Inven Capital Environmental, Social, and Governance “ESG” Policy

Contents
Inven Capital’s view on ESG ................................................................................................................ 3
ESG in the investment Process............................................................................................................ 31.

Pre-investment screening & due diligence ................................................................................. 3
Exclusion Policy ............................................................................................................................... 4
Anti-bribery, anti-corruption (ABAC) and anti-money laundering (AML) due diligence ................ 6
Legal due diligence .......................................................................................................................... 7
ESG readiness evaluation ................................................................................................................ 7a.

Methodology........................................................................................................................... 7b.

Data collection process ........................................................................................................... 8c.

Risk & performance evaluation............................................................................................... 8

Term sheet sustainability clause ..................................................................................................... 92.

Transaction documentation ESG clauses .................................................................................... 93.

Post-investment portfolio support ........................................................................................... 10
Onboarding process ...................................................................................................................... 10
Continuous support and regular progress evaluation .................................................................. 10

4.

Exit readiness ............................................................................................................................ 10

ESG at Inven ...................................................................................................................................... 11
Investors and SFDR reporting ........................................................................................................... 11
Appendix 1 – List of collected ESG data ............................................................................................ 13
Appendix 2 – Inven ESG readiness evaluation tool........................................................................... 20
Appendix 3 – ECS Requirements transaction documentation .......................................................... 27
Appendix 4 - Change log ................................................................................................................... 29

Inven Capital’s view on ESG
Our core values have always led the work we are doing. Those values include respecting both ourplanet and people in our investment process and our own operations.
We are a climate tech fund that intends to invest into start-ups with a potential to benefit ourenvironment and reduce greenhouse gas emissions. At the same time, we believe in the importanceof social and governance aspects of their operations which make their business models more resilient
and ready to face upcoming challenges as well as reducing risk for the investors like us.
Therefore, we use a set of environmental, social and governance indicators (ESG framework), to
integrate the planet and people values holistically into our investment sourcing, pre - investment due
diligence, portfolio management as well as exit processes. As ESG is a to a great extent a voluntary,
non-regulatory framework, with many different definitions, we have implemented a strategy basedon the aggregation of the current industry best practices and plan to review it on a regular basis.
Inven ESG Policy describes the process how we assess start-ups regarding their ESG readiness andsustainability risks during the investment process as well as our approach to assisting our portfolio
companies with ESG implementation during portfolio management.

ESG in the investment process
Our ESG framework is integrated in our whole investment process starting with selection of potential
investments (sourcing) and detailed analysis during the due diligence phase, followed by regularannual assessments and support of our portfolio companies with the goal to make them ready for anexit or corporate ESG reporting requirements.
1. Pre-investment screening & due diligence• Exclusion Policy• Anti-bribery, anti-corruption (ABAC) and anti-money laundering (AML) due diligence• Legal due diligence• ESG readiness evaluation- Methodology- Data collection process- Risk & performance evaluation• Term sheet sustainability clause
2. Transaction documentation sustainability clauses
3. Post-investment portfolio support• On-boarding workshop• Continuous support and regular progress evaluation
4. Exit readiness1. Pre-investment screening & due diligence
During the pre-investment process we first verify that the start-up is not active in any of the excluded
business activities as defined in the exclusion policy below. We strictly avoid companies that would
engage in any of these excluded activities.

The due diligence process further includes anti-bribery and anti-corruption assessment performed byan independent external provider as well as an anti-money laundering check performed by the fund´scompliance officer. In case we find any fraudulent conduct, the company had been involved in, we are
not going to proceed with the investment.
Further, we engage with a third independent party to perform a legal due diligence of the potential
investee. This due diligence normally includes appraisal of corporate laws, labour laws, contracts,
litigations and data protection. We proceed with the investment only if the due diligence has not
identified any illegal or compromising behaviour.
Simultaneously, we perform our internal ESG readiness evaluation described below to find out
whether a start-up is acquainted with the ESG framework. The results of the ESG evaluation are
integrated subsequently in our investment approach as a portfolio management tool. Unmanaged
potential risks (red flags) uncovered by the ESG evaluation will not exclude potential investments but
will point out areas that have to be worked on with increased focus.
The results of the due diligence and our ESG risk assessment are presented to our investmentcommittee in a Deal qualifying memorandum and are considered during the investment decision
making process.

