described below regularly to ensure that the promoted environmental and social characteristics are met.

UVC Partners berücksichtigt bei seinen Investitionsentscheidungen bestimmte ökologische und soziale Merkmale, strebt jedoch keine nachhaltigen Investitionen im Sinne der SFDR an. UVC Partners strebt nach einer Integration von verantwortungsvollen Investitionspraktiken in den gesamten Investitionsprozess, von der Auflage des Fonds bis zum Exit. Die Berücksichtigung ökologischer und sozialer Merkmale erfolgt daher durch bestimmte Sektorausschlüsse, die Integration von ESG-Faktoren in den Investitionsentscheidungsprozess, durch Investitionsvereinbarungen und als Teil einer aktiven Eigentümerschaft. UVC Partners überprüft und überarbeitet die ESG-Politik regelmäßig, um sicherzustellen, dass die beworbenen ökologischen und sozialen Merkmale berücksichtigt werden. 

II. This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment.

No. Reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the financial product.

1. What environmental and/or social characteristics are promoted by this financial product?

Investment Restrictions:
The governing documentation underlying this product (in particular, the limited partnership agreement of the product) provides for various sector exclusions relating to environmental and/or social characteristics, such as fossil fuel-based energy production or energy-intensive and/or high CO2-emitting industries.

Other:
Also, UVC Partners is committed to investing responsibly as demanded by the Principles for Responsible Investment (PRI) and it is UVC Partners’ ambition to develop companies into successful but sustainable businesses, who follow the Ten principles of the UN Global Compact. UVC Partners therefore aspires to integrate responsible investment practices into its entire investment process; from origination to exit, and to lead by example within its own internal operations. UVC Partners considers two dimensions in his responsible investment practice:  

a) ESG: UVC Partners uses Environmental, Social and Corporate Governance (ESG) factors to evaluate and mitigate non-financial risk. A healthy ESG performance is a prerequisite for long-term value creation and for a positive investment decision.

b) Impact: As a financial investor investing into the global leaders of the future, UVC Partners’ responsibility goes beyond minimizing risk. UVC Partners wants to proactively pursue investments with a positive social and environmental impact alongside financial return. Through UVC Partners’ investment focus areas (digitization of business processes, transformation of industrial processes and disruption of mobility) most of the investments particularly address numbers 8, 9, 11, 12 and 13 of the UN’s Sustainable Development Goals (SDGs). In case of a potential investment where other SDGs might be relevant, UVC Partners will exceptionally also consider other additional SDGs, if the necessary data has been provided or can be obtained. UVC Partners pays special attention to the compliance with global standards for equal pay, diversity and inclusion, environmental policies, carbon emissions, waste management, health/safety policies as well as product safety and responsible purchasing policies.

Impact assessment process:
UVC Partners evaluates every potential investment’s impact against the Development Goals published by the United Nations (“SDG”) as described above. Therefore, as part of every due diligence (see also “Investment Criteria: ESG & Impact Questionnaire” under 3), UVC Partners assesses an “Impact Score” of the startup along the relevant SDGs. The startup is given a scoring between -2 (very negative impact) and +2 (very positive impact) where applicable, addressing both the current and the expected SDG development in the future. Even though not every SDG may be applicable due to the specific sector of the potential investment or a lack of data (see above), UVC Partners interprets each single SDG against the planned investment widely. After having allocated the respective scoring, i.e. -2, -1, 0, +1, +2 along the relevant SDG-dimensions, UVC Partners aggregates the scores to an overall score. UVC Partners excludes any potential investment with a negative aggregate score or with a single SDG-rating equal to -2 (“red flag”). The allocation of scores thereby follows the judgment of the deal team (Principal/Partner + Associate). Based on the fact that deal teams are flexible, and assessments are regularly compared and reviewed, UVC Partners expects that the allocation of individual SDG-scores harmonizes as a common understanding of a -2 score (very negative) and -1 (negative) emerges. That ensures that the SDG rating, while still relatively new, evolves to become more and more objective with every new impact assessment process.  

c) UVC Partners pursues a holistic concept, integrating ESG as described under  2) in different stages of the Funds development. Hereby applies the following procedures:  

- Screening
ESG issues are an integral part of UVC Partners’ screening process. UVC Partners raises awareness amongst the investment team to keep ESG issues in mind and raise red flags early in the investment process.  

