Sustainable Finance Disclosure Regulation (SFDR) Statement

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”)

Sustainability risks

Project A Ventures Management GmbH ("Project A", LEI: 3912008RQ3ORI32X9I23) integrates sustainability risks in its decision-making process, as referred to under Article 3 of the Sustainable Finance Disclosure Regulation (EU 2019/2088) (“SFDR”). Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material negative effect on the value of the investment.

The review of sustainability risks is part of the due diligence process and risk management by the Project A team.

Project A considers sustainability risks as part of the due diligence process by implementing an investment exclusion list and following a dedicated ESG Due Diligence checklist, covering topics such as:

• Exclusion of businesses in non-designated countries

• Research of any ESG issues reported in the media with regards to the business or founders

• Identification and discussion with founders of key ESG material issues within the sector of investment, such as environmental impacts, social considerations and governance structures, assessing the short-term roadmap to tackle these. These analyses are designed to be stage appropriate.

The results of such assessment are integrated into the investment memorandum and evaluated when the investment decision is being taken. Should an issue be identified and if the investment has been, or is intended to be, undertaken despite material sustainability risks pursuant to the ESG Due Diligence, investment managers must ensure no unreasonable sustainability risks exist (a “red flag”), provide more details of their research and integrate it into the investment committee briefing. This briefing is then evaluated by the investment committee before a final decision on investment, assessing whether ESG risks are acceptable in light of details provided by research despite flagged sustainability risks.

Project A remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case, Project A can also apply measures to reduce or mitigate them. At all times, Project A will apply the principle of proportionality considering the identified ESG issue, the strategic relevance of an investment and the potential to reduce and mitigate such risks.

No consideration of adverse impacts of investment decisions on sustainability
factors

Currently, Project A does not consider principal adverse impacts (PAIs) on sustainability factors as described by Article 4 SFDR and the Commission Delegated Regulation (EU) 2022/1288 (“SFDR-DR”). Sustainability factors are environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery matters.

Given that Project A invests primarily in early-stage companies which have no regulatory disclosure requirements and little market experience reporting against ESG metrics, obtaining this data in full for compliance purposes remains practically unfulfillable at this time.

Project A is regularly reviewing its approach to PAIs, as well as the legal and administrative developments on the interpretation of the SFDR and SFDR-DR and might reevaluate itsstance once smaller and younger companies report more ESG data.

Transparency of remuneration policies in relation to the integration of sustainability risks

As a registered alternative investment fund manager (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 Art. 3 (b) of Regulation (EU) No. 345/2013 (“EuVECA-Regulation”), Project A does not have a remuneration guideline (remuneration policy) in accordance with the requirements of the KAGB. Therefore, the integration of sustainability risks is not considered when determining remuneration, as defined by Article 5 of the SFDR.

Sustainability-related disclosures

Information pursuant to Art. 10 of the Disclosure Regulation can be viewed following the
respective fund links.

• Project A Ventures V GmbH & Co. KG

• Project A Ventures IV GmbH & Co. KG

• Project A Opportunity III GmbH & Co. KG

• Project A Buy-Out Co-Invest I GmbH & Co. KG

Date of Publication: 10 March 2021
The information on this website and accompanying Article 10 SFDR disclosures has been
updated as follows,

• 31 January 2023: Editing of section “Engagement Policies” under Project A Ventures IV GmbH & Co. KG Article 10 disclosures in order to provide more details and the addition of the Article 10 disclosures of Project A Buy-Out Co-Invest I GmbH & Co. KG.

• 30 May 2023: Editorial amendments of editorial amendments and additional Project A Opportunity III GmbH & Co information about its investment strategy.

• 8 January 2025: Information pursuant to art. 3, 4 and 5 SFDR, and info pursuant to art. 10 concerning Project A’s financial products, have been separated into different documents. Further, multiple sections have been updated in line with Project A’s new ESG policy affecting all Article 8 funds, as well as the incorporation of Article 10 disclosures of Project A Ventures V GmbH & Co. KG

If you have any questions or require any additional documents, please do not hesitate to contact us at esg@project-a.vc