Exclusion Policy
When we look for potential investment opportunities, we carefully analyse the business models andstrictly avoid start-ups (and its subsidiaries) engaged in any of the excluded activities listed below.
"Excluded Activities" shall mean any of the following activities:
1. Projects which result in limiting people’s individual rights and freedom, or violation of humanrights, such aso Prisons and detention centers of any form (e.g., correctional institutions or police stations
with detention facilities); ando Health sector projects with “secure units” such as closed psychiatric wards; ando Any activities which are known directly or indirectly to result in harmful or exploitative formsof forced labour10 or harmful child labour11, as defined by the ILO (International Labour
Organization) Fundamental Labour Conventions.
2. Projects unacceptable in climate and environmental terms

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Forced labour means traditional practices of forced labour, such as vestiges of slavery or slave-likepractices, and various forms of debt bondage, as well as new forms of forced labour that have emerged inrecent decades, such as human trafficking, also called “modern-slavery” to shed light on working andliving conditions contrary to human dignity
Harmful child labour means the employment of children that is economically exploitive, or is likely to be
hazardous to, or to interfere with, the child's education, or to be harmful to the child's health, or physical,
mental, moral or social development. In addition any labour that is performed by a person which has not
yet reached the age of 15 is considered to be harmful, unless the local legislation specifies compulsory
school attendance or the minimum age for working to be higher; in such cases, the higher age will beapplied for defining harmful child labour

o
o

o
o

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Any activity involving significant degradation, conversion or destruction12 of critical habitats13;
Conversion of natural forests into plantation. This includes irrigated forests14, logging, clear
cutting or degradation of (and commercial concessions over) tropical natural forests or highconservation value forests15 in all regions, as well as the purchase of logging equipment forthis purpose;
Unsustainable fishing methods (such as drift net fishing in the marine environment using nets
in excess of 2.5 km in length and blast fishing);
Extraction of mineral deposits from the deep sea16; ando Extraction or mining of conflict minerals and metals17.
Destruction means (1) the elimination or severe diminution of the integrity of an area caused by a major,
long-term change in land or water use or (2) modification of a habitat in such a way that the area’s ability
to maintain its role is lost
Critical habitat is a subset of both natural and modified habitat that deserves particular attention. Critical
habitat includes areas with high biodiversity value that meet the criteria of the International Union forConservation of Nature (“IUCN”) classification, including habitat required for the survival of criticallyendangered or endangered species as defined by the IUCN Red List of Threatened Species or as definedin any national legislation; areas having special significance for endemic or restricted-range species; sitesthat are critical for the survival of migratory species; areas supporting globally significant concentrations
or numbers of individuals of congregatory species; areas with unique assemblages of species or which areassociated with key evolutionary processes or provide key ecosystem services; and areas having
biodiversity of significant social, economic or cultural importance to local communities. Primary Forestor forests of High Conservation Value shall be considered Critical Habitats. Critical Habitats include
species under strict protection in accordance with Articles 12-16 of the Habitats Directive (Directive
92/43/EEC on the conservation of natural habitats and of wild fauna and flora, as amended)
Except for temporary watering in the first 3 years after planting, which is allowed for the seedlings todevelop deep rooting systems to ensure high survival rates
High conservation value forests are defined by the Forest Stewardship Council as those that possess one
or more of the following attributes: 1) forest areas containing globally, regionally or nationally significant
concentrations of biodiversity values (e.g. endemism, endangered species, refugia); 2) forest areas
containing globally, regionally or nationally significant large landscape level forests, contained within, or
containing the management unit, where viable populations of most if not all naturally occurring species
exist in natural patterns of distribution and abundance; 3) forest areas that are in or contain rare, threatenedor endangered ecosystems; 4) forest areas that provide basic services of nature in critical situations (e.g.
watershed protection, erosion control); 5) forest areas fundamental to meeting basic needs of local
communities (e.g. subsistence, health); 6) forest areas critical to local communities' traditional cultural
identity (areas of cultural, ecological, economic or religious significance identified in cooperation withsuch local communities).
Deep sea is defined as the areas of the ocean below 200m - The International Seabed Authority and Deep
Seabed Mining. United Nations.
Minerals and metals covered by the Regulation (EU) 2017/821 laying down supply chain due diligenceobligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflictaffected and high-risk areas, as amended.
PCBs: Polychlorinated biphenyls are a group of highly toxic chemicals.
Commission Regulation (EU) 2016/1005 of 22 June 2016 amending Annex XVII to Regulation (EC) No
1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation,
Authorisation and Restriction of Chemicals (REACH) as regards asbestos fibres (chrysotile).
Ozone Depleting Substances (ODS) mean chemical compounds, which react with and delete stratosphericozone, resulting in "holes in the ozone layer". The Montreal Protocol on Substances that Deplete the Ozone
Layer lists ODs and their target reduction and phase-out date.
Regulation (EU) 2017/852 of the European Parliament and of the Council of 17 May 2017 on mercury.
Based on Stockholm Convention on Persistent Organic Pollutants (POPs) as amended in 2009.
Based on Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their
Disposal; Regulation (EC) No 1013/2006 of 14 June 2006 on shipments of waste; and DecisionC(2001)107/Final of the OECD Council concerning the revision of Decision C(92)39/Final on the control
of transboundary movements of wastes destined for recovery operations.
Unless in compliance with EU Directive 2001/18/EC and EU Directive 2009/41/EC, and related country
legislation, as further amended.