- Investment Criteria: ESG & Impact Questionnaire
During the Due Diligence process, potential investee companies are asked to fill out UVC Partners’ ESG & Impact Questionnaires, that contain all questions necessary for the impact assessment process and reflect the SDGs as described under 2). The investment team members fill out the Impact Score Questionnaire. These are used to assess the status regarding ESG & Impact of the company and identify focus areas of improvement to be tackled after investment.  

- Investment Agreement
UVC Partners includes a sustainability clause in all new investment agreements. The company commits to develop an ESG policy and review its strategy to optimize itself towards a higher positive impact within 90 days after signing. The policy entails appropriate measures, actions as well as reporting KPIs to implement and track progress of the ESG policy which will be reviewed and monitored by the Board of Directors on a regular basis.  

- Active Ownership
The board of directors is ultimately responsible for developing the portfolio company’s sustainability strategy and linking evidence-improved ESG performance to the company’s value. UVC Partners plays a critical role in guiding and assisting the portfolio teams to ensure its ongoing compliance with the drafted ESG action plans. They stay informed and respond to new development and risks and regularly oversee the company’s activities through an ESG section in their quarterly reports.  

III. What investment strategy does this financial product follow?


The product is a venture capital fund aiming at equity investments in technology companies in their early stage with a focus on digitization of business processes, transformation of industrial processes, and disruption of mobility.

1. What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product?

The product may not deviate from its investment strategy unless the governing documentation has been revised by partners’ resolution (requiring >75% majority). Therefore, no investments within the excluded sectors will be conducted.

2. How is that strategy implemented in the investment process on a continuous basis?

See above. Also, as part of the due diligence and ongoing investment management, the investment team for the product will initially and continuously monitor whether the sector exclusions are abided by.

3. What is the policy to assess good governance practices of the investee companies?

See above. As part of the due diligence and ongoing investment management, the investment team will review whether a potential investee company has good governance practices in place.

4. What is the asset allocation planned for this financial product?

The product will make investments aligned with the environmental or social characteristics that do not qualify as sustainable investments as defined in the SFDR.  

5. What investments are not in line with the environmental or social characteristics promoted by this product, what is their purpose and are there any minimum environmental or social safeguards?

See above. The product is bound by its investment strategy set out in the governing documents and may not deviate from it. Therefore, all investment will be made in line with the environmental or social characteristics promoted by this product, both on the level of the Portfolio Company as well as other types of exposures to those entities as the case may be.

6. Monitoring of environmental or social characteristics

The product is bound by its investment strategy set out in the governing documents and may not deviate from it. Therefore, all investments will be made in line with the environmental or social characteristics promoted by this product.
UVC Partners is bound to the investment restrictions by § 4 Partnership Agreement. Deviations from certain investment restrictions need the approval of the Investor Advisory Board.
After the investment, UVC Partners plays a critical role in guiding and assisting the portfolio teams to ensure its ongoing compliance with the drafted ESG action plans. They stay informed and respond to new development and risks and regularly oversee the company’s activities through an ESG section in their quarterly reports.  The ESG policy of the portfolio companies will also be reviewed and monitored by the Board of Directors on a regular basis.

7. Methodologies

UVC Partners considers ESG aspects in different stages of the investment process. The Fund conducts its initial assessment during its due diligence as described above. After the investment is made, the ongoing integration of ESG matters will be affected as described under II.1. UVC Partners is currently in the process of evaluating the integration of ESG matters in the investment process with the aim of further developing its ESG policy.

8. Data sources and processing and imitations to methodologies and data

For the impact assessment process as described above UVC Partners is partly reliant on the information collected via the ESG Questionnaires as part of the due diligence. There may be cases where a potential investment cannot provide all the information asked in the ESG Questionnaires. Also, this information is verified only if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that incomplete or false information may remain undetected in certain cases. As the Fund’s investment is made for several years, UVC Partners considers it a priority to establish and maintain a trustful working relationship with the Fund’s portfolio companies in order to ensure compliance with the restrictions described in this section.

