SFDR

DISCLOSURES PURSUANT TO THE SUSTAINABLE FINANCE DISCLOSURE REGULATION (EU) 2019/2088

Date of publication: May 2025

I. Sustainability risks

AENU Management GmbH (“AENU Management”) (LEI: [in process]) 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.

AENU Management considers sustainability risks as part of its due diligence process prior to any investment. This also includes an assessment of sustainability risks. Material ESG topics are identified for each potential investment. Once material issues are identified, an in-depth ESG analysis is conducted based on self-reported data of the startups obtained from an ESG questionnaire. If there is an unmitigated risk exposure AENU Management engages with the respective company and, if needed, discontinues the investment process. AENU Management may also engage with the relevant company for it to apply measures to reduce or mitigate any sustainability risks. At all times, AENU Management will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

II. Remuneration policies

As a registered AIFM 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 article 3 (b) of Regulation (EU) No. 345/2013 (“EuVECA-Regulation”), AENU Management does not have and does not need to have a remuneration policy in accordance with the requirements of the KAGB.

III. Statement on principal adverse impacts of investment decisions on sustainability factors

Summary

AENU Management considers principal adverse impacts of its investment decisions on sustainability factors. This is the first website statement on principal adverse impacts on sustainability factors within the meaning of Art. 4 SFDR.

Sustainability factors include environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. AENU Management considers the mandatory indicators as set forth in no. 1 to 14 of Table 1 of Annex I of the Delegated Regulation (EU) 2022/1288 (“RTS”) as well as three optional indicators from Table 2 and Table 3 of Annex I of the RTS as stipulated below:

Investments in companies without carbon emission reduction initiatives (Table 2, No. 4)
Investments in companies producing chemicals (Table 2, No. 9)
Number of days lost to injuries, accidents, fatalities, or illness (Table 3, No. 3)

AENU Management obtained its registration within the meaning of section 2 (4) in conjunction with section 44 KAGB from the German Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht – “BaFin”) on 24 February 2025.

The first closing of AENU II GmbH & Co. KG GmbH & Co. KG (“AENU Fund II”), the first AIF to be managed by AENU Management, is not expected to take place prior to the last quarter of 2025. Accordingly, as of the date hereof, AENU Fund II has not made any investments from which data on principal adverse impacts could be collected and considered. AENU Management currently expects that the initial investments of AENU Fund II will not be made before the first quarter of 2026. As a result, the first consolidated principal adverse impact statement is expected to cover the reference period from (approximately) 1 January 2026 to 31 December 2026 and will be published in this section of the website the latest by 30 June 2027.

In the interim, AENU Management will ensure that the necessary policies and procedures (as described below under “Description of policies to identify and prioritise principal adverse impacts on sustainability factors”) are implemented to safeguard that principal adverse impacts are appropriately considered from the time of the initial investment in a portfolio company.

Zusammenfassung

AENU Management berücksichtigt die wichtigsten nachteiligen Auswirkungen seiner Investitionsentscheidungen auf Nachhaltigkeitsfaktoren. Dies ist die erste Website-Erklärung zu den wichtigsten nachteiligen Auswirkungen auf Nachhaltigkeitsfaktoren im Sinne von Art. 4 SFDR.

Zu den Nachhaltigkeitsfaktoren gehören Umwelt-, Sozial- und Arbeitnehmerbelange, die Achtung der Menschenrechte und die Bekämpfung von Korruption und Bestechung. AENU Management berücksichtigt die in Nr. 1 bis 14 der Tabelle 1 des Anhangs I der Delegierten Verordnung (EU) 2022/1288 („RTS“) genannten obligatorischen Indikatoren sowie drei optionale Indikatoren aus Tabelle 2 und Tabelle 3 des Anhangs I der RTS wie nachstehend aufgeführt:

Investitionen in Unternehmen ohne Initiativen zur Reduzierung von CO2-Emissionen (Tabelle 2, Nr. 4)
Investitionen in Unternehmen, die Chemikalien herstellen (Tabelle 2, Nr. 9)
Anzahl der durch Verletzungen, Unfälle, Todesfälle oder Krankheit verlorenen Tage (Tabelle 3, Nr. 3)

AENU Management hat am 24. Februar 2025 von der deutschen Bundesanstalt für Finanzdienstleistungsaufsicht (Bundesanstalt für Finanzdienstleistungsaufsicht – „BaFin“) die Registrierung im Sinne des § 2 Abs. 4 iVm § 44 KAGB erhalten.