3. Activities prohibited by applicable national law and EU lawso This includes any products or activities subject to international phase out or bans, including
production of or trade in products containing PCBs9; production, placing on the market anduse of asbestos fibres10; production, use of or trade in ozone depleting substances11 and othersubstances which are subject to international phase-outs or bans, including pharmaceuticals,pesticides/herbicides, chemicals12 , and other hazardous substances; trade in mercury,mercury compounds, and a large range of mercury-added products13; production or use of ortrade in persistent organic pollutants14; production or trade in wildlife or wildlife products
regulated under the Convention on International Trade in Endangered Species of Wild Fauna
and Flora (CITES); transboundary movements of waste prohibited under public international
law15;
o Cross-border trade in waste and waste products unless compliant with the Basel Convention
and the underlying national and EU regulations but for the avoidance of doubt, use of waste
as a fuel in district heating is not excluded;o Activities prohibited by host country legislation or international legal instruments ratified by
the EU, relating to the protection of biodiversity resources, or cultural heritage; ando Any activities relating to the deliberate release of Genetically Modified Organism (GMO)16.
4. Ethically or morally controversial projects
o Animal and human reproductive cloning;o Activities involving live animals for scientific and experimental purposes, including gene
editing and the breeding of these animals17;
o Sex trade and related infrastructure, services and media;
o Projects with the purpose of producing, manufacturing, processing or distribution of tobacco;o Gambling and related equipment, casinos, and equivalent enterprises or hotels hosting such
facilities17; ando Projects with political or religious purpose.
5. Ammunition and weapons, including explosives and sporting weapons, as well as equipment or
infrastructure dedicated to military/police use, infrastructure or correctional facilities, prisons.
6. Any business relating to pornography or prostitution.
7. Production or trade in any product or activity deemed illegal under host country laws or
regulations or international conventions and agreements.
8. Production and distribution of racist, anti-democratic and/or neo-Nazi media.

Anti-bribery, anti-corruption (ABAC) and anti-money laundering (AML) due
diligence
During the pre-investment phase we also have a third party to perform anti-bribery and anticorruption due diligence on the target companies to avoid start-ups who or whose founders andmanagers have been involved in any kind of criminal or compromising behaviour in the past.
We also check the ownership structure and the ultimate beneficial owner of the potential investee
company. We do not invest into companies with opaque ownership structures.

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Unless in compliance with (EU) Directive 2010/63/EU as amended by Regulation (EU) 2019/1010 of theEuropean Parliament and of the Council on the protection of animals used for scientific purposes.
Projects whose main purpose is other than gambling are excluded if more than 10% of its annual revenues
is generated by gambling.

Inven’s independent compliance officer performs an anti-money laundering check according to theapplicable AML law before we make an investment. We would not invest into companies involved in
any AML related offences.

