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 IIIDownload PDF
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.
Growth Opportunities Fund IDownload PDF
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.