Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)
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 accordance with the SFDR as well as the Level 2 Delegated Regulation to the SFDR (EU) 2022/1288 (“RTS”).
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 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.
I. Sustainability risks
UVC Partners (LEI:391200P7DR2TBWQNR653) 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 Partner scan 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 principal adverse impacts of its investment decisions on sustainability factors within the meaning of Art. 4 SFDR and, hence, does not use the sustainability indicators listed in Annex I of the RTS to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. Given that 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 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. Therefore, substantial legal uncertainties would remain when applying those provisions to the strategies pursued by UVC Partners. 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. 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) 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. 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 July 2024.
Fund IIIDownload PDF
The sustainability-related disclosures relating to UVC Fonds IV GmbH & Co. KG (“Fund IV”) (UVC III: 3912009SWYJMS0RVSB16) apply accordingly to Fund III except for the investment exclusions. With respect to investment exclusions, Fund III shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to portfolio companies whose business activity consists of:
a) an illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Fund or the relevant company or entity, including without limitation, human cloning for reproduction purposes);
b) the production of and trade in tobacco and distilled alcoholic beverages and related products;
c) the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies;
d) casinos and equivalent enterprises;
e) the research, development or technical applications relating to electronic data programs or solutions, which
i) aim specifically at supporting any activity referred to above; internet gambling and online casinos; or pornography; or which
ii) are intended to enable to illegally enter into electronic data networks; or download electronic data.
In addition, when providing support to the financing of the research, development or technical applications relating to (A) human cloning for research or therapeutic purposes or (B) genetically modified organisms ("GMOs"), UVC Partners shall ensure the appropriate control of legal, regulatory and ethical issues linked to such human cloning for research or therapeutic purposes and/or GMOs.
Fund III shall not invest in companies which, at the time of Fund III’s initial investment, have their seat in a country against which an embargo is imposed by the United Nations, the European Union or the USA, unless compliance with such embargo would violate binding German law or EU law (in particular the rules of foreign trade legislation and Regulation (EG) 2271/96).
Fund IV(UVC IV: 391200M6DUOOEJAIA298)
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 Portfolio unternehmen 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 beschriebenenHandlungen 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) address SDGs 8, 9, 12and 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 notnegative and with no single SDG-rating equaling -2.
Further, the Fund is bound by the investmentrestrictions and limitations set out in the Fund’s limited partnershipagreement and shall procure that such requirements, restrictionsand limitations are complied with at all times. TheFund 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 EligibleFinal 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;
iii) performing the activities excluded as referred to in Article19 ofRegulation (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 thepurpose of research or for the purpose of stem cell procurement, including bymeans 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 thecompany or entity), including, without limitation, human cloning forreproductive purposes;
c) invest, guarantee or otherwise provide financial or other support,directly or indirectly, to companies o rother entities which substantiallyfocus on:
i) the production of and trade intobacco and distilled alcoholic beverages and related products;
ii) the production of and trade in weapons and ammunition of any kind andfinancing of these activities, it being understood that this restriction doesnot apply to the extent such activities are part of or accessory to explicitEuropean Union policies;
iii) casinos and equivalent enterprises;
iv) the research, development or technical applications relating toelectronic data programs or solutions, which
(aa) aim specifically at
− supporting any activity referred tounder i) to iii) of this paragraph c),− internet gambling and onlinecasinos, 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, ofsteel (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 NACE30.30);
(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 &EnvironmentalSustainability (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 theSDGs are identified and evaluated. Based on the results of this assessment, theFund 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 byusing 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 impactwithin 90 days after signing; such ESG policy must entail appropriatemeasures, actions and reporting obligations of KPIs to implement and trackprogress of the ESG policy);
- Development and monitoring of key performanceindicators related to ESG criteria at portfolio company level;
- Conduction of training sessions for and with theportfolio companies on how to resolve ESG-related issues;
- Exercise of (minority) shareholder rights in the portfoliocompanies.
Further, the Fund will respond with individual measures when becoming aware of ESG-relatedincidents or controversies at portfolio company level. Yet, it remains at thesole discretion of the Fund to determine which efforts are appropriate andproportionate in light of the size and strategic importance of the respectiveportfolio company as well as the transactional context.
