SFDR

Summary

AENU Fund SCA SICAV-RAIF (the “Fund”) invests in early venture stage companies addressing global environmental challenges. The Fund has sustainable investments as its objective. It will make a minimum share of 80% of sustainable investments with an environmental objective. In line with this a sustainable investment for the Fund is defined as an investment in an economic activity that contributes to an environmental objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices. A portion of the Fund’s investments (up to 20%) can be held as ancillary liquidity or tactically invested in Put-Options/Warrants to hedge the public market equity long-positions in case of an expected market-downturn.

The Fund has set up an integrated impact / ESG & business diligence process that takes into account positive and negative outcomes and externalities.

To qualify for investment of the Fund, a company must demonstrate that its commercial success is directly tied to creating a positive impact (referred to as “Impact Interlock” within the Fund’s Impact Guidelines). Each investment must show potential for measurable impact in alignment with at least one of the UN SDGs or environmental objectives, including climate change mitigation, climate change adaptation, sustainable use of water and marine resources, transition to a circular economy, pollution prevention, and the protection and restoration of biodiversity and ecosystems. Within these sustainable objectives the Fund invests sector- and tech-agnostic into transitional, enabling, or direct impact businesses.

Furthermore, a part of the Fund’s impact analysis during investment process and portfolio management for each Investee Company and its products/services is a “do no significant harm” (DNSH) analysis based on the principles of adverse impact indicators (“PAIs”).

Post investment the Fund has an engagement strategy (“impact-as-a-service”), which includes, among other, impact & ESG KPI and target setting for every investment.

To monitor and report its performance regarding the sustainable investment objectives and principles of adverse impact, the Fund collects data annually from its investee companies. This data includes information on adverse impacts and relevant impact indicators, enabling the Fund to provide comprehensive yearly portfolio reports to its investors.

To assess good governance practices of the Investee Companies, the Fund evaluates the ESG points during the investment process through direct conversations with founders and through its ESG questionnaire.

The Investment Advisor’s research has shown there are currently no specifically and significantly relevant benchmarks available for products categorized under Article 9 SFDR investing in early-stage venture and technology-companies that invest across both private and public markets. Therefore, there is no benchmark chosen for the Fund.

No significant harm to the sustainable investment objective

The Fund’s sustainability and impact assessments have two objectives: (1) to assess and validate the net positive outcomes of a potential investment against its impact guidelines and impact investment thresholds and (2) ensure adherence to the do no significant harm principles and that any potential negative outcomes or controversies associated with the OECD Guidelines for multinational companies and/or the UN Global Compact are understood, managed and mitigated.

In order to analyze potential negative outcomes, the Fund first conducts an internal theory of change assessment that takes into account impact logic steps, which help guide due diligence efforts. From an impact perspective, the Fund evaluates impact risks and corresponding mitigation strategies. These risks might result from the product, the business model, or the operations of the company, among others. To the extent that a life cycle assessment (LCA) is key in understanding the positive and negative outcomes of a product or service, the Fund either analyzes peer reviewed scientific studies or company LCAs.

The Fund also assesses environmental, social and governance risks and opportunities during the investment process through management conversations and a sustainability questionnaire and integrates this information into the final investment decision and post-investment engagement strategy. These ESG factors include the principal of adverse impact indicators that are relevant to the specific company being evaluated.

Should a potential investment or portfolio company fail to meet the ‘do no significant harm’ safeguards, the Fund might decide to issue a negative investment decision or follow-on recommendation.

Sustainable investment objective of the financial product

The Fund operates under sustainable investment objectives that are linked to corresponding sustainability indicators. These indicators are integrated into the entire value- and process-chain for its investment decision-making and post-investment engagement strategy:

The (qualitative) sustainable investment objective of the Fund is to provide value-additive capital for tech-entrepreneurs who help solving the climate crisis and advance (climate) justice. It invests in inclusive and ambitious founders who are building impact technologies that have the potential to reduce significant CO2e at scale.

