SFDR Policy - Earlybird

Sustainable Finance Disclosure Regulation

Earlybird DWES Management GmbH & Co. KG, Earlybird Growth Management GmbH & Co. KG, Earlybird VC Management GmbH & Co. KG, Earlybird Venture Capital GmbH & Co. KG, Earlybird Health Management GmbH & Co.KG and Earlybird UNI-X Management GmbH & Co. KG (each an “Earlybird ManCo” and together “Earlybird”) are alternative investment fund managers within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and/or the EuVECA-Regulation and as such publish the following information on their 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 27th of November 2019 on sustainability disclosure requirements in the financial services sector (the “SFDR”). Unless the information is explicitly provided in relation to a specific Earlybird ManCo or specific fund managed by any of the Earlybird ManCos the following statements refer to the management and investment decision-making processes of all Earlybird ManCos in general.

I. Sustainability risk policies statement

Earlybird addresses sustainability risks in its 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.

A standardized sustainability risk questionnaire that is mandatory to be completed as part of the Due Diligence process prior to an investment decision ensures the adequate and systematic assessment of the main sustainability risk factors associated with a proposed investment. 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.

Earlybird regularly reviews its sustainable risk policies to ensure that those are being kept in line with the ESAs recommendations as they may evolve over time.

II. No consideration of principal adverse impacts

Earlybird 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. Earlybird 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, Earlybird is not in a position to commit to such standard in light of its fiduciary duty to the funds and their investors.

Earlybird 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 Earlybird.

After internal revision Earlybird has updated its ESG-Policies. This disclosure describes the updated ESG-Policy as of January 2023.

Sustainability-related disclosures

The interpretation and application of the SFDR are currently still changing over time. The fund-related disclosures were last updated in September 2023 in the context of structuring the new Earlybird DWES VIII Fund to incorporate the latest guidance on the SFDR from the European Commission as well as the first approaches of a market practice.