Das First Closing der AENU II GmbH & Co. KG GmbH & Co. KG („AENU Fonds II“), dem ersten AIF, der von AENU Management verwaltet wird, wird voraussichtlich nicht vor dem letzten Quartal 2025 stattfinden. Dementsprechend hat der AENU Fonds II zum Zeitpunkt der Erstellung dieses Statements noch keine Investitionen getätigt, von denen Daten über die wichtigsten nachteiligen Auswirkungen erhoben und berücksichtigt werden könnten. AENU Management geht derzeit davon aus, dass die ersten Investitionen des AENU Fonds II nicht vor dem ersten Quartal 2026 getätigt werden. Daher wird erwartet, dass die erste konsolidierte Erklärung zu den wichtigsten nachteiligen Auswirkungen den Referenzzeitraum vom (ungefähr) 1. Januar 2026 bis zum 31. Dezember 2026 abdecken wird und spätestens am 30. Juni 2027 in diesem Abschnitt der Website veröffentlicht wird.

In der Zwischenzeit wird AENU-Management sicherstellen, dass die erforderlichen Strategien und Verfahren (wie unten unter „Description of policies to identify and prioritise principal adverse impacts on sustainability factors“ beschrieben) umgesetzt werden, um sicherzustellen, dass ab dem Zeitpunkt der Erstinvestition in ein Portfoliounternehmen die wichtigsten nachteiligen Auswirkungen der Investitionsentscheidungen auf Nachhaltigkeitsfaktoren angemessen berücksichtigt werden.

Description of the principal adverse impacts on sustainability factors

AENU Management will publish the table with the sustainability indicators considered from Tables 1-3 of Annex I of the RTS for the first reference period, which is expected to begin in 2026, by 30 June 2027 at the latest.

Description of policies to identify and prioritise principal adverse impacts on sustainability factors

AENU Management has implemented the following policies to identify and prioritise principal adverse impacts on sustainability factors. These policies have been approved by the governing body of AENU Management in April 2025. The responsibility for their implementation and application has been allocated to Elena Harumi Stark (Head of Impact & ESG).

The indicators as set forth in no. 1 to 14 in the table above are mandatory according to the RTS. All other indicators were chosen by AENU Management by taking into account their relevance with respect to AENU Management’s business strategy.

Prior to every investment, AENU Management conducts a due diligence. During the due diligence stage, an ESG questionnaire tailored to the company’s location, size, business model and stage of development is sent to the company via AENU Management’s chosen reporting platform to collect relevant information on their performance, policies, and strategies.

Following a materiality assessment, AENU Management assesses the adverse impact indicators as stated above and puts a special focus on the indicators that are material to the specific company by considering its sector, business model, and stage. For each investment, an analysis of the respective material principal adverse impacts is conducted based on the data obtained from the ESG questionnaire provided by the prospective portfolio company during the due diligence process.

If the reported indicators indicate a risk to the sustainable investment objective and the negative adverse impacts cannot be prevented or considerably reduced, the investment opportunity will not be pursued further.

After an investment, i.e., during the holding period, AENU Management checks for adverse impacts on material sustainability factors in regular intervals. Where information is not publicly available, the relevant data is collected either directly from the portfolio companies or by making reasonable assumptions. As the ownership stake in portfolio companies of the Funds managed by AENU Management evolve over time, direct access to certain impact and ESG data may become more limited, even though impact and ESG information rights are legally secured through Impact & ESG side letter agreements with the Funds managed by AENU Management. In such cases, where company-specific data is unavailable, AENU Management may supplement its assessment with publicly available information and well-founded internal estimates. Thus, errors cannot be excluded completely. Yet, AENU Management will always endeavour to identify such errors or inaccuracies and to intervene as appropriate.