The majority of investments are geared towards climate impact in terms of reduction or removal of CO2e emissions. However, the Fund is able to also invest in social investments that aim to advance social equality and empower people in relation to the United Nations sustainable development goals with special focus on quality education. Even though, social investments are not a primary objective of the Fund.

As part of this (on a quantitative level), every investment must have the potential to demonstrate measurable impact in accordance with either one of the United Nations Sustainable Development Goals (the “UN SDGs”) or at least one of the environmental objectives, namely:

• (a) climate change mitigation;
• (b) climate change adaptation;
• (c) sustainable use and protection of water and marine resources;
• (d) transition to a circular economy;
• (e) pollution prevention and control;
• (f) the protection and restoration of biodiversity and ecosystems.

Consequently, the Fund invests on a sector-agnostic and tech-agnostic level with the aim of financing both transitional, enabling, and direct impact companies that align with the previously outlined objectives.

Investment strategy

First, the Fund’s investment strategy is focused on companies whose products or services inherently contribute towards sustainable investment objectives. As a first step, every potential investment has to be assessed against the Fund’s impact guidelines: Intentionality, Impact Logic Model, Interlock, Impact Scale, Additionality and Impact Measurement.

Second, the Fund’s investment focus is categorized in five high-level clusters, while each of the clusters is subdivided into several sub-clusters that are each guided by a specific investment thesis:

• • Energy Transition
• • Carbon Economy
• • Ecosystems & Biodiversity
• • Industrial Decarbonization
• • Climate Jobs/Education

In each cluster, different technologies are applied to achieve the sustainable investment objective. Typically, the product strategies of the investee companies aim to improve, mitigate, or adapt to environmental/climate challenges, to implement circularity in certain industries or for certain resources, to preserve, protect or restore certain resources or ecosystems (including e.g. biodiversity), or to improve lives and livelihoods.

Third, specific impact and ESG assessments regarding the sustainable investment objective and good governance practices are integrated across the entire investment process, governance, and portfolio management of the Fund. As part of its prohibited investments policy the Fund has explicitly excluded investments in harmful industries such as fossil fuels, tobacco, firearms, nuclear weapons, pornography, and alcohol, among others.

Proportion of investments

The fund invests in early stages, primarily in Europe.

At least 80% of the Fund’s investments will qualify as sustainable investments. A minimum of 80% are direct investments into climate startups (pursuing environmentally sustainable objectives). The Fund has no minimum commitments in relation to social investments or investments aligned with the EU Taxonomy.

The 20% designated for “non-sustainable” investments comprises two components: investments intended for liquidity purposes and to hedge the Fund, and Micro Investments that are exempt from scrutiny and reporting due to their lack of economic significance for the Fund but generally still adhere to its sustainable investment objectives.

Monitoring of the sustainable investment objective

As part of the Fund’s aligned commitment to ensure a substantial contribution to sustainability, it aims to sign an impact & ESG clause with portfolio companies. This clause includes a series of commitments, from carbon accounting to impact management. Whenever possible, the Fund selects impact and ESG performance indicators and annual targets with each portfolio company. Data is collected, at least, on an annual basis, and then used in sustainability engagement conversations with the responsible impact & ESG officer. Based on the assessment, the Fund provides and tailors impact & ESG resources.

As part of its periodic disclosure the Fund will exclusively report the aggregated (primary) Fund Key Performance Indicators (KPIs) and will provide detailed reports on the underlying KPIs for individual portfolio companies.

Note: ESG & impact measurement / management and the Impact Clause can only be guaranteed to be implemented at those portfolio companies where the Fund is leading/co-leading the investment round or has sufficient influence over the company’s other investors and management.

Download PAI Statement (PDF)

I. Sustainability risks

AENU Management GmbH incorporates sustainability risk assessment into investment decisions. Sustainability risks are defined as environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment.

