Article 5 SFDR - Remuneration Disclosure
As a registered alternative investment fund manager within the meaning of KAGB, the Manager 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.
Article 10 SFDR - Promotion of environmental or social characteristics
PrequelVentures Management GmbH (“Manager”) is the alternative investment fundmanager of Prequel Ventures Fund I GmbH & Co. KG (“Partnership”)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 thefinancial services sector (Sustainable Finance Disclosure Regulation, “SFDR”).
Summary
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.
What environmental and/orsocial characteristics are promoted by this financial product?
The Partnership may not invest, guarantee or otherwise provide financial or other support, directly orindirectly, to companies or other entities (A) whose business activity consists of an illegal economic activity (i.e., any production, trade or other activity which is illegal under the laws or regulations applicable to the Partnership or the relevant company or entity, including without limitation, human cloning for reproduction purposes), or (B) which substantially focus on: (i)the production of and trade in tobacco and distilled alcoholic beverages; (ii)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; (iii)casinos and equivalent enterprises; or (iv) the research, development or technical applications relating to electronic data programs or solutions, which (x)aim specifically at supporting any activity referred to under (i)to (iv)above; internet gambling and online casinos; or pornography; or which (y)are intended to enable to illegally enter into electronic data networks or to illegally download electronic data.
What sustainability indicators are used to measure the attainment of each of the environmental or social characteristics promoted by this financialproduct?
There are currently no sustainability indicators or other quantitative measurement withregard to the promoted environmental or social characteristics.
Does this financial productconsider principal adverse impacts on sustainability factors?
The Manager 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.
The Manager does not use sustainability indicators. Considering the numerous legal uncertainties currently related to the application of the provisions ofthe 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, the Manager is not in a position to commit to such standard in light of its fiduciary duty to the Partnership and its investors.
The Manager 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 the Manager.
What investment strategy does this financial product follow?
The Partnership intends to seek long-term capital appreciation through equity and quasi-equity investments in early-stage technology companies active in the field of Supply Chain Management and Logistics, primarily in Europe.
What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristicspromoted by this financial product?
The investment strategy is described in § 3 of the limited partnership agreement of the Partnership (“LPA”). Further binding elements of the investment strategy can be found in § 18 (1) of theLPA. The investment restrictions are set out in § 18 (4) of the LPA.
How is that strategy implemented in the investment process on a continuous basis?
No investments are made in the area of exclusions. As partof the due diligence and ongoing investment management, the investment team for the Partnership will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies.
What is the policy to assess good governance practices of the investee companies?
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.
What is the asset allocation planned for this financial product?
The Partnership will invest fully in line with its investment strategy and investment restrictions. The Partnership will not invest a portion of its capital in any other asset class.
Methodologies and Due Diligence
The Manager considers the promoted Environmental, Social, and Governance (ESG) aspects when sourcing new investee companies for the Partnership and during the due diligence on targeted investee companies. The investment team for the Partnership will initially and continuously monitor whether the investment restrictions are abided by and whether the investmentfalls within the investment policies. The Partnership will not make anyinvestment in the excluded sectors.
Data sources and processing and limitations to methodologies and data
The Manager is partly reliant on the information provided by investee companies during the due diligence process. Moreover, in the post-investment phase, the Partnership is reliant on the company’s reported data. In both cases, complete data may not always be available due to the nature of investments. The information is verified only if and to the extent,misrepresentations are suspected.
Engagement policies
The Manager does not follow any ongoing engagement policies regardingthe Partnership, as the Manager only needs to assure that no investments withinthe promoted sector exclusions are made by the Partnership.