When the Fund identifies principal adverse impacts on sustainability factors at portfolio company level during the holding phase, it will discuss on a case-by-case basis with each portfolio company appropriate actions to mitigate such adverse impacts, in particular considering other impacts of the investment, its size, strategic importance and transactional context.

The so described policies will be re-evaluated on a regular basis, i.e., annually, in particular to reflect any legal or regulatory changes as well as data availability and further developments in the market. Hence, in the future, AENU Management may also use other indicators to identify and assess principal adverse impacts.

Engagement policies

Post investment AENU Management has established an engagement strategy (“impact-as-a-service”) to reduce the (principal) adverse impacts assessed through the indicators set forth in the table above in accordance with its set targets. Impact and ESG information rights are legally secured through Impact & ESG side letter clauses with the Funds managed by AENU Management. This clause includes a series of commitments, from carbon accounting to impact management. Whenever possible, the Fund selects impact and ESG performance indicators and annual targets with each portfolio company. Data is collected, at least, on an annual basis, and then used in sustainability engagement conversations with the responsible impact & ESG officer. Based on the assessment, the Fund provides and tailors impact & ESG resources.

AENU Management will engage with the portfolio companies to discuss any (potential) principal adverse impacts. Where there is no reduction of principal adverse impacts over more than one period, AENU Management will support the respective portfolio company in implementing mitigation measures and/or ensure the topic is appropriately addressed at board level.

References to international standards

AENU Management is a member of Leaders for Climate Action, Impact VC, and Venture ESG, proactively developing and implementing best practices for integrating climate and ESG considerations into venture capital business practices. While AENU Management is committed to continuously improving its climate-related strategies, it has not, as of today, formally committed to the specific objectives of the Paris Agreement. Due to the early-stage nature of the fund’s investments, data quality and availability remain significant challenges, particularly when it comes to forward-looking climate scenarios. As such, AENU Management currently prioritizes focusing on the net emission savings of its portfolio investments as a more relevant and actionable measure of climate impact, rather than applying a forward-looking climate scenario that may not be sufficiently supported by reliable data at this stage.

IV. Sustainability-related disclosures

AENU II GmbH & Co. KG

LEI: [in process]

Summary

AENU II GmbH & Co. KG (the “AENU Fund II” or the “Fund”) is managed by AENU Management.

The Fund has sustainable investments as its objective (cf. Art. 9(2) SFDR). The Fund will only make ‘sustainable investments’ within the meaning of Art. 2(17) SFDR. Sustainable investment means an investment in an economic activity that contributes to an environmental or social objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices.

The Fund will invest in early-stage venture and technology-companies with the purpose to achieve impact by providing entrepreneurial solutions to a societal/environmental issue based on a scalable approach. The Fund will make a minimum of 80 % sustainable investments with an environmental objective. The sustainable investments of the Fund will likely contribute to one or more of the following environmental objectives:

Climate change mitigation
Climate change adaptation
The sustainable use and protection of water and marine resources
The transition to a circular economy
Pollution prevention and control
The protection and restoration of biodiversity and ecosystems

The Fund has developed a robust impact approach to assess whether potential investments qualify as suitable ‘sustainable investment’ in accordance with Art. 2 (17) SFDR. The contribution to one of the above environmental objectives by an economic activity of a company is assessed in accordance with the Systemic Impact Framework, the impact methodology developed by AENU Management.

The Fund may also make a maximum of 20% of social sustainable investments aimed to advance social equality and empower people in relation to the United Nations’ sustainable development goals. However, social investments are not a primary objective of the Fund.

The Fund incorporates inclusion (impact screening) as well as exclusion (negative screening in accordance with the Fund’s exclusion policy) aspects during the decision making process and considers principal adverse impacts of its investment decisions to ensure that no significant harm to any environmental or social sustainable investment objective is caused by an investment.

