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Sustainability Related Disclosures
SEF Ventures Management GmbH (“SEF Ventures ”) is an alternative investment fund manager within the meaning of the German Capital Investment Act (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 ”). The following disclosures have been carefully prepared in accordance with the SFDR, the Commission Delegated Regulation (EU) 2022/1288 and additional guidance issued by the European Commission, the European Supervisory Authorities and the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht). However, certain ambiguities remain in the interpretation of the regulatory framework, and there are ongoing discussions regarding the need to amend the SFDR. As a result, the text below may need to be adjusted in response to future interpretative guidance or legislative changes.
Art. 3 SFDR – Integration of sustainability risks
SEF Ventures integrates Sustainability Risks into its investment decisions as outlined below. “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. Sustainability Risks are not only limited to the financial situation and operations of the Portfolio Company; they could also have an effect on the market environment, competitors, or regulatory landscape. SEF Ventures is therefore considering Sustainability Risks in the due diligence process of the investment and regularly following up on the risk assessment during the investment period.
Environmental Sustainability Risks (incl. climate-related risks) are categorized into physical risks and transition risks. Physical risks are e.g., extreme weather conditions which could cause a disruption of the supply chain of the Portfolio Company or lead to a significant increase in e.g., raw material prices. Transition risks are e.g., regulatory risks, which could lead to e.g., an increase in energy prices which is impacting the financial situation of a Portfolio Company. A shift in technology could lead to e.g., stranded assets or significant changes in the market potential of a technology/product or service. Depending on the stage of the investment, physical risks are more or less material. E.g., for early-stage investments, physical risks are not considered, in case of investments which include a pilot stage physical risks are considered for a site-selection. Transition and physical risks may also interact in unpredictable ways, a complexity that is not accounted for in the due diligence process.
Sustainability Risks could also stem from social and governance issues and cause a potential or actual negative impact on the financial value of an investment and the reputation of the Portfolio Company and/or the Fund.
Such issues could be tax fraud or fines, imposed to the Portfolio Company due to incompliance with regulations.
Risk Management Process:
Risk Identification:
SEF Ventures applies exclusion criteria as a first filter in the risk management process. During the pre-investment due diligence phase the potential Portfolio Company is asked to indicate Sustainability Risks which could affect their operations or supply chains and markets.
Sustainability Risk Assessment
Based on the input of the Portfolio Company and enriched by internal references a Sustainability Risk Assessment on the impact of the technology/product/service which is offered by the potential Portfolio Company is conducted, including the life cycle stages of the technology/product or service. In addition a Risk Assessment for ESG (environmental, social, and governance) related risks stemming from the operations of the potential Portfolio Company is conducted.
Consequences of Sustainability Risk Assessment
In case significant and material risks are identified, the investment is not further pursued. A scoring system is applied to evaluate the significance and importance of risks;
In cases where SEF Ventures holds a lead investor position or has sufficient influence, the following process is applied to encourage Portfolio Companies to comply.
Development of Action Plan and Targets:
At the beginning of the investment period, a risk mitigation plan for manageable risks, which were identified during the due diligence phase, is developed together with the Portfolio Company and targets are agreed upon. Regular follow-ups will provide information on the progress of the action plan and lead to respective measures. Beyond this, SEF Ventures employs and will consult experienced experts to obtain a holistic risk perspective on the investment.
SEF Ventures carefully evaluates and strives to mitigate the impact of potential sustainability-related risks on the investments during the due diligence phase and during the investment period to minimize undesired potentially negative effects on the financial evaluation of the Portfolio Companies.
Art. 4 – Consideration of principal adverse impacts
SEF Ventures considers principal adverse impacts on an entity level. “Principal Adverse Impacts” (“PAI ”) are impacts of investment decisions on sustainability factors, i.e., negative impacts on environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.
SEF Ventures strives to consider all principle adverse impact indicators (“PAIIs ”) of Table 1 of Annex I of the Commission Delegated Regulation (EU) 2022/1288 (“SFDR RTS ”) and selected PAIIs from Annex I Tables 2 and 3 of the SFDR RTS.
The selection of Table 2 and 3 PAIIs is done based on a materiality assessment considering the sector of the investment, the stage of the investment and the life cycle stage.
For the Sustainable Economy Fund I GmbH & Co. KG, SEF Ventures applies a standardized Sustainability Assessment Questionnaire, which is discussed with potential portfolio companies during the Due Diligence (“DD ”) phase.