Designated reference benchmark
No index has been designated as a reference benchmark to meet theenvironmental or social characteristics promoted by the Fund.
Growth Opportunities Fund IDownload PDF
(Growth: 39120039EZNBUQO7SR68)
The sustainability-related disclosures relating to UVC Fonds IV GmbH & Co. KG (“Fund IV”) apply accordingly to Growth I except for the investment strategy and the investment exclusions.
Growth I may only pursue investments in companies in which a previous UVC fund (UnternehmerTUM-FondsI GmbH & Co. KG, UnternehmertumVC Fonds II GmbH & Co. KG and Unternehmertum VC Fonds III GmbH & Co. KG) (i) directly or indirectly already holds an investment of any type or (B) makes an investment alongside Growth I. However, Growth I may only invest in a UVC portfolio company to the extent such investment opportunity is not pursued by the respective previous fund.
With respect to investment exclusions, Growth I shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to portfolio companies whose business activity consists of:
a) an illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Fund or the relevant company or entity, including without limitation, human cloning for reproduction purposes);
b) the production of and trade in tobacco and distilled alcoholic beverages and related products;
c) the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies;
d) casinos and equivalent enterprises;
e) the research, development or technical applications relating to electronic data programs or solutions, which
i) aim specifically at supporting any activityreferred to above; internet gambling and online casinos; or pornography; orwhich
ii) are intended to enable to illegally enter into electronic data networks; or download electronic data.
f) fossil fuel-based energy production and related activities, as follows:
i) Coal mining, processing, transport and storage;
ii) Oil exploration & production, refining, transport, distribution and storage;
iii) Natural gas exploration & production, liquefaction, regasification, transport, distribution and storage;
iv) Electric power generation exceeding the Emissions Performance Standard (i.e. 250 grams of CO2e per kWh of electricity), applicable to fossil fuel-fired power and cogeneration plants, geothermal and hydropower plants with large reservoirs.
g) energy-intensive and/or high CO2-emitting industries, as follows:
i) Manufacture of other inorganic basic chemicals(NACE 20.13)
ii) Manufacture of other organic basic chemicals(NACE 20.14)
iii) Manufacture of fertilizers and nitrogen compounds (NACE 20.15)iv) Manufacture of plastics in primary forms (NACE20.16)
v) Manufacture of cement (NACE 23.51)
vi) Manufacture of basic iron and steel and of ferroalloys (NACE 24.10)vii) Manufacture of tubes, pipes, hollow profiles and related fittings, of steel (NACE 24.20)
viii) Manufacture of other products of first processing of steel (NACE 24.30, incl. 24.31-24.34)
ix) Aluminium production (NACE 24.42)
x) Manufacture of conventionally-fuelled aircraft and related machinery (sub-activity of NACE 30.30)
xi) Conventionally-fuelled air transport and airports and service activities incidental to conventionally-fuelled air transportation (sub-activities of NACE 51.10, 51.21and 52.23).
Notwithstanding the above, investments in sectors mentioned in section (vii) items i) – xi) included, shall be allowed if UVC Partners confirms that the final recipient transaction either (i) qualifies as environmentally sustainable investments as defined in the “EU taxonomy for sustainable activities” (Regulation (EU)2020/852, as amended from time to time) or (ii) is eligible under EIF’s Climate Action & Environmental Sustainability (CA&ES) criteria for green financing.
In addition, when providing support to the financing of the research, development or technical applications relating to (A) human cloning for research or therapeutic purposes or (B) genetically modified organisms ("GMOs"), UVC Partners shall ensure the appropriate control of legal, regulatory and ethical issues linked to such human cloning for research or therapeutic purposes and/or GMOs.
Growth I shall not invest in companies which, at the time of Growth I’s initial investment, have their seat in a country against which an embargo is imposed by the United Nations, the European Union or the USA, unless compliance with such embargo would violate binding German law or EU law (in particular the rules of foreign trade legislation and Regulation (EG) 2271/96).
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