Prior to an investment in a portfolio company, the Fund defines specific impact metrics / outcomes for each portfolio company (“Impact KPIs”) to measure the attainment of the sustainable investment objective. The Impact KPI(s) reflect the environmental/social purpose of the portfolio company and its “Theory of Change”.

In order to quantify the attainment of the sustainable investment objective, the respective Impact KPIs of each investment are collected on an annual basis as well as on an ad hoc basis if required. The Fund uses reasonable efforts to quality check and stress test the collected data. The goal is to use objective and quantitative data. However, some Impact KPIs may rely – to a certain extent – on estimations.

The actions and decisions described in the following section are each made by AENU Management for and on behalf of the Fund.

A reference benchmark for attaining the sustainable investment objective has not been designated for the Fund.

Zusammenfassung

Die AENU II GmbH & Co. KG (der „AENU Fonds II“ oder der „Fonds“) wird von AENU Management verwaltet.

Der Fonds hat nachhaltige Investitionen zum Ziel (vgl. Art. 9(2) SFDR). Der Fonds wird nur „nachhaltige Investitionen“ im Sinne von Art. 2(17) SFDR tätigen. Nachhaltige Investitionen sind Investitionen in eine wirtschaftliche Tätigkeit, die zu einem ökologischen oder sozialen Ziel beiträgt, vorausgesetzt, dass die Investition keinem ökologischen oder sozialen Ziel erheblich schadet und dass die Unternehmen, in die investiert wird, gute Unternehmensführungspraktiken befolgen.

Der Fonds wird in Risikokapital- und Technologieunternehmen in der Frühphase investieren, um durch die Bereitstellung unternehmerischer Lösungen für ein gesellschaftliches/ökologisches Problem auf der Grundlage eines skalierbaren Ansatzes eine positive Wirkung zu erzielen. Der Fonds wird mindestens 80 % nachhaltige Investitionen mit einem Umweltziel tätigen. Die nachhaltigen Investitionen des Fonds werden wahrscheinlich zu einem oder mehreren der folgenden Umweltziele beitragen:

Eindämmung des Klimawandels
Anpassung an den Klimawandel
Nachhaltige Nutzung und Schutz von Wasser- und Meeresressourcen
Übergang zu einer Kreislaufwirtschaft
Vermeidung und Verminderung der Umweltverschmutzung
Schutz und Wiederherstellung der Biodiversität und der Ökosysteme

Der Fonds hat einen robusten Ansatz entwickelt, um zu bewerten, ob potenzielle Investitionen als geeignete „nachhaltige Investitionen“ im Sinne von Art. 2 (17) SFDR einzustufen sind. Der Beitrag einer wirtschaftlichen Tätigkeit eines Unternehmens zu einem der oben genannten Umweltziele wird gemäß dem Systemic Impact Framework, der von AENU Management entwickelten Impact Methodologie, bewertet.

Der Fonds kann auch maximal 20 % der Investitionen in nachhaltige Investitionen mit einem sozialen Ziel tätigen, um die soziale Gleichstellung zu fördern und die Menschen in Bezug auf die Ziele der Vereinten Nationen für nachhaltige Entwicklung zu stärken. Nachhaltige Investitionen mit einem sozialen Ziel sind jedoch kein vorrangiges Ziel des Fonds.

Der Fonds bezieht sowohl Aspekte der Inklusion (Wirkungsanalyse) als auch der Exklusion (Negativprüfung gemäß der Ausschlussrichtlinie des Fonds) in den Entscheidungsprozess ein und berücksichtigt die wichtigsten negativen Auswirkungen seiner Investitionsentscheidungen, um sicherzustellen, dass durch eine Investition kein erheblicher Schaden für ein ökologisches oder sozial nachhaltiges Investitionsziel entsteht.

Vor einer Investition in ein Portfoliounternehmen definiert der Fonds spezifische Wirkungskennzahlen/Ergebnisse für jedes Portfoliounternehmen („Impact KPIs“), um die Erreichung des nachhaltigen Investitionsziels zu messen. Die Impact KPI(s) spiegeln den ökologischen/sozialen Zweck des Portfoliounternehmens und seine “Theory of Change” wider.