Legal due diligence
An independent provider performs a legal due diligence of the potential investee. This due diligencenormally includes appraisal of corporate laws, labour laws, contracts, litigations and data protection.
The results of the due diligence are provided in a due diligence report and a summary is presented toour investment committee as part of the Deal qualifying memorandum. In case any illegal orcompromising behaviour is detected we do not proceed with the investment.

ESG readiness evaluation
We aim to bring up ESG early in the due diligence process in order to get a sense of the founders’mindset and the general start-ups approach towards ESG management.

a. Methodology
Our methodology consists of 10 clusters portraying different topics the start-up should take into
consideration. Each cluster consists of specific indicators representing risks and opportunities. Data
related to these clusters are collected directly form the start-ups (See Data collection process section
below) and evaluated using our proprietary tool as described in Risk & performance evaluation section
below. The clusters are:●General environmento We look at the holistic view of the start-up’s environmental risk management, i.e.
does the start-up have an environmental commitment, short or long term targets
and objectives.

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Carbon footprinto We assess the start-up’s approach to managing their carbon footprint, bymeasuring, setting targets and reducing their impact across all scopes.

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Material Managemento We ask about the management of energy, water, and waste.

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Supply chaino We ask about work towards an ethical supply chain, managing the suppliers toensure the start-up’s values are kept throughout their entire value chain.

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Employeeso We assess the existence of a strong team and culture, managing employees’ needs,
professional development and work environment to strive to a high talent level andretention of talent.

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Customers/ end userso We assess if the start-up maintains a strong relationship with all forms of customers
and users of the product or service; creates a dialogue on their needs andsatisfaction from the start-up’s work, with emphasis on installing a cybersecurity
policy and structure to secure their information.
●

Communityo We analyse aspirations to work with local suppliers and contribute to the local
community, by sharing or initiating projects relating to the internal start-up’s skills,
talent, or product.

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Diversity and inclusiono We ask if the start-up strives to integrate inclusion practices in all business aspects,
with the goal of creating a diverse team, management, and the board.

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General governanceo We check if the company upholds all laws and regulations and maintains a highcompliance standard.

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Board of directors
o We evaluate the incorporation of the best practices in the board structure and theoverseeing of the start-up’s journey.

b. Data collection process
Since the 2022 year-end we collect ESG indicators through a reporting platform provided by thecompany Worldfavor. Data are collected on annual basis through Worldfavor standard questionnairesthat meet the current market practice, requirements of SFDR (Regulation EU 2019/2088 on
sustainability‐related disclosures in the financial services sector), RTS (Regulation EU 2022/1288 on
regulatory technical standards and Regulation EU 2023/363 amending and correcting the regulatory
technical standards) and other common reporting standards. The list of collected ESG indicators is in
Appendix 1 of this document.

c. Risk & performance evaluation
Based on the collected data we perform a risk assessment which is performed by investment
managers in cooperation with Inven´s sustainability officer. The risk assessment is performed using
Inven internal methodology using a specific weight system. The weight system combines results fromthe data collected through Worldfavor platform and information gathered during interviews withstart-up representatives
The risk assessment composes of several key broad risk areas (size of the company, presence indeveloping countries, existence of an ESG policy) and 29 ESG KPIs with assigned weights. The weights
define which focus areas and KPIs will be managed first as they have the highest priority.
The risk assessment starts with the key broad areas that can influence the weights of the examined
29 ESG KPIs. After assessing the broad risk areas, we perform a review of the selected 29 ESG KPIs
and assign them scores based on our perception how well are these KPIs managed in the start-up. The
result is an ESG evaluation conclusion that we work with in the subsequent portfolio management.
Unmanaged potential risks (red flags) uncovered by the ESG evaluation will not exclude potential
investments but will point out areas that have to be worked on with increased focus.

ESG readiness evaluation tool is described more closely in Appendix 2 of this document.

Term sheet sustainability clause
We include a sustainability clause in our term sheets to ensure the companies understand theimportance we place on ESG and are prepared to implement their own ESG goals if they are not inplace yet.
Usually, we require the companies to perform the steps listed below within 12 months following theclosing:-

adopt and thereafter maintain in effect a climate Policy, including measurement and reportingof scope 1 and scope 2 emissions18,
evaluate and establish best practices of its business activities regarding environment, society
and governance (ESG); anddefine and implement a plan on how to define, measure and report on the sustainability
impact and performance of the company.