9. Due diligence

For the impact assessment process as described above, UVC Partners is partly reliant on the information collected via the ESG Questionnaires as part of the due diligence and thereby follows industry standard procedures to complete the ESG Questionnaires. Where necessary, UVC Partners will engage with external (data-) providers to develop a coherent ESG due diligence in case further information is necessary to validate the investment.  

10. Engagement policies

As the Fund’s investment is made for several years, UVC Partners considers it a priority to establish and maintain a trustful working relationship with the Fund’s portfolio companies in order to ensure compliance with the restrictions described in this section. Further, UVC Partners wants to generate a positive impact beyond Fund’s portfolio companies and share learnings and scientific insights, cooperating with other VCs as well as public institutions and foundations in order to advance the whole ecosystem.  Yet, if UVC Partners encounters deviations against the Fund’s environmental or social investment strategy, including any management procedures applicable to sustainability-related controversies in investee companies, the Fund Management envisages to engage with the respective portfolio company in order to implement a correcting mechanism. As venture capital investor, the influence UVC Partners has on the Fund`s portfolio companies through shareholdings is nonetheless limited; also regarding UVC Partners’ influence on sustainability matters. Therefore, during the pre- as well as the post-investment phase, information on ESG related issues will be collected and evaluated regularly. To this end, we will conduct, where appropriate, training sessions for portfolio companies on how to resolve ESG related issues.

Fund IV

Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)

Date of publication: December 2023

Date of update: December 2023 (addition of sustainability-related disclosures for UVC Fonds IV GmbH & Co. KG)

I. Sustainability risks

Unternehmertum Venture Capital Partners GmbH (LEI: 391200P7DR2TBWQNR653, “UVC Partners”) 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. UVC Partners 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 by using a questionnaire. The results of such assessment are taken into account when the investment decision is being taken. However, UVC Partners remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case UVC Partners can also apply measures to reduce or mitigate any sustainability risks. At all times, UVC Partners 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

UVC Partners does not consider any adverse impacts of its investment decisions on sustainability factors and does not use the sustainability indicators listed in Annex I of the Delegated Regulation (EU) 2022/1288 (as amended from time to time, “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.

UVC Partners has – yet on a voluntary basis – already started to collect the relevant data on the sustainability indicators at portfolio company level. With such voluntary collection, UVC Partners wants to test data quality and data availability at portfolio company level. Given that UVC Partners will invest in early-stage companies with typically small teams and since UVC Partners will only hold minority interests in such companies, it is currently not foreseeable for UVC Partners whether the relevant data can be obtained on a regular basis, putting UVC Partners in a position to take into account principal adverse impacts. Further, there is still only little practical experience with regard to the application of the respective provisions under the SFDR and the RTS, which determine the sustainability indicators to be used and provide details on the mandatory processes to obtain and process the respective data.

If and to the extent that the legal uncertainties will be resolved, a practicable market and administrative practice will evolve and data availability can be ensured, UVC Partners will re-evaluate considering principal adverse impacts of its investment decisions as required by Art. 4 SFDR in due course.

III. Remuneration disclosure

As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”) and a manager of a qualifying venture capital fund as defined in Art. 3 (b) of Regulation (EU) No 345/2013 (“EuVECA-Regulation”), UVC Partners does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB or the EuVECA Regulation.

IV. Sustainability-related disclosures for UVC Fonds IV GmbH & Co. KG

Financial product: UVC Fonds IV GmbH & Co. KG (the “Fund” / der “Fonds”)

LEI: [●not yet allocated●]

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 Fund aspires to integrate responsible investment practices into its entire investment process from origination to exit. 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 UVC Partners 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. Der Fonds strebt nach einer Integration von verantwortungsvollen Investitionspraktiken in den gesamten Investitionsprozess, von der Auflage des Fonds bis zum Exit. 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 UVC Partners 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 excluding certain environmentally and/or socially relevant sectors from the Fund’s investment scope (i.e., by implementing certain investment exclusions in the decision-making process, see section ‘Investment strategy’).