Um die Erreichung des nachhaltigen Investitionsziels zu quantifizieren, werden die jeweiligen Impact KPIs jeder Investition jährlich sowie bei Bedarf ad hoc erhoben. Der Fonds unternimmt angemessene Anstrengungen, um die gesammelten Daten einer Qualitätsprüfung und einem Stresstest zu unterziehen. Ziel ist es, objektive und quantitative Daten zu verwenden. Einige Impact-KPIs können jedoch bis zu einem gewissen Grad auf Schätzungen beruhen.

Die im folgenden Abschnitt beschriebenen Maßnahmen und Entscheidungen werden jeweils von AENU Management für und im Namen des Fonds getroffen.

Für den Fonds wurde keine Referenzbenchmark für die Erreichung des nachhaltigen Anlageziels festgelegt.

No significant harm to the sustainable investment objective

The Fund will not significantly harm any sustainable investment objective by means of considering principal adverse impacts on sustainability factors in the investment decision process.

AENU Management considers the mandatory indicators as set forth in no. 1 to 14 of Table 1 of Annex I of the Delegated Regulation (EU) 2022/1288 (“RTS”) as well as three optional indicators from Table 2 and Table 3 of Annex I of the RTS as stipulated below:

Investments in companies without carbon emission reduction initiatives (Table 2, No. 4)
Investments in companies producing chemicals (Table 2, No. 9)
Number of days lost to injuries, accidents, fatalities, or illness (Table 3, No. 3)

To gather the relevant and material data, during the due diligence (DD) stage, an ESG questionnaire tailored to the company’s location, size, business model, and stage of development is sent to the company via AENU Management’s chosen reporting platform to collect relevant information on their performance, policies, and strategies.

For further details on the principal adverse impact consideration please refer to the “Statement on principal adverse impacts of investment decisions on sustainability factors” above in these SFDR Website Disclosures.

As a responsible investor, the Fund strives to ensure that good governance practices are in place and adhered to during and after investment. The Fund has integrated a set of good governance-related questions feasible for early-stage startups in its pre-investment ESG due diligence as well as in the post-investment monitoring and engagement processes. Hence, the Fund ensures that good governance practices are in place and adhered to. Given that the Fund primarily invests in early-stage companies based in Europe, formal compliance with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights may not be relevant at the time of investment, as there are few employees and no extensive supply chains. As these issues become more relevant as the company grows, the Fund ensures that appropriate processes are established within the company. The Fund will always check if there are any indications for non-compliance with good governance criteria.

Further, by considering the principal adverse impact indicators 10 and 11 from Table 1, Annex I of the RTS, the Fund ensures that it will receive all relevant information on compliance with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights.

Sustainable investment objective of the financial product

The Fund will only make ‘sustainable investments’ within the meaning of Art. 2(17) SFDR.

The Fund pursues an impact investing strategy based on the ‘Theory-of-Change’.^[1] The Fund will invest in early-stage venture and technology-companies with the purpose to achieve impact by providing entrepreneurial solutions to a societal/environmental issue based on a scalable approach. This impact needs to be clearly measurable and inherently integrated into the business model of the portfolio companies.

Most of the investments of the Fund are expected to be geared towards climate impact. Therefore, the Fund will make a minimum of 80 % sustainable investments with an environmental objective. The sustainable investments of the Fund will likely contribute to one or more of the following environmental objectives:

Climate change mitigation
Climate change adaptation
The sustainable use and protection of water and marine resources
The transition to a circular economy
Pollution prevention and control
The protection and restoration of biodiversity and ecosystems

The Fund has developed a robust impact approach to assess whether potential investments qualify as suitable ‘sustainable investment’ in accordance with Art. 2 (17) SFDR: The contribution to one of the above environmental objectives by an economic activity of a company is assessed in accordance with the Systemic Impact Framework, the impact methodology developed by AENU Management.

For the avoidance of doubt, the Fund may also make a maximum of 20% of social sustainable investments aimed to advance social equality and empower people in relation to the United Nations’ sustainable development goals. However, social investments are not a primary objective of the Fund.