Due diligence process includes:

• • Identification of material ESG topics for each prospective investment
• • Comprehensive ESG analysis using self-reported startup data from ESG questionnaires
• • Engagement with companies when unmitigated risk exposure exists
• • Potential discontinuation of investment if necessary
• • Application of proportionality principles considering strategic relevance and transaction context

II. Remuneration policies

As a registered AIFM under German Investment Code (KAGB) Section 2(4) and a qualifying venture capital fund manager per Regulation (EU) No. 345/2013 (EuVECA-Regulation), AENU Management confirms it does not have and does not need to have a remuneration policy in accordance with the requirements of the KAGB.

III. Statement on principal adverse impacts

Summary

AENU Management considers principal adverse impacts of investment decisions on sustainability factors. This is their first website statement on principal adverse impacts on sustainability factors within the meaning of Art. 4 SFDR.

Sustainability factors include:

• • Environmental concerns
• • Social concerns
• • Employee concerns
• • Respect for human rights
• • Fight against corruption and bribery

Mandatory indicators 1–14 as stipulated in Table 1, Annex I of Delegated Regulation (EU) 2022/1288 are considered.

Optional indicators selected:

• 1. Investments in companies without carbon emission reduction initiatives (Table 2, No. 4)
• 2. Investments in companies producing chemicals (Table 2, No. 9)
• 3. Number of days lost to injuries, accidents, fatalities, or illness (Table 3, No. 3)

BaFin registration obtained 24 February 2025. AENU Fund II first closing expected Q4 2025. Initial investments expected Q1 2026. First consolidated PAI statement covers 1 January 2026 – 31 December 2026, to be published by 30 June 2027.

Zusammenfassung

AENU Management berücksichtigt die wichtigsten nachteiligen Auswirkungen seiner Investitionsentscheidungen auf Nachhaltigkeitsfaktoren. Dies ist die erste Website-Erklärung zu den wichtigsten nachteiligen Auswirkungen auf Nachhaltigkeitsfaktoren im Sinne von Art. 4 SFDR.

Nachhaltigkeitsfaktoren:

• • Umwelt-, Sozial- und Arbeitnehmerbelange
• • Achtung der Menschenrechte
• • Bekämpfung von Korruption und Bestechung

Obligatorische Indikatoren 1–14 gemäß Tabelle 1, Anhang I der Delegierten Verordnung (EU) 2022/1288 werden berücksichtigt.

Optionale ausgewählte Indikatoren:

• 1. Investitionen in Unternehmen ohne Initiativen zur Reduzierung von CO2-Emissionen (Tabelle 2, Nr. 4)
• 2. Investitionen in Unternehmen, die Chemikalien herstellen (Tabelle 2, Nr. 9)
• 3. Anzahl der durch Verletzungen, Unfälle, Todesfälle oder Krankheit verlorenen Tage (Tabelle 3, Nr. 3)

BaFin-Registrierung am 24. Februar 2025. First Closing des AENU Fonds II erwartet letztes Quartal 2025. Erste Investitionen erwartet erstes Quartal 2026. Erste konsolidierte Erklärung: Referenzzeitraum ca. 1. Januar 2026 – 31. Dezember 2026. Veröffentlichung spätestens 30. Juni 2027.

Description of principal adverse impacts on sustainability factors

AENU Management will publish a table with sustainability indicators from Tables 1–3 of Annex I RTS for the first reference period (beginning 2026) by 30 June 2027 at the latest.

Description of policies to identify and prioritise principal adverse impacts

Elena Harumi Stark (Head of Impact & ESG) holds responsibility for implementation and application. Policies were approved by AENU Management’s governing body in April 2025.

The indicators as set forth in no. 1 to 14 in the table above are mandatory according to the RTS. All other indicators were chosen by AENU Management by taking into account their relevance with respect to AENU Management’s business strategy.