We require that this policy and measures shall be discussed with and reported to the board of
directors. Inven in cooperation with the main shareholders offers a reasonable support to the
management with the commitments mentioned above.

2. Transaction documentation ESG clauses
Our transaction documentation contains several ESG related clauses to ensure the company fulfils
our requirements. These are adjusted individually based on the ESG readiness and typically include:
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reporting obligations – the company should report information regarding developments or
initiatives at the company with respect to environmental, social (including health and safety,
employees, human rights, consumer and community issues) and corporate governancematters on annual basis;diversity and inclusion matters - the company shall consider in good faith interviewing atleast one (1) woman or a member of a population currently underrepresented within thecompany, as determined by the board of directors in its sole discretion, for each open
executive level employment position and each vacant independent director seat on theboard, if and when such a seat exists;
Environment and social standards (“ECS Requirements”) - environmental, climate and social
obligations to be undertaken by the company to ensure that there is compliance withEnvironmental and Social Law of EU or the country where the company is incorporated or
carries out its business activities including the continuing ban on excluded activities (ECS
requirements are listed Appendix 3);
Sustainability clause - the company shall, within 12 months following the signing of thetransaction documents, adopt and thereafter maintain in effect a climate policy, including
measurement and reporting of Scope 1 and Scope 2 emissions, at the company and its
subsidiaries; evaluate and establish best practices of its business activities in regards toenvironment, society and governance (ESG); and define and implement a plan on how to

18 ‘scope 1, 2 and 3 GHG emissions’ means the scope of greenhouse gas emissions referred to in points (1)(e)(i)to (iii) of Annex III to Regulation (EU) 2016/1011 of the European Parliament and of the Council; greenhousegas (GHG) emissions’ means greenhouse gas emissions as defined in Article 3, point (1), of Regulation (EU)2018/842 of the European Parliament and of the Council

define, measure and report on the sustainability impact and performance of the company
and its subsidiaries. Such policy and measures shall be discussed with and reported to theboard of directors, and the investors in the company shall reasonably support the
management with the commitments, mentioned above.

3. Post-investment portfolio support
After we have become investors, we define the next steps for the portfolio management based on the
conclusions on the state of the start-up ESG readiness. First, we prepare an onboarding process basedon the individual needs of every investee. We define goals based on the ESG readiness evaluation andtrack them on annual basis

Onboarding process
We present red flags and potential opportunities to the start-up leadership team. Based on the preinvestment evaluation, we set goals for improvements and set out a plan of action and support
requirements.
Where possible and relevant, we conduct an ESG/SDG workshop for the start-up’s leadership team(and other relevant team members) in order to deep dive on the potential risks and opportunities aswell as an initial roadmap for creating a management strategy.
We provide the start-up with Inven’s Onboarding Toolkit for ESG management, a set of example policy
documents, research, case studies and initiatives guides for managing different ESG focus areas.
We connect the start-ups to Inven’s experts’ network (e.g. consultants, other founders, specialistsetc.) for support in establishing a management strategy for the risk and opportunities detected.

Continuous support and regular progress evaluation
We continuously engage with our start-ups on improving the identified priority areas and share withthem any relevant information or tools that we gather from our expert network (e.g. VentureESG
group, Worldfavor platform etc).
Our start-ups have a continuous access to the Worldfavor platform that they can use not only as areporting tool, but also as a carbon footprint calculator and a source of information on the current
market approach towards ESG.
We perform annual assessment to detect progress in the risk and opportunity areas through repeateddata collection and interviews. Based on the annual assessment we define new risks and opportunity
areas to focus on for the next year.
We aim to bring the ESG topic to the board of directors meetings and actively provide our portfolio
companies with advice and support in ESG implementation. However, as we are minority shareholders
in our portfolio companies our ability to enforce our recommendations can be limited.

4. Exit readinessIn the case of exiting (via sale, M&A or IPO) we will consider possible ESG factors, too. Our portfolio
support described above is aimed at preparing our portfolio companies for exits regarding their ESG

readiness (right ESG policies, practices and reporting)so that they can fulfil requirements placed onthem by future investors or regulations for larger companies.

