ESG Policy +

10. SFDR – Promotion of environmental or social characteristics

415 Capital Management GmbH (“Manager”) is the alternative investment fund manager of 415 Capital Fund II GmbH & Co. KG (“415 Capital Fund II”) within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and the EuVECA-Regulation 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 (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/or social characteristics are promoted by this financial product?

Investment Restrictions

The 415 Capital Fund II shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities:

What sustainability indicators are used to measure the attainment of each of the environmental or social characteristics promoted by this financial product?

There are currently no sustainability indicators or other quantitative measurement with regard to the promoted environmental or social characteristics.

Does this financial product consider 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 of the 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 415 Capital Fund II and its investors.

The Manager will constantly monitor and review the evolution around such regulations and standards and considers 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 purpose of the Partnership is to build, hold and manage (including, but not limited to, to divest) in its own name and for its own account a portfolio of equity and equity-related investments primarily in companies developing innovative medical device technologies primarily in Europe, the U.S., and Israel.

What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product?

The investment strategy is described in § 3 of the partnership agreement of 415 Capital Fund II (the “LPA”). Further binding elements of the investment strategy can be found in § 18 (1) of the LPA. The investment restrictions are set out in § 18 (3) and (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 part of the due diligence and ongoing investment management, the investment team for 415 Capital Fund II 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?

415 Capital Fund II will invest fully in line with its investment strategy and investment restrictions. 415 Capital Fund II will not invest a portion of its capital in any other asset class.

Methodologies

The Manager considers the promoted ESG aspects when sourcing new portfolio companies for 415 Capital Fund II and during the due diligence on targeted portfolio companies. 415 Capital Fund II will not make any investment in the excluded sectors unless previously approved by the investor advisor board.

Data sources and processing and limitations to methodologies and data

415 Capital Fund II is partly reliant on the information provided by portfolio companies during the due diligence process. Moreover, in the post-investment phase, 415 Capital Fund II 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. As the fund’s investment is made for several years, the Manager considers it a priority to establish and maintain a trustful working relationship with the fund’s portfolio companies to ensure compliance with the restrictions described in this section.

Due Diligence

As part of the due diligence and ongoing investment management, the investment team for 415 Capital Fund II will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies.

Engagement policies

The Manager does not follow any ongoing engagement policies regarding 415 Capital Fund II, as the Manager only needs to assure that no investments within the promoted sector exclusions are made by 415 Capital Fund II.