Further, the Fund is committed to invest responsibly as demanded by the UN Principles for Responsible Investment (“PRI”) and aspires to integrate responsible investment practices in its entire investment process:

First, the Fund incorporates several environmental, social and corporate governance (ESG) factors in the investment decision-making process to evaluate and mitigate non-financial risks. The Fund considers a healthy ESG performance a prerequisite for long-term value creation and for positive investment decisions.

Second, beyond minimizing risk, the Fund is committed to proactively pursue investments with a positive social and environmental impact alongside financial return. By following an investment strategy focused on digitization of business processes, transformation of industrial processes and disruption of mobility, the Fund contributes to several UN Sustainable Development Goals (“SDGs”) and particularly addresses SDGs 8, 9, 11, 12 and 13. Yet, the Fund may also consider investments contributing to other SDGs. The Fund pays special attention to the compliance with global standards for equal pay, diversity and inclusion, environmental policies, carbon emissions, waste management, health/safety policies as well as product safety and responsible purchasing policies.

Investment strategy

The purpose of the Fund is to build, hold and manage (including, but not limited to, to divest) a portfolio of equity and equity-related investments in portfolio companies.

The investment focus is primarily targeted at technology-oriented companies. The Fund will invest in portfolio companies which, at the time of the Fund’s initial investment, are innovative companies with high growth potential in their expansion stages (and have been founded and started their business activity within the last ten years) which develop as main business any activity comprising the renewal and enlargement of a range of products and services and their associated markets; the establishment of new methods of design, production, supply and distribution; the introduction of changes in management, work organization, and working conditions and skills of the workforce; and covering technological, non-technological and organizational innovation. The Fund shall primarily provide financing to portfolio companies in their early stage and market entry phase.

The Fund may only make investments in portfolio companies that fall within the aforementioned investment scope of the Fund as defined in the Fund’s limited partnership agreement and, thus, (directly or indirectly) adress SDGs 8, 9, 12 and 13. Yet, the Fund may also consider investments contributing to other SDGs. When identifying suitable investment opportunities, the Fund evaluates every potential investment’s impact against the SDGs as part of every due diligence process. Thereby, the portfolio company is given a scoring between -2 (very negative impact) and +2 (very positive impact) with respect to every single SDG, which forms the basis to assesses an overall score. The Fund may only make an investment in a portfolio company if the aggregate score is not negative and with no single SDG-rating equaling -2.

Further, the Fund is bound by the investment restrictions and limitations set out in the Fund’s limited partnership agreement and shall procure that such requirements, restrictions and limitations are complied with at all times. The Fund shall not 

a) invest in portfolio companies that perform or engage in research and innovation activities considered as illegal in Germany or according to the legislation applicable to the Portfolio Company;

b) invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities

i) that do not qualify as IFE Eligible Final Recipients (as defined in the Fund’s limited partnership agreement);

ii) performing research and innovation activities considered as illegal according to the legislation applicable in the country of the company or entity;

ii) performing the activities excluded as referred to in Article19 of Regulation (EU) No 1291/2013 of the European Parliament and of the Council:

(aa) research activity aiming at human cloning for reproductive purposes;

(bb) research activity intended to modify the genetic heritage of human beings which could make such changes heritable (excluding research relating to cancer treatment of the gonads);

(cc) research activities 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;

iv) whose business activity consists of an illegal economic activity (i.e., any activity which is illegal under the laws or regulations applicable to the company or entity), including, without limitation, human cloning for reproductive purposes;

c) invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies o rother entities which substantially focus on:

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

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

iii) casinos and equivalent enterprises;

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

(aa) aim specifically at

- supporting any activity referred to under i) to iii) of this paragraph c),

- internet gambling and online casinos, or

- pornography; or which
(bb) are intended to enable to illegally

- enter into electronic data networks, or

- download electronic data;

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

(aa) coal mining, processing, transport and storage;