ESG at Inven
ESG does not only apply to how we invest and help our portfolio companies flourish and grow but it
is also an integral part how we internally manage our fund. We aim at applying the same ESG
considerations and the same standards we measure our portfolio with to ourselves; being in a strong
position when it comes to ESG ourselves not only makes our demands to portfolio companies morebelievable, it also strengthens our (economic and structural) position as a VC firm.
ESG responsibility
While every member of our (investment) team is concerned with and thinks along the lines of ESG
when making decisions and supporting portfolio companies, we have assigned the overall
responsibility for ESG to our Sustainability Officer and Investment Manager Kristýna Machová(kristyna.machova@invencapital.cz). Kristýna is steering and coordinating our ESG activities and ismaking sure that we stay on top of the most recent industry trends. She is being supported by our
Financial Manager Hana Uhlíková (hana.uhlikova@invencapital.cz) who is responsible for the ESG/SFDR reporting and compliance work. Our approach to ESG is discussed regularly in our operationaland strategic meetings and all investment team members are being educated on ESG topics.
Hiring and working environment
We are committed to hiring a diverse team (team members from different European countries, equal
proportion of women and men) and providing an inclusive working environment (several members of
our team work part-time and have flexible working hours so that they can manage their family
responsibilities).
Good governanceAll our decision making in both the board of directors and the investment committee is committed togood governance principles that are in detail defined in our set of internal guidelines, articles ofassociation and sub-funds statutes.
We have also been climate neutral in our operations as a fund since 2018, offsetting our emissions via
tree planting in the Czech Republic with a local NGO Sázíme stromy (sazimestromy.cz) and having
multiple initiatives to reduce our carbon footprint where possible (green travel, recycled paper,
filtered tap water etc.).
To always stay up-to-date on the recent market developments, we are partnering with leading global
communities such as Invest Europe, VentureESG, GITA: The Global Impact Tech Alliance,
WorldfavorandLeaders for Climate Action (Kickstart your climate action journey – Leaders for Climate
Action (lfca.earth).

Investors and SFDR reporting
Inven Capital is a fund of qualified investors and an alternative investment fund according to EU
regulations. Inven Capital has established 4 sub-funds (Sub-fund A, Sub-fund B, Sub-fund C, Sub-fundD) as of May 2023. All sub-funds are classified as Article 8 financial products according to SFDR
regulation. Even though, Sub-funds A and B are in their divestment phase and cannot make any newinvestments, we collect ESG data from their portfolio companies and support them on their ESG
journey. Sub-fund C and Sub-fund D are in their investment phase and will invest into new companies
until the end of 2026.
We prepare the following SFDR disclosures: fund level web disclosures on sustainability risk policies,
principal adverse impacts and remuneration policies, financial products (sub-funds) web disclosures,annual reporting included in the sub-funds annual reports, principal adverse impact statements. We
do not prepare precontractual information disclosures as we do not raise new capital during the lifeof our sub-funds. In case we would raise new capital, we will prepare the precontractual information
one month before doing so.

Appendix 1 – List of collected ESG data
ESG Data are collected through Worldfavor platform and include the following questions/ requests
for information:
Questions

Answeroptions

Biodiversity
Biodiversity management & impact
Upload your biodiversity policy or equivalent policy covering the protection of biodiversitysensitive areas

File upload

Describe your company's impact on biodiversity and natural ecosystems across the value chain
and how these impacts are managed

Comment

Upload your deforestation policy/commitment

File upload

Does the company negatively affect biodiversity-sensitive areas?

Yes, No

Climate Change
Climate change management
Which of the following climate change practices does your company have in place?

Options

Describe risks and opportunities identified related to climate change with the potential to havefinancial or strategic impact on your business

Comment

Describe your greenhouse gas (GHG) emissions reduction targets, or provide a link with more
information

Comment

Does your company derive any revenues from exploration, mining, extraction, production,
processing, storage, refining or distribution, including transportation, storage and trade, of fossil
fuels?

Yes, No

Scope 1, 2 & 3 GHG emissions
Total Scope 1 GHG emissions

Which categories are included in your company's Scope 3 emissions?

ton CO2
equivalents(tCO2e)ton CO2
equivalents(tCO2e)ton CO2
equivalents(tCO2e)Options

Is there a third-party verification or assurance process in place for GHG emissions data?