Investment strategy

The purpose of the Fund is to build, hold and manage (including to divest) a portfolio of equity and equity-related investments in portfolio companies that meet the Fund’s Investment Scope, in accordance with and subject to the Investment Restrictions and Limitations. The Fund shall pursue a long term and sustainable investment strategy.

The Fund will conduct investments in a broad range of development stages of enterprises between seed stage and early growth rounds in the global technology sector, focusing on climate, energy, decarbonization, food and agricultural technology, mobility and buildings, industrial and materials as well as enterprise and finance, which at the time of the Fund’s initial investment are primarily headquartered or have the majority of their business in the European Union, the United Kingdom, or an EFTA Country.

The Fund seeks to only invest in companies that address pressing environmental problems by generating positive outcomes for people and the planet. For a potential investment of the Fund, it must be impossible for the investment to achieve commercial success without simultaneously creating a positive impact (‘Impact Interlock’).

The Fund is committed to responsible investment practices that align with its values and principles. Hence, as part of its impact investing strategy, the Fund has categorically excluded investments in certain economic activities Its exclusion policy guides the Fund’s capital allocation decisions in alignment with its strategy and the SFDR, showcasing best practices within environmental, social, and governance considerations. This policy is designed to ensure that the positive impacts of the Fund’s investments will never be negated by negative impacts. It is regularly reviewed and updated as new insights become available. The following exclusion list is the basis and starting point of the Fund’s responsible investing approach.

Prohibited Substances & Wildlife: Activities involving banned chemicals, hazardous waste, endangered wildlife, and ozone-depleting substances (e.g., Rotterdam Convention, Basel Convention, CITES, Montreal Protocol).
Fossil Fuels & High-Emission Industries: Activities related to fossil fuel extraction and high-emission industries that are inconsistent with decarbonization objectives.
Environmental Degradation: Unsustainable agricultural or forestry practices, use of unbound asbestos, and large-scale habitat alteration.
Human Rights & Ethical Standards: Exploitative practices, human rights violations, unethical research (e.g., human cloning), and activities lacking Free, Prior, and Informed Consent (FPIC).
Unethical Business Models: Activities related to illegal operations, sanctioned entities, pornography, gambling, tobacco, non-medical animal testing, and fur trading.
Conditional Sectors: Genetically Modified Organisms (GMOs) and Clean Transition Technologies require extensive due diligence and LPAC approval to ensure alignment with decarbonization goals and regulatory standards.

A comprehensive and regularly updated exclusion list that takes current developments into account can be found online here: [in process]

Good Governance Practices:

Good governance practices are assessed 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. For this purpose, the Fund creates and implements a framework with certain Impact & ESG clauses in the investments’ shareholder agreements and regularly evaluates the progress on good governance (policies) within the portfolio companies. If the Fund becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution. The Fund’s goal is to ensure the best possible good governance of the portfolio companies of the Fund.

Proportion of investments

The intention of AENU Management is that 100% of the investments made by the Fund shall be aligned with the sustainable investment objective. The Fund will invest fully in line with its impact-investment strategy and investment restrictions, i.e., will only make investments which are aligned with its sustainable investment objective.

Monitoring of sustainable investment objective

In light of the Fund’s objective to invest in early-stage venture and technology companies spanning a diverse range of topics covered by its sustainable investment objectives, it is acknowledged that certain solutions are not yet identifiable at this stage. Accordingly, it is not feasible to provide an exhaustive list of sustainability indicators to measure the attainment of the Fund’s sustainable investment objective. The Fund will individually define one to several Impact KPIs for each portfolio company and track these Impact KPIs.

Routine reporting disclosures will encompass 1-4 Impact KPIs that effectively capture the principal areas of investment activity. The Impact KPIs outlined below are therefore presented as indicative examples that are likely to be relevant for a large proportion of the Fund’s investments and therefore could be capable to aggregate data from a significant proportion of the Fund’s investments:

Emission savings (enabled) measured in tons of CO2e
Energy savings (enabled) measured in MWh
Renewable energy production (enabled) measured in MWh
Climate vulnerable assets protection (enabled) measured in financial value of assets (e.g., € or $)
Land protected, restored, or managed sustainably measured in hectares

In order to quantify the attainment of the sustainable investment objective, the respective Impact KPIs of each investment are collected on an annual basis as well as on an ad hoc basis if required.