(bb) oil exploration & production, refining, transport, distribution and storage;

(cc) natural gas exploration production, liquefaction, regasification, transport, distribution and storage;

(dd) electric power generation exceeding the Emissions Performance Standard (i.e., 250 grams of CO2 per kWh of electricity), applicable to fossil fuel-fired power and cogeneration plants, geothermal and hydropower plants with large reservoirs;

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

(aa) manufacture of organic and other inorganic basic chemicals (NACE 20.13);

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

(cc) manufacture of fertilisers and nitrogen compounds (NACE 20.15);

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

(ee) manufacture of cement (NACE 23.51);

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

(gg) manufacture of tubes, pipes, hollow profiles and related fittings, of steel (NACE 24.30);

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

(ii) aluminum production (NACE 24.42);

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

(kk) conventionally-fuelled air transport and, airports and service activities incidental to conventionally-fuelled air transportation (sub-activities of NACE 51.10, 51.21 and 51.23).

Notwithstanding the above, investments in sectors mentioned in section vi) items (aa) – (kk) including, shall be allowed if confirmed that the investment either (A) qualifies as environmentally sustainable investment as defined in the EU Taxonomy, or (B) is eligible under the European Investment Fund’s Climate Action &Environmental Sustainability (CA&ES) criteria for green financing.

The Fund’s investment strategy is continuously implemented as part of the investment process: Each investment opportunity will be reviewed as part of the due diligence process in light of the Fund’s investment strategy, in particular with regard to the investment exclusions as well as the SDGs. After an investment, i.e., during the holding period, the Fund will regularly monitor its portfolio companies and support them when and where deemed relevant.

Good governance practices are assessed through a questionnaire as part of every due diligence process prior to any investment made by the Fund. 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 and/or social characteristics. The Fund 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

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. Accordingly, the Fund undertakes to monitor (compliance with) its environmental and/or social characteristics on an ongoing basis. Prior to making an investment, the Fund assesses the attainment of its environmental and/or social characteristics with respect to every (potential) portfolio company. The Fund uses the sustainability indicators ‘No investments in the area of investment exclusions’ and ‘Direct or indirect contribution to SDG 8, 9, 11, 12 and/or 13, or other/additional SDGs’, and collects respective data at portfolio company level in order to assess and monitor the initial and ongoing compliance with such characteristics. During the holding period, the Fund obtains the relevant information in quarterly reports from its portfolio companies and will consult with them in regular intervals and carry out further checks if there are indications of potential issues with the Fund’s ESG approach. Moreover, the ESG policy of the portfolio companies will be reviewed and monitored by the Fund on a regular basis. External monitoring mechanisms are not in place.

Methodologies for environmental or social characteristics

The Fund applies qualitative assessments with respect to its environmental and/or social characteristics. The Fund 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 questionnaire. Through this questionnaire, the investment exclusions, good governance practices and contribution towards the SDGs are identified and evaluated. Based on the results of this assessment, the Fund identifies whether the environmental and/or social characteristics promoted by the Fund 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. By using the sustainability indicator ‘No investments in the area of exclusions’, the Fund assesses and ensures the portfolio companies’ ongoing compliance with its investment exclusions. Hence, the Fund measures and evaluates the attainment of its environmental and/or social characteristics on an ongoing basis.

Data sources and processing

In order to attain each of the environmental and/or social characteristics promoted by the Fund, a questionnaire is completed by the (potential) portfolio companies in the course of the due diligence process conducted prior to each investment. Where necessary, the Fund will engage with external (data) providers to develop a coherent ESG due diligence in case further information is necessary to validate the potential investment. Moreover, during the holding period, the portfolio companies provide the Fund with quarterly reports. Hence, most data is obtained from the (potential) portfolio companies and around [●] % of the relevant data is estimated or supplemented by external (data) providers. Further, purely 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. 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 from the (potential) portfolio companies as well as the data supplemented by external (data) providers 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, the data estimated or supplemented by external (data) providers might – by the very nature of estimations – not reflect the actual data situation at portfolio company level. Further limitations, in particular with regard to the accuracy of the data and reliability of the data sources used, are currently not foreseeable. 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 data quality and compliance with the environmental and/or social characteristics promoted by the Fund.