Before each investment, AENU Management conducts comprehensive due diligence. An ESG questionnaire tailored to company location, size, business model, and development stage is distributed via their reporting platform.

Following materiality assessment, the firm evaluates adverse impact indicators with focus on those material to the specific company. Investment opportunities presenting sustainable investment risks that cannot be prevented or considerably reduced will not proceed.

During holding periods, AENU Management regularly checks for adverse impacts on material sustainability factors. Data collection occurs directly from portfolio companies or through reasonable assumptions. Errors cannot be excluded completely. Yet, AENU Management will always endeavour to identify such errors or inaccuracies and to intervene as appropriate.

When principal adverse impacts are identified at portfolio company level during holding phases, the Fund discusses case-by-case appropriate mitigation actions with each portfolio company.

Policies undergo regular annual re-evaluation to reflect legal/regulatory changes, data availability, and market developments.

Engagement policies

AENU Management has established an “impact-as-a-service” engagement strategy to reduce principal adverse impacts.

Impact and ESG information rights are legally secured through Impact & ESG side letter clauses. Whenever possible, the Fund selects impact and ESG performance indicators and annual targets with each portfolio company. Data collection occurs at least annually.

The Fund will engage with portfolio companies regarding any potential principal adverse impacts. Where impacts show no reduction over multiple periods, AENU Management will support the portfolio company in implementing mitigation measures and/or ensure board-level attention.

References to international standards

Memberships:

• • Leaders for Climate Action
• • Impact VC
• • Venture ESG

While AENU Management is committed to continuously improving its climate-related strategies, it has not, as of today, formally committed to the specific objectives of the Paris Agreement. Due to early-stage fund investments, data quality and availability present significant challenges. AENU Management prioritizes net emission savings as a relevant and actionable measure of climate impact, rather than applying a forward-looking climate scenario.

IV. Sustainability-related disclosures

AENU II GmbH & Co. KG — LEI: [in process]

Summary

AENU II GmbH & Co. KG (the “AENU Fund II” or the “Fund”) is managed by AENU Management. The Fund has sustainable investments as its objective (cf. Art. 9(2) SFDR). The Fund will only make “sustainable investments” within the meaning of Art. 2(17) SFDR.

Sustainable investment means an investment in an economic activity that contributes to an environmental or social objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices.

The Fund will make a minimum of 80% sustainable investments with environmental objectives, likely contributing to:

• 1. Climate change mitigation
• 2. Climate change adaptation
• 3. The sustainable use and protection of water and marine resources
• 4. The transition to a circular economy
• 5. Pollution prevention and control
• 6. The protection and restoration of biodiversity and ecosystems

Impact methodology uses the Systemic Impact Framework developed by AENU Management. Social sustainable investments (maximum 20%) aimed to advance social equality per UN SDGs. Not a primary objective.

Screening approach: both inclusion (impact screening) and exclusion (negative screening per exclusion policy). Impact KPIs: specific impact metrics/outcomes defined prior to investment, reflecting Theory of Change.

A reference benchmark for attaining the sustainable investment objective has not been designated for the Fund.

No significant harm to the sustainable investment objective

The Fund will not significantly harm any sustainable investment objective by considering principal adverse impacts. Same mandatory (1–14) and optional (3) indicators as listed in Section III apply.

Good governance practices: governance-related questions integrated into pre-investment ESG due diligence, post-investment monitoring, and engagement processes.

Given that the Fund primarily invests in early-stage companies based in Europe, formal compliance with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights may not be relevant at the time of investment.

PAI indicators 10 and 11 from Table 1 ensure receipt of relevant compliance information.

Sustainable investment objective of the financial product

The Fund pursues Theory-of-Change based impact investing in early-stage venture and technology companies. Impact must be clearly measurable and inherently integrated into the business model.

Environmental focus (80% minimum): climate change mitigation, climate change adaptation, sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, and protection and restoration of biodiversity and ecosystems.