During the investment period an ESG Assessment is applied. The portfolio companies regularly report on the status and progress regarding the PAIIs, as discussed during the DD phase and during an annual sustainability meeting. The consolidated results of the ESG assessments of the portfolio companies will be published annually in the periodic report and on the website of SEF Ventures in accordance with legal requirements.
SEF Ventures is currently not yet a signatory partner for e.g. UN Global Compact but the Partnership applies the principles of OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights in the ESG assessment.
The availability of data is very much dependent on the stage of the company. In seed phase investments the likelihood to obtain reporting data with a reasonable effort might be lower than for Series A phase companies. In case the data are not available, SEF Ventures will transparently disclose this with the help of comments.
Art. 5 – Remuneration Disclosure
As a registered alternative investment fund manager within the meaning of the German Capital Investment Act (Kapitalanlagegesetzbuch, KAGB), SEF Ventures does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.
Status: July 2024
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Privacy Policy
How to contact the appropriate authority
This privacy policy applies to data processing by:
Responsible authority:
SEF Ventures Management GmbH
Schlüterstr. 38, 10629 Berlin, Germany (Registered office of the company)
Goethestr. 43, 80336 München, Germany
E-mail: talkto@sef.ventures
Phone: +49 157 7173 0899
What kind of data is collected and processed?
When visiting our website at sef.ventures , certain data will automatically be sent to the server of our website by the browser you use. This data is stored temporarily in a log file. The following information will be stored until it is deleted automatically:
IP address or the name of the device that accesses this website,
timestamp of the access,
name and URL or the accessed file,
the website from which you accessed this website (referrer URL),
used browser and probably the operating system of your device, and
the name of your access provider.
This data is processed by us in order to fullfill the following aims:
ensuring a smooth connection to the website,
ensuring a comfortable use of our website,
evaluating system security and stability, or
for other administrative purposes.
We use the following hosting service provider for the provision of this website:
IONOS SE
Elgendorfer Str. 57
56410 Montabaur, Germany
E-mail: info@ionos.de
This hosting service provider is recipient of your personal data and acts as processor on behalf of us. The purpose of using this hosting service provider is not to have to keep a server on our premises in accordance with Art. 6(1)1f GDPR.
Cookies used by this website
This website does not use any cookies.
Transfer of your data to third parties
Your personal data will not be transferred to third parties for purposes other than those listed below.
We only pass on your personal data to third parties if:
you have given your express consent to this in accordance with Art. 6 para. 1 sentence 1 lit. a GDPR,
the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. f GDPR is necessary for the assertion, exercise or defense of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in not disclosing your data,
in the event that there is a legal obligation for the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c GDPR, or
this is legally permissible and necessary for the processing of contractual relationships with you in accordance with Art. 6 para. 1 sentence 1 lit. b GDPR.
Rights of affected persons
You have the right:
in accordance with Art. 15 GDPR, to request information about your personal data processed by us. In particular, you can request information about the purposes of processing, the category of personal data, the categories of recipients to whom your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of appeal, the origin of your data if it was not collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information on its details;
in accordance with Art. 16 GDPR, to immediately request the correction of incorrect or incomplete personal data stored by us;
in accordance with Art. 17 GDPR, to demand the erasure of your personal data stored by us, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims;
in accordance with Art. 18 GDPR, to demand the restriction of the processing of your personal data if the accuracy of the data is disputed by you, the processing is unlawful, but you refuse to delete it and we no longer need the data, but you need it to assert, exercise or defend legal claims or you have lodged an objection to the processing in accordance with Art. 21 GDPR;
in accordance with Art. 20 GDPR, to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format or to request that it be transmitted to another controller;
in accordance with Art. 7 para. 3 GDPR, to withdraw your consent once given to us at any time. As a result, we may no longer continue the data processing based on this consent in the future, as well as
to lodge a complaint with a supervisory authority in accordance with Art. 77 GDPR. As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our company headquarters.
Right to object
If your personal data are processed on the basis of legitimate interests pursuant to Art. 6 para. 1 sentence 1 GDPR, you have the right to object to the processing of your personal data pursuant to Art. 21 GDPR, provided that there are reasons for this arising from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying any particular circumstances. If you wish to exercise your right of revocation or objection, it is sufficient to send an e-mail to talkto@sef.ventures .
Data security
We use suitable technical and organizational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or unauthorized access by third parties. Our security measures are continuously improved in line with technological developments.
Validity of this privacy policy
This privacy policy is valid as from November 2023.