The Fund uses reasonable efforts to quality check and stress test the collected data. The goal is to use objective and quantitative data. However, some Impact KPIs may rely – to a certain extent – on estimations.

Further, during the holding period, AENU Management checks for adverse impacts on sustainability factors in regular intervals. When the Fund identifies principal adverse impacts on sustainability factors at portfolio company level during the holding phase, it will discuss on a case-by-case basis with each portfolio company appropriate actions to mitigate such adverse impacts, in particular considering other impacts of the investment, its size, strategic importance and transactional context.

Methodologies

In order to quantify the attainment of the sustainable investment objective, the respective Impact KPIs of each investment are collected on an annual basis as well as on an ad hoc basis if required. Further, the Fund uses the principal adverse impact indicators in order to consider principal adverse impacts of its investment decisions on sustainability factors and collects the relevant data from its portfolio companies on a regular basis. Hence, the Fund measures and evaluates the attainment of its sustainable investment objective on an ongoing basis.

Data sources and processing

The Impact KPIs and principal adverse impact indicators are collected at least on an annual basis (as well as on an ad hoc basis if required) directly from each portfolio company. During the due diligence stage, an ESG questionnaire tailored to the company’s location, size, business model, and stage of development is sent to the company via AENU Management’s chosen reporting platform to collect relevant information on their performance, policies, and strategies.

The Fund uses reasonable efforts to quality check and pressure test the collected data. The goal is to use objective and quantitative data. However, some metrics may rely – to a certain extent – on estimations. As the ownership stake in portfolio companies of the Funds managed by AENU Management evolve over time, direct access to certain impact and ESG data may become more limited, even though impact and ESG information rights are legally secured through Impact & ESG side letter agreements with the Funds managed by AENU Management. In such cases, where company-specific data is unavailable, AENU Management may supplement its assessment with publicly available information and well-founded internal estimates. AENU Management estimates that around 75% of the relevant data will be estimated or supplemented by information publicly available. Thus, errors cannot be excluded completely. Yet, AENU Management will always endeavour to identify such errors or inaccuracies and to intervene as appropriate.

Should data on the principal adverse impact indicators not be readily available, the Fund may carry out additional research, cooperate with third party data providers or external experts, or make reasonable assumptions.

Limitations to methodologies and data

As AENU Management invests in early-stage venture and technology-companies, some limitations may arise from the stage of the portfolio company. Data can be incomplete or insufficiently granular. Uncertainty is an inevitable aspect of impact assessments.

When the company is in an early stage, data to evaluate the impact potential might be limited or needs to be based on certain assumptions. Further, as the ownership stake in portfolio companies of the Funds managed by AENU Management evolve over time, direct access to certain impact and ESG data may become more limited, even though impact and ESG information rights are legally secured through Impact & ESG side letter agreements with the Funds managed by AENU Management.

In such cases, where company-specific data is unavailable, AENU Management may supplement its assessment with publicly available information and well-founded internal estimates. Thus, errors cannot be excluded completely. Yet, AENU Management will always endeavour to identify such errors or inaccuracies and to intervene as appropriate.

The Fund will approach these methodological and data limitations by continuously improving the existing and developing new standards. Furthermore, the Fund actively works together with other stakeholders from the VC industry and impact advisors who provide an independent outside view on potential limitations. All this assures that the limitations do not affect the attainment of the sustainable investment objective.

Due diligence

In order to identify all foreseeable risks and the upside potential of each investment, the fund conducts an extensive due diligence before each investment. The Fund uses an ESG questionnaire during the due diligence as well as in the post investment monitoring tailored to the company’s location, size, business model, and stage of development. The ESG questionnaire is sent to the company via AENU Management’s chosen reporting platform to collect relevant information on their performance, policies, and strategies.