Yes, No

Total Scope 2 GHG emissions

Total Scope 3 GHG emissions

GHG emissions intensity
Scope 1 and 2 emissions intensity ratio

tCO2e/MEUR

Scope 3 emissions intensity ratio

tCO2e/MEUR

Energy
Energy management
Which of the following energy management practices does your company have in place?

Options

Upload your ISO 50001 certificate

File upload

Describe your company's energy targets and the progress against these targets

Comment

Energy performance
Total energy consumption

megawatt
hours (MWh)Energy intensity ratio

MWh/MEUR

Percentage of non-renewable energy consumption and production

percentage(%)

Environmental Practices
Environmental management practices
Which of the following environmental management practices does your company have in place?

Options

Upload your company's environmental policy

File upload

Upload your company's environmental management certificate (ISO 14001/EMAS)

File upload

Are environmental performance measures/KPIs regularly compiled and presented to top
management?

Yes, No

Waste & Resource circularity
Waste management & impact
Describe your company's actual and potential waste-related impacts along the value chain, andhow these are managed

Comment

Upload your waste management policy

File upload

Waste performance
Total weight of waste generated

tons (t)Total weight of waste recycled or re-used

tons (t)Total weight of hazardous waste generated

tons (t)Resource circularity
Provide details about any circularity measures taken by your company to increase recycling andre-use of input materials

Comment

Water
Water management & impact
Describe your company's water-related impacts across the value chain, and how these aremanagedComment

Upload your water management policy

File upload

Describe the measures taken to reduce water consumption

Comment

Water use
Total water consumption
Percentage of water recycled and reused

cubic meters(m3)
percentage(%)

Water stress
Does your company operate in, or close to, areas of high water-stress?

Yes, No

Water pollution
Emissions to water

tons (t)Employment Practices
Human resource management
Upload your HR policy, employee handbook or equivalent document describing your employment
policies and practices

File upload

Does your company have a grievance/complaints handling mechanism related to employee
matters?

Yes, No

Employee hires & turnover
Organic net new hires

Numbers

Total net new hires

Numbers

Employee turnover rate

percentage(%)

Employee engagement
Do you conduct an annual employee survey?

Yes, No

Employee benefits
Standard benefits offered to employees

Options

Training & development
Average hours of training per full-time employee

hours (h)Describe what employee training programs your company has in place

Comment

Diversity & Non-discrimination
Diversity & non-discrimination impact
Describe your company's challenges and opportunities in relation to diversity and nondiscrimination, and how these are being managed

Comment

Gender diversity
Number of employees that are female

Numbers

Percentage of employees that are female

percentage(%)

Percentage of managers that are female
Percentage of board members that are female

percentage(%)
percentage(%)

Pay equality
Unadjusted gender pay gap

percentage(%)

Non-discrimination
Total number of incidents of discrimination

Numbers

Describe the status of the incidents and actions taken

Comment

Health, Safety & Well-being
Health & safety management
Which of the following health and safety measures has your company implemented?

Options

Upload your health and safety policy

File upload

Upload your company's ISO 45001 certificate
Work-related injuries & ill health
Number of days lost to work-related injuries

Numbers

Number of work-related injuries

Numbers

Health & safety training
Describe the type and scope of health and safety training provided to workers

Comment

Human Rights & Labor Standards
Human rights policy
Upload your human rights policy

File upload

Which of the following areas does your human rights policy cover?

Options

Human rights due diligence
Does your company have a human rights due diligence in place?

Yes, No

Which of the following steps are included in your human rights due diligence process?

Options

Describe the measures taken by your company to prevent and mitigate actual and potential
human rights impacts
Does your company have processes and compliance mechanisms in place to monitor compliancewith UN Global Compact principles and OECD Guidelines for Multinational Enterprises?
Has your company been involved in violations of the UN Global Compact principles or OECD
Guidelines for Multinational Enterprises?
Freedom of association and collective bargaining

Comment

Percentage of active workforce covered under collective bargaining agreements

percentage(%)

Yes, No
Yes, No

Anti-corruption
Anti-corruption practices
Which of the following practices do you have in place to prevent corruption?

