Mandatory disclosures under Regulation of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (EU) 2019/2088 (“SFDR”):

Published on April 1st, 2021 by neoteq ventures*


Policies on the integration of sustainability risk in investment decision-making processes (Article 3 SFDR)


neoteq ventures aspires to follow a responsible and sustainable investment strategy. By doing so, we seek to identify and capture value creating opportunities as well as to mitigate sustainability risks. A sustainability risk is defined as „an environmental, social or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of the investment“. For neoteq ventures in specific, sustainability risks are risks which could cause a material negative impact on the value of our investment portfolio.


neoteq ventures has implemented an ESG Policy and by doing so follows a responsible investment process. When evaluating a potential investment, neoteq ventures’ investment professionals analyze potential material risks and opportunities related to ESG matters. Reasonable steps are taken to mitigate ESG-related risks. neoteq ventures’ legal team, together with external advisers as needed, provide necessary support in conducting this review.


During the phase of its investment in the portfolio company, neoteq ventures investment professionals assist the portfolio company’s board of directors and management in developing a plan to mitigate ESG risks and capitalize on ESG opportunities.


We additionally follow a Code of Conduct (including exclusion criteria with respect to business activities that are not eligible for investment) that is integrated in the investment processes.


neoteq ventures commits to adhere to the United Nations Principles of Responsible Investment (“UN PRI”) in line with its fiduciary responsibilities towards its investors.


neoteq ventures regularly reviews its sustainable risk policies to ensure alignment with current regulatory and market best practices as they may evolve over time.


Adverse sustainability impact statement (Article 4 SFDR)


As part of its portfolio management practices, neoteq ventures aspires to consider the principal adverse impacts of investment decisions on sustainability factors in the manner prescribed by Article 4 of the Disclosure Regulation.


‘Sustainability factors ’mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.


During the initial screening and due diligence process, we make use of established standards and frameworks to identify and assess material ESG related risks and opportunities of the respective target company.


The results of this analysis are documented in the investment recommendation materials presented to the investment committee of the respective neoteq ventures fund and are considered in the review of the investment opportunity. Identified “Red Flags” need to be brought to the investment committee’s (ICs) attention and without cure or adequate mitigation an investment will not be pursued.


With its investment neoteq ventures sets out clear expectations for portfolio companies that are designed to ensure material ESG risks opportunities are addressed. While the board of directors is ultimately responsible for developing the portfolio company’s sustainability strategy and ensuring it is implemented, neoteq ventures provides guidance to help the company achieve its strategic aims and meet its expectations.


In preparation for the exit phase of an investment, reasonable steps are taken to ensure the portfolio company is positioned to continually improve its ESG performance. The value generated by ESG.


Furthermore, neoteq ventures abides by, and actively encourages its portfolio companies to consider, the Ten Principles of the United Nations Global Compact.


The principal adverse sustainability impacts of neoteq ventures investment decisions will typically vary depending on the sector and industry of the underlying company. Furthermore, given the early-stage nature of our investment strategy, the availability of relevant (non-financial) information to assess the adverse sustainability impacts may be limited.


Mandatory disclosures of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)


neoteq ventures does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB in place yet.


* neoteq ventures refers to neoteq ventures management GmbH and funds managed by neoteq ventures management GmbH