Further, for its impact assessment AENU Management has developed a robust impact approach to assess whether potential investments qualify as suitable ‘sustainable investment’ in accordance with Art. 2 (17) SFDR. The Systemic Impact Framework developed by AENU Management is employed to rigorously assess the commercial and impact potential of early-stage investments, ensuring alignment with the Fund’s objective of driving systemic change. This comprehensive evaluation encompasses six distinct categories.

First, Founder Intentionality is assessed to determine whether founders exhibit a clear and demonstrable commitment to addressing climate or social challenges through their proposed solutions.
Second, Additionality is evaluated by establishing whether the solution represents the most effective alternative to address a defined impact problem, particularly in comparison to incumbent solutions and existing baselines.
Third, the Theory of Change is scrutinized by examining the robustness of research evidence linking the identified impact problem with the proposed solution, thereby ensuring credibility and coherence.
Fourth, the assessment of Interlock focuses on verifying the extent to which commercial success and impact achievement are fundamentally intertwined, indicating a high degree of alignment between financial performance and positive societal or environmental outcomes.
Fifth, Impact Measurement & Management is critically examined to ensure the systematic quantification, tracking, and reporting of impact metrics, thereby promoting accountability, and enabling continuous improvement.
Lastly, Impact Scale is analyzed by considering the potential breadth and depth of impact, with a specific focus on ensuring scalability in line with the Fund’s sustainable investment objectives.

The Fund’s team applies the Systemic Impact Framework to ensure that investment opportunities meet the requisite impact criteria to be considered for investment. This framework serves as a foundational tool for evaluating the long-term sustainability of potential portfolio companies and their capacity to drive enduring systemic change. Emphasis is placed on the measurability of impact, with a stringent approach to quantifying and transparently reporting impact metrics to facilitate ongoing monitoring and assessment of progress over time.

Engagement policies

Engagement forms part of the impact investing strategy of the Fund. Impact and ESG information rights are legally secured through Impact & ESG side letter clauses with the Funds managed by AENU Management. This clause includes a series of commitments, from carbon accounting to impact management. Whenever possible, the Fund selects impact and ESG performance indicators and annual targets with each portfolio company. Data is collected, at least, on an annual basis, and then used in sustainability engagement conversations with the responsible impact & ESG officer. Based on the assessment, the Fund provides and tailors impact & ESG resources.

The Fund will respond with individual measures when becoming aware of ESG-related incidents or controversies at portfolio company level. The Fund will regularly review and, as necessary, adjust its engagement policy.

Attainment of the sustainable investment objective

A reference benchmark for attaining the sustainable investment objective has not been designated for the Fund. AENU Management’s research has shown that there are currently no relevant benchmarks available for products categorized under Art. 9 SFDR investing in early-stage venture and technology-companies.

While AENU Management is committed to continuously improving its climate-related strategies, it has not, as of today, formally committed to the specific objectives of the Paris Agreement. Due to the early-stage nature of the fund’s investments, data quality and availability remain significant challenges, particularly when it comes to forward-looking climate scenarios. As such, AENU Management currently prioritizes focusing on the net emission savings of its portfolio investments as a more relevant and actionable measure of climate impact, rather than applying a forward-looking climate scenario that may not be sufficiently supported by reliable data at this stage.

[1] ‘Theory-of-Change’ is a model that specifies the desired outcomes of an activity, project or programme, evidencing the underlying logic of causality between action and result, and making transparent its assumptions, influences, and the potential risks of producing undesired effects, which shall be taken into account when establishing the level of desired outcomes achieved. For more information on the Theory-of-Change as well as Key Concepts of impact investing in alternative investments please refer to Section 2 ‘Key Concepts’ of the Position Paper ‘Impact Investing in Alternative Investments’ published by Bundesverband Alternative Investments e.V. (BAI) together with Bundesinitiative Impact Investing e.V. (BIII) in November 2024 which can be downloaded here: BAI_BIII_Position_Paper_Impact_Investing_in_Alternative_Investments.pdf (last accessed on 28 May 2025).

PAI Statement