Social investments (20% maximum): aimed to advance social equality per UN SDGs. Not a primary objective of the Fund.

Investment strategy

The Fund’s purpose is to build, hold, and manage a portfolio of equity and equity-related investments in portfolio companies meeting the Investment Scope.

Investment scope sectors:

• • Climate
• • Energy
• • Decarbonization
• • Food and agricultural technology
• • Mobility and buildings
• • Industrial and materials
• • Enterprise and finance

Geographic focus: EU, United Kingdom, EFTA Countries (at initial investment).

It must be impossible for the investment to achieve commercial success without simultaneously creating a positive impact (“Impact Interlock”).

Exclusion policy

• 1. Prohibited Substances & Wildlife: Banned chemicals, hazardous waste, endangered wildlife, ozone-depleting substances (Rotterdam Convention, Basel Convention, CITES, Montreal Protocol)
• 2. Fossil Fuels & High-Emission Industries: Fossil fuel extraction and high-emission industries inconsistent with decarbonization
• 3. Environmental Degradation: Unsustainable agricultural/forestry practices, unbound asbestos, large-scale habitat alteration
• 4. Human Rights & Ethical Standards: Exploitative practices, human rights violations, unethical research (e.g. human cloning), activities lacking FPIC
• 5. Unethical Business Models: Illegal operations, sanctioned entities, pornography, gambling, tobacco, non-medical animal testing, fur trading
• 6. Conditional Sectors: GMOs and Clean Transition Technologies require extensive due diligence and LPAC approval

Good governance practices

Assessed as part of every due diligence process. Includes:

• • Sound management structures
• • Employee relations
• • Remuneration of staff
• • Tax compliance

Regular monitoring during holding periods. Framework with Impact & ESG clauses in shareholder agreements.

Proportion of investments

The intention of AENU Management is that 100% of the investments made by the Fund shall be aligned with the sustainable investment objective.

Monitoring of the sustainable investment objective

Impact KPIs defined prior to each investment. 1 to several KPIs per portfolio company. Routine reporting: 1–4 Impact KPIs per company.

Indicative Impact KPI examples:

• • Emission savings (enabled) — tons of CO2e
• • Energy savings (enabled) — MWh
• • Renewable energy production (enabled) — MWh
• • Climate vulnerable assets protection (enabled) — financial value (EUR or USD)
• • Land protected, restored, or managed sustainably — hectares

The Fund uses reasonable efforts to quality check and stress test the collected data.

Methodologies

Impact KPIs collected annually and ad hoc. PAI indicators collected on regular basis. Measurement and evaluation is ongoing.

Data sources and processing

Data collected at least annually from portfolio companies. ESG questionnaire during due diligence via reporting platform.

AENU Management estimates that around 75% of the relevant data will be estimated or supplemented by information publicly available.

Limitations to methodologies and data

Early-stage companies may have incomplete or insufficiently granular data. Ownership stake evolution may limit direct access. Continuous improvement through industry collaboration and independent outside views.

Due diligence

Systemic Impact Framework — six categories:

• 1. Founder Intentionality — founders’ commitment to climate/social challenges
• 2. Additionality — solution effectiveness vs. incumbents and baselines
• 3. Theory of Change — robustness of research evidence linking problem to solution
• 4. Interlock — commercial success and impact achievement are fundamentally intertwined
• 5. Impact Measurement & Management — systematic quantification, tracking, reporting
• 6. Impact Scale — breadth, depth, and scalability of impact

Engagement policies

Impact and ESG information rights secured through side letter clauses. Annual performance indicators and targets. Response with individual measures for ESG incidents/controversies.

Attainment of the sustainable investment objective

No reference benchmark designated. There are currently no relevant benchmarks available for products categorized under Art. 9 SFDR investing in early-stage venture and technology-companies.

Paris Agreement: not formally committed. Prioritizes net emission savings over forward-looking climate scenarios.