Sustainability policy

Information provided by 24Ventures Sp. z o.o. as an external in compliance with the requirements of Regulation 2019/2088 of the European Parliament and of the Council (EU) of 27 November 2019 on disclosure of information related to sustainable development in the financial services sector (“SFDR Regulation”).

Introduction	The SFDR Regulation introduces uniform requirements within the European Union for financial products and financial market participants regarding the disclosure of information related to sustainable development, in particular information on the strategies adopted in the scope of their business activities concerning the introduction of risks to sustainable development (including taking into account adverse effects on sustainable development). These risks are defined as environmental, social or governance situations or conditions that, if they occur, could have an actual or potential material adverse effect on the value of the investment. This information is disclosed via the website, in the process of concluding agreements with clients and in certain cases also as part of periodic reports. 24Ventures sp. z o.o. is covered by the scope of application of the SFDR Regulation as a financial market participant, i.e. as a manager of alternative investment fund.
Transparency of strategy to the Sustainability Risk Article 3 Section 1 of the SFDR Regulation	The SFDR Regulation requires financial market participants to publish information on their websites about their strategies for introducing sustainability risks into their business in the investment decision-making process. 24Ventures Sp. z o.o. through AIF invests in early-stage companies that grow their businesses based on software products that in general aim to digitalize and automate processes. Although such companies, regarding their stage of development and scope of operations usually don't negatively affect environmental, social or governance factors, 24Ventures performs ESG analysis as a part of its due diligence process. A scope of due diligence may vary depending on the business. It should be emphasized that AIF implements investments financed from EU funds, where the decision-making process and asset allocation strategies take into account significant restrictions resulting from legal regulations or the principles of operation of programs providing such funds. At the same time, AIF also takes into account aspects that have a positive impact on the idea of sustainable development in its investment activities, including applying sectoral restrictions, within which AIF investments cannot be made for the purpose of financing specific types of activities conducted by or which the future portfolio company intends to conduct and which may give rise to risks to sustainable development. For the portfolio companies (after the investment of 24Ventures) we require the reporting of ESG data for the purpose of monitoring an investment.
Transparency on adverse sustainability impacts at entity level Article 4 Section 1 letter b in connection to Article 7 Section 2 of the SFDR Regulation	By major adverse impacts we mean those impacts of investment decisions that have an adverse effect on sustainable development factors. By "sustainable development factors" we mean environmental, social and labour issues, issues related to respect for human rights and combating corruption and bribery. In accordance with Article 4, Section 1, letter b of the SFDR Regulation, 24Ventures sp. z o.o. informs that at present its business does not envisage taking into account the main adverse effects of investment decisions on sustainable development factors from the perspective of the impact of the investment on the environment. The above is dictated primarily by the fact that investment decisions made by 24Ventures sp. z o.o., in its opinion, have a positive impact on sustainable development factors. These decisions do not contribute to the occurrence of negative effects or are not directly related to them. In addition, this also results from the nature of the business conducted and the product offered, which is AIF, and is also caused by the limited availability of development indicators resulting from the lack of full legal regulation in this area, including the ongoing work of the joint committee of the European Banking Authority (EBA), the European Insurance and Occupational Pensions Authority (EIOPA) and the European Securities and Markets Authority (ESMA) on the development of draft regulatory technical standards (RTS) to clarify the SFDR, including in terms of the content, methods and presentation of information related to sustainability indicators in relation to climate and other adverse environmental effects, social and labour issues, respect for human rights and combating corruption and bribery, or the period for which these standards enter into force or apply. Due to the fact that no risks to sustainable development are expected in the investment process, there are no major adverse effects of investment decisions on sustainable development factors from the perspective of the investment's impact on the environment. As indicated above, AIF takes into account aspects that have a positive impact on the idea of sustainable development, including applying sectoral restrictions, within which AIF investments cannot be made for the purpose of financing specific types of activities conducted by or intended to be conducted by the future portfolio company and which may give rise to risks to sustainable development. 24Ventures sp. z o.o. does not rule out taking into account major adverse effects of investment decisions on sustainable development factors in the future when managing AIF.
Transparency of remuneration policies in relation to the introduction of sustainability risks into the business Article 5 Section 1 of the SFDR Regulation	In accordance with the requirements of the SFRD Regulation, financial market participants and financial advisors include in their remuneration policies information on how to ensure the consistency of these policies with the introduction of sustainability risks into their activities and publish this information on their websites. 24Ventures sp. z o.o. informs that it is not an entity obliged to adopt a remuneration policy, therefore the above requirement does not apply to it, and furthermore - as already indicated above, it does not introduce sustainability risks into its activities. In accordance with Article 13 Section 1 of Directive 2011/61/EU, Member States shall require AIFMs to have remuneration policies and practices; remuneration policies and practices must be consistent with and promote sound and effective risk management and must not encourage the taking of risks that are inconsistent with the risk profiles, rules or instruments of incorporation of the AIFs they manage. 24Ventures sp. z o.o. is not obliged to apply a remuneration policy – in accordance with Article 3 Section 2 of this Directive, the above provisions do not apply to AIFM managing AIF portfolios (directly or through an undertaking with which the AIFM is linked by common management or control or by a substantial direct or indirect shareholding), where the total value of assets under management, including assets acquired using leverage, does not exceed the threshold of EUR 100 million in total; or does not exceed the threshold of EUR 500 million, where the AIF portfolios consist of AIFs that do not use leverage and in which redemption rights cannot be exercised for a period of five years from the date of initial investment in each AIF. Under Polish law, the above has been regulated by the Act on Investment Funds – Article 70j provides an obligation regarding remuneration policy, but this provision does not apply to an AIFM who performs the activities specified in Article 70e Section 1 without the Commission's permission, after being entered into the register of AIFM (exclusion from Article 70zb Section 4).
Products that promote an environmental or social aspect (or both) or aimed at sustainable investment Article 8 and Article 9 in connection to Article 10 Section 1 of the SFDR Regulation	24Ventures sp. z o.o. does not offer financial products that promote environmental or social aspects (or both), or aimed at sustainable investments.

In accordance with Article 12 Section 1 of the SFDR Regulation, Financial Market Participants shall ensure that any information published in accordance with Article 3, 5 or 10 is kept up to date. In the event that a Financial Market Participant changes such information, it shall publish on the same website a clear explanation of such change. Therefore, in the event of a change in the information presented, 24Ventures sp. z o.o. shall update it accordingly.