Due diligence

In order to attain the aforementioned environmental and/or social characteristics, the Fund carefully selects its portfolio companies during the investment decision-making process. The Fund conducts a due diligence on every (potential) portfolio company. As part of this due diligence, the Fund carefully reviews how a (potential) investment relates to the environmental and/or social characteristics promoted by the Fund. The Fund incorporates inclusion (positive screening with respect to the SDGs) and 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 questionnaire 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 the Fund. In order to attain the environmental and/or social characteristics promoted by the Fund, the Fund may use the following measures to engage with its portfolio companies:

• Inclusion of sustainability clauses in new investment agreements (whereby the portfolio companies commit themselves to develop an ESG policy and review and optimize their strategy towards a higher positive impact within 90 days after signing; such ESG policy must entail appropriate measures, actions and reporting obligations of KPIs to implement and track progress of the ESG policy);

• Development and monitoring of key performance indicators related to ESG criteria at portfolio company level;

• Conduction of training sessions for and with the portfolio companies on how to resolve ESG-related issues;

• Exercise of (minority) shareholder rights in the portfolio companies.

Further, the Fund will respond with individual measures when becoming aware of ESG-related incidents or controversies at portfolio company level. Yet, it remains at the sole discretion of the Fund to determine which efforts are appropriate and proportionate in light of the size and strategic importance of the respective portfolio company as well as the transactional context.Designated reference benchmarkNo index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by the Fund.


Growth Opportunities Fund I

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Product disclosure for financial products referred to in Article 8(1) and 10 of Regulation (EU) 2019/2088 (SFDR) for UVC Growth Opportunities Fund I GmbH & Co. KG

Unternehmertum Venture Capital Partners GmbH (“UVC Partners”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”).

UVC Partners has updated its ESG-Policies since the establishment of UVC Growth Opportunities Fund I GmbH & Co. KG. The following disclosure describes the updated ESG-Policy of as of February 2022.

I. Summary

UVC Partners considers certain environmental and social characteristics as part of its investment decisions but does not seek to make sustainable investments as defined in the SFDR. UVC Partners aspires to integrate responsible investment practices into its entire investment process from origination to exit. The consideration of environmental and social characteristics is therefore carried out through certain sector exclusions as well as the integration of ESG factors in the investment decision-making process, the investment agreements and as part of an active ownership. UVC Partners monitors and reviews the ESG - Policy as described below regularly to ensure that the promoted environmental and social characteristics are met.

UVC Partners berücksichtigt bei seinen Investitionsentscheidungen bestimmte ökologische und soziale Merkmale, strebt jedoch keine nachhaltigen Investitionen im Sinne der SFDR an. UVC Partners strebt nach einer Integration von verantwortungsvollen Investitionspraktiken in den gesamten Investitionsprozess, von der Auflage des Fonds bis zum Exit. Die Berücksichtigung ökologischer und sozialer Merkmale erfolgt daher durch bestimmte Sektorausschlüsse, die Integration von ESG-Faktoren in den Investitionsentscheidungsprozess, durch Investitionsvereinbarungen und als Teil einer aktiven Eigentümerschaft. UVC Partners überprüft und überarbeitet die ESG-Politik regelmäßig, um sicherzustellen, dass die beworbenen ökologischen und sozialen Merkmale berücksichtigt werden.

II. This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment.

No. Reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the financial product.

1. What environmental and/or social characteristics are promoted by this financial product?

Investment Restrictions:
The governing documentation underlying this product (in particular, the limited partnership agreement of the product) provides for various sector exclusions relating to environmental and/or social characteristics, such as fossil fuel-based energy production or energy-intensive and/or high CO2-emitting industries.

