ESG Policy

415 Capital Management GmbH (“415 Capital”) is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information on its website 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").

I. Sustainability risk policies statement

415 Capital addresses sustainability risks in their investment decision-making process. ‘Sustainability risk’ means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. The main concerns we pay attention to are, social and employee matters, human rights, and governance. We developed criteria and qualitative standards which define when an investment may present a sustainability risk. During Due Diligence as well as the administration of our holdings we carefully review employment contracts and safety, manufacturing, and quality standards (including during site visits), meet and speak to team members, review supply chains, and ensure that portfolio company operations and corporate governance are in accordance with our ESG policies and principles. Some example of sustainability risks include:

Furthermore, there are certain sectors and countries that are totally excluded from financing. For example, the partnership does not invest or engage in;

We regularly review our policies to ensure that they address new and emerging risks as well as investors’ concerns.

II. Principal adverse sustainability impacts statement

Transparency of adverse sustainability impacts at entity level, Initial statement as of March 2021.

1. Summary

415 Capital considers principal adverse impacts of its investment decisions on sustainability factors. The present statement is the consolidated principal adverse sustainability impacts statement of 415 Capital.

2. Description of principal adverse sustainability impacts and policies to identify and prioritize

‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters. The indicators are applicable to investments in investee companies. 415 Capital has identified the principal adverse sustainability impacts of the investments, taken actions and developed policies on the identification and prioritization as described in the “I. Sustainability risk policies statement” statement above. The probability of occurrence and severity of adverse impacts, including their potentially irremediable character is analyzed and discussed, on a continuous basis before an investment is completed as well as during the holding period, by the investment committee and the ESG officers. The collection of relevant data and information occurs through the close contact that 415 Capital cultivates with its portfolio companies.

3. References to international standards

415 Capital strives to be a responsible and professional alternative investment fund manager (AIFM). To meet this standard, 415 Capital acknowledges that it is necessary to act responsibly and fair towards investors, business partners, competitors, supervisory authorities, and employees. A code of conduct, which we believe is of the highest of international standards, was established and summarizes the behavior required to live up to the envisaged standard of responsibility and, thus, constitutes a critical component of the corporate culture of 415 Capital. The main aspects include; Compliance with the Law and Respect of Integrity, Fair Dealings, ESG Policy, Data Protection, Independence, Prevention of Money Laundering, Communication, Principles for Dealing with the Workplace and with Third Parties.