SFDR entity level

SFDR Website statement – Manager BigCircle Ventures Fund

The world needs greentech innovations to reach net-zero and circularity, but a wealth of research inventions never gets used at scale. BigCircle Ventures brings a unique flow of early-stage innovations to the market that would otherwise stay untouched on a shelf, hidden in a university, research institute or company lab. By using a long-proven model for discovering, nurturing and funding innovations, we have both impact and financial results as key focus for our investors.

In achieving the goals of the BigCircle Ventures Group we have a Venture Builder and a Fund Manager. The first is a hands-on team of professionals which scouts, selects and fosters new innovations towards successful ventures. The latter manages funds aimed at providing capital to effectively scale the innovations built by the Venture Builder.

Sustainability risks (SFDR Article 3)

When selecting and monitoring the portfolio companies, as part of the investment due diligence and portfolio management procedures, the Manager applies its (to be developed) ESG (Environmental, Social, Governance) Policy in respect of each potential investment. For this assessment, the Manager makes use of the information gathered and analysis made by the Venture Builder (Operating Partner) as part of the Venture Building Process. As part of this assessment, the fund determines whether the targeted Portfolio Company meets the requirements of a Sustainable Investment and whether there are any ‘red flags’ (for example, unmanageable ESG risks) that should prevent the Manager from proceeding with the potential transaction with the targeted Portfolio Company. By means of the application of the aforementioned assessment, the fund aims to identify the most important Sustainability Risks and opportunities and to identify and define appropriate mitigation activities. Such appropriate mitigation activities and measures to be applied in the specific situation and under the relevant circumstances is further developed and embedded in the Risk Management Policy of the Manager.

Consideration of principal adverse impacts (SFDR Article 4)

On the entity (manager) level of BigCircle Venture Fund, we do not assess Principal Adverse Impacts (PAIs) in line with SFDR (Article 4). This is because our portfolio companies are start-ups and too small to be obligated to publish this data, making it impossible to ensure accurate and complete reporting for the fund. However, when sufficient data becomes available, we will annually monitor all PAIs, including the 14 mandatory indicators, in accordance with SFDR. We will periodically review whether our portfolio companies report this data and will start considering adverse impacts at the entity level once they do.

At the fund level, we do consider adverse impacts (Article 7). Before investing, we identify PAIs that may be relevant to the company and collect data on these during the due diligence process. Given that the companies we consider are early-stage and may not have this data readily available, qualitative data is also acceptable at this stage. Additionally, we assess other significant adverse sustainability impacts of our potential portfolio companies as part of a general ESG risk assessment during due diligence and monitor these risks post-investment.

To conclude, due to our focus on early-stage (startup) investments in companies with sustainable objectives, we generally do not expect significant adverse impacts on these indicators. Our typical investment companies are also likely to be inherently aware of their potential adverse impacts and strive to mitigate them where possible.

Remuneration policy and integration of sustainability risks (SFDR Article 5)

As a fund manager, we implement a remuneration policy that ensures BigCircle Ventures maintains a controlled compensation practice. This approach aligns with and promotes effective risk management, preventing excessive risk exposure for both the fund manager and the investors in our funds. Our remuneration policy also aligns with the integration of sustainability risks. The variable compensation for individuals working under the BigCircle Ventures fund manager is determined based on criteria including how well they act in the best interests of the BigCircle Ventures fund, the Funds, and the investors. This includes adherence to applicable internal policies and procedures, encompassing relevant investment selection and risk management policies that incorporate sustainability risks