Other:
Also, UVC Partners is committed to investing responsibly as demanded by the Principles for Responsible Investment (PRI) and it is UVC Partners’ ambition to develop companies into successful but sustainable businesses, who follow the Ten principles of the UN Global Compact. UVC Partners therefore aspires to integrate responsible investment practices into its entire investment process; from origination to exit, and to lead by example within its own internal operations. UVC Partners considers two dimensions in his responsible investment practice:

a) ESG: UVC Partners uses Environmental, Social and Corporate Governance (ESG) factors to evaluate and mitigate non-financial risk. A healthy ESG performance is a prerequisite for long-term value creation and for a positive investment decision.

b) Impact: As a financial investor investing into the global leaders of the future, UVC Partners’ responsibility goes beyond minimizing risk. UVC Partners wants to proactively pursue investments with a positive social and environmental impact alongside financial return. Through UVC Partners’ investment focus areas (digitization of business processes, transformation of industrial processes and disruption of mobility) most of the investments particularly address numbers 8, 9, 11, 12 and 13 of the UN’s Sustainable Development Goals (SDGs). In case of a potential investment where other SDGs might be relevant, UVC Partners will exceptionally also consider other additional SDGs, if the necessary data has been provided or can be obtained. UVC Partners pays special attention to the compliance with global standards for equal pay, diversity and inclusion, environmental policies, carbon emissions, waste management, health/safety policies as well as product safety and responsible purchasing policies.

Impact assessment process:
UVC Partners evaluates every potential investment’s impact against the Development Goals published by the United Nations (“SDG”) as described above. Therefore, as part of every due diligence (see also “Investment Criteria: ESG & Impact Questionnaire” under 3), UVC Partners assesses an “Impact Score” of the startup along the relevant SDGs. The startup is given a scoring between -2 (very negative impact) and +2 (very positive impact) where applicable, addressing both the current and the expected SDG development in the future. Even though not every SDG may be applicable due to the specific sector of the potential investment or a lack of data (see above), UVC Partners interprets each single SDG against the planned investment widely. After having allocated the respective scoring, i.e., -2, -1, 0, +1, +2 along the relevant SDG-dimensions, UVC Partners aggregates the scores to an overall score. UVC Partners excludes any potential investment with a negative aggregate score or with a single SDG-rating equal to -2 (“red flag”). The allocation of scores thereby follows the judgment of the deal team (Principal/Partner + Associate). Based on the fact that deal teams are flexible, and assessments are regularly compared and reviewed, UVC Partners expects that the allocation of individual SDG-scores harmonizes as a common understanding of a -2 score (very negative) and -1 (negative) emerges. That ensures that the SDG rating, while still relatively new, evolves to become more and more objective with every new impact assessment process. 

c) UVC Partners pursues a holistic concept, integrating ESG as described under 2) in different stages of the Funds development. Hereby applies the following procedures: 

- Screening
ESG issues are an integral part of UVC Partners’ screening process. UVC Partners raises awareness amongst the investment team to keep ESG issues in mind and raise red flags early in the investment process. 

- Investment Criteria: ESG & Impact Questionnaire
During the Due Diligence process, potential investee companies are asked to fill out UVC Partners’ ESG & Impact Questionnaires, that contain all questions necessary for the impact assessment process and reflect the SDGs as described under 2). The investment team members fill out the Impact Score Questionnaire. These are used to assess the status regarding ESG & Impact of the company and identify focus areas of improvement to be tackled after investment.

- Investment Agreement
UVC Partners includes a sustainability clause in all new investment agreements. The company commits to develop an ESG policy and review its strategy to optimize itself towards a higher positive impact within 90 days after signing. The policy entails appropriate measures, actions as well as reporting KPIs to implement and track progress of the ESG policy which will be reviewed and monitored by the Board of Directors on a regular basis. 

- Active Ownership
The Board of Directors is ultimately responsible for developing the portfolio company’s sustainability strategy and linking evidence improved ESG performance to the company’s value. UVC Partners plays a critical role in guiding and assisting the portfolio teams to ensure its ongoing compliance with the drafted ESG action plans. The stay informed and respond to new development and risks and regularly oversee the company’s activities through an ESG section in their quarterly reports.

III. What investment strategy does this financial product follow?


The product is a venture capital fund aiming at equity investments in technology companies in their growth stage with a focus on digitization of business processes, transformation of industrial processes, and disruption of mobility.