Options

Upload your anti-corruption policy

File upload

Which forms of corruption and bribery does your company’s anti-corruption policy cover?

Options

Describe identified significant risks of corruption and how these are managed

Comment

Anti-corruption training
Percentage of employees that have received training on anti-corruption

percentage(%)

Incidents of corruption
Total number of incidents of corruption

Numbers

Business Ethics & Leadership
Code of Conduct
Upload your company's Code of Conduct or Code of Business Ethics

File upload

Are all new employees required to sign your Code of Conduct (or equivalent document)?

Yes, No

Upload your Supplier Code of Conduct or equivalent document

File upload

Are all new supplier required to sign your Supplier Code of Conduct (or equivalent document)?

Yes, NoWhistleblowing mechanisms
Does your company provide means and knowledge to all employees how to submit grievancesand report unethical behavior (whistleblowing)?

Yes, No

Upload your whistleblowing policy

File upload

Board composition & ESG involvement
Does any of the board members have competencies relating to environmental, social or
governance topics?

Yes, NoHow often does the board review of environmental, social and governance topics and theirimpacts, risks, and opportunities?

Options

Remuneration
How is performance-related pay (bonuses) determined?

Options

Product & Service Quality
Quality management
Describe your company's challenges and opportunities in relation to the quality of your products
or services, and how these are being managed

Comment

Upload your company's ISO 9001 certificate

File upload

Customer Privacy & Data Security
Data privacy & IT security management
Upload your information security policy

File upload

Upload your data privacy policy

File upload

Upload your ISO/IEC 27001 certificate

File upload

EU Taxonomy Reporting
Select activities
Select eligible and taxonomy aligned activities

Options

Select eligible but not taxonomy-aligned activities

Options

Eligible and Taxonomy-aligned activities
Report proportion of turnover from eligible and taxonomy-aligned activities
Report proportion of CapEx from eligible and taxonomy-aligned activities
Report proportion of Opex from eligible and taxonomy-aligned activities

percentage(%)
percentage(%)
percentage(%)

Eligible but not Taxonomy-aligned activities
Report proportion of turnover from eligible but not taxonomy-aligned activities
Report proportion of CapEx from eligible but not taxonomy-aligned activities
Report proportion of Opex from eligible but not taxonomy-aligned activities

percentage(%)
percentage(%)
percentage(%)

Non-eligible activities
Report proportion of turnover from non-eligible activities
Report proportion of CapEx from non-eligible activities
Report proportion OpEx from non-eligible activities

percentage(%)
percentage(%)
percentage(%)

Accompanying disclosures
Upload your accounting policy

File upload

Describe your assessment of compliance with EU Taxonomy

Comment

Provide additional contextual information about your KPIs

Comment

Sustainability Approach
Company information
Select the NACE activities that your company performs

Location of operations

NACE
Activities(Level 4
Items)Countries

Total number of operations

Numbers

Primary markets for your products or services

Countries

Annual turnover / Net sales

MEUR

Number of full-time employees

FTEs

Sustainability areas

Which environmental areas do your sustainability practices cover?

Options

Which social areas do your sustainability practices cover?

Options

Which governance areas do your sustainability practices cover?

Options

Which guidelines and principles do your company comply with?

Options

Which reporting regulations does your company follow?

Options

Which reporting initiatives does your company use?

Options

Sustainable Sourcing Approach
Supply chain information
Number of significant suppliers

Numbers

Location of significant suppliers' operations

Countries

Sustainable sourcing practices
How are your sustainable sourcing practices communicated to suppliers?

Options

How do you ensure that your suppliers act according to your sustainable sourcing practices?

Options

Supply chain sustainability areas
Which environmental areas do your sustainable sourcing practices cover?

Options

Which social areas do your sustainable sourcing practices cover?

Options

Which governance areas do your sustainable sourcing practices cover?

Options

Appendix 2 – Inven ESG readiness evaluation tool
ESG screening questionnaire Biggest Unicorn
OVERALL RESULTSSCORINGENVIRONMENTAL ASSESSMENT
SOCIAL ASSESSMENT
GOVERNANCE ASSESSMENT

GENERAL INFORMATION

Answers

Investor Notes

Biggest Unicorn

Company nameDate of call/interview
Investment manager (Inven)
Contact person (Company)