SFDR Disclosures

Disclosures in Accordance with Regulation (EU) 2019/2088 (“SFDR”)

This disclosure applies to the following management companies and their respective funds:

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Management Companies

ProVenture Management II AS and ProVenture Management III AS

Funds

ProVenture Seed II AS and ProVenture Seed III AS

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Integration of Sustainability Risks

The listed companies integrate sustainability risks into their investment decisions by assessing environmental, social, and governance (ESG) factors. While ESG considerations are part of the risk assessment process, they are not standalone criteria, as the primary objective of all funds is economic value creation in the early-stage venture capital (VC) domain. Given the early-stage focus of our funds, there is often a lack of established ESG data. We actively encourage portfolio companies to adopt and strengthen sustainability practices as they mature.

 

Exclusions

We exclude investments in companies that:

• Violate international norms or standards.

• Produce or promote products with specific negative characteristics.

• Are involved in controversial activities.

 

These exclusions reflect our commitment to responsible investment practices.

 

Sustainability Risks and Returns

Sustainability risks, if unmanaged, may negatively impact investment value and returns. Based on the early-stage nature of our investments, these risks are evaluated in the context of the companies’ potential for growth and alignment with sustainability practices over time.

 

Guiding Portfolio Companies on ESG Practices

Although ESG practices may not be fully integrated at the time of initial investment, we are committed to guiding and supporting portfolio companies in adopting ESG principles as they develop. This includes encouraging adherence to best practices, fostering sustainability initiatives, and promoting long-term value creation.

 

Principal Adverse Impacts

Currently, we do not systematically consider principal adverse impacts (PAI) on sustainability factors due to data limitations typical of early-stage startups. However, we actively monitor regulatory developments and may adjust our approach as necessary.

 

Fund Classification

All funds are classified as Article 6 under SFDR. They do not promote environmental or social characteristics, nor do they have specific sustainability objectives.

 

Transparency and Updates

We are committed to providing transparent and up-to-date information. This disclosure will be revised as needed to reflect changes in our policies, processes, or regulatory requirements.