1. What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product?

The product may not deviate from its investment strategy unless the governing documentation has been revised by partners’ resolution (requiring >75% majority). Therefore, no investments within the excluded sectors will be conducted.

2. How is that strategy implemented in the investment process on a continuous basis?

See above. Also, as part of the due diligence and ongoing investment management, the investment team for the product will initially and continuously monitor whether the sector exclusions are abided by.

3. What is the policy to assess good governance practices of the investee companies?

See above. As part of the due diligence and ongoing investment management, the investment team will review whether a potential investee company has good governance practices in place.

4. What is the asset allocation planned for this financial product?

The product will make investments aligned with the environmental or social characteristics that do not qualify as sustainable investments as defined in the SFDR.

5. What investments are not in line with the environmental or social characteristics promoted by this product, what is their purpose and are there any minimum environmental or social safeguards?

See above. The product is bound by its investment strategy set out in the governing documents and may not deviate from it. Therefore, all investment will be made in line with the environmental or social characteristics promoted by this product, both on the level of the Portfolio Company as well as other types of exposures to those entities as the case may be.

6. Monitoring of environmental or social characteristics

The product is bound by its investment strategy set out in the governing documents and may not deviate from it. Therefore, all investments will be made in line with the environmental or social characteristics promoted by this product.
UVC Partners is bound to the investment restrictions by § 4 Partnership Agreement. Deviations from certain investment restrictions need the approval of the Investor Advisory Board.
After the investment, UVC Partners plays a critical role in guiding and assisting the portfolio teams to ensure its ongoing compliance with the drafted ESG action plans. They stay informed and respond to new development and risks and regularly oversee the company’s activities through an ESG section in their quarterly reports.  The ESG policy of the portfolio companies will also be reviewed and monitored by the Board of Directors on a regular basis.

7. Methodologies

UVC Partners considers ESG aspects in different stages of the investment process. The Fund conducts its initial assessment during its due diligence as described above. After the investment is made, the ongoing integration of ESG matters will be affected as described under II.1. UVC Partners is currently in the process of evaluating the integration of ESG matters in the investment process with the aim of further developing its ESG policy.

8. Data sources and processing and imitations to methodologies and data

For the impact assessment process as described above UVC Partners is partly reliant on the information collected via the ESG Questionnaires as part of the due diligence. There may be cases where a potential investment cannot provide all the information asked in the ESG Questionnaires. Also, this information is verified only if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that incomplete or false information may remain undetected in certain cases. As the Fund’s investment is made for several years, UVC Partners considers it a priority to establish and maintain a trustful working relationship with the Fund’s portfolio companies in order to ensure compliance with the restrictions described in this section.

9. Due diligence

For the impact assessment process as described above, UVC Partners is partly reliant on the information collected via the ESG Questionnaires as part of the due diligence and thereby follows industry standard procedures to complete the ESG Questionnaires. Where necessary, UVC Partners will engage with external (data-) providers to develop a coherent ESG due diligence in case further information is necessary to validate the investment. 

10. Engagement policies

As the Fund’s investment is made for several years, UVC Partners considers it a priority to establish and maintain a trustful working relationship with the Fund’s portfolio companies in order to ensure compliance with the restrictions described in this section. Further, UVC Partners wants to generate a positive impact beyond Fund’s portfolio companies and share learnings and scientific insights, cooperating with other VCs as well as public institutions and foundations in order to advance the whole ecosystem.  Yet, if UVC Partners encounters deviations against the Fund’s environmental or social investment strategy, including any management procedures applicable to sustainability-related controversies in investee companies, the Fund Management envisages to engage with the respective portfolio company in order to implement a correcting mechanism. As venture capital investor, the influence UVC Partners has on the Fund`s portfolio companies through shareholdings is nonetheless limited; also regarding UVC Partners’ influence on sustainability matters. Therefore, during the pre- as well as the post-investment phase, information on ESG related issues will be collected and evaluated regularly. To this end, we will conduct, where appropriate, training sessions for portfolio companies on how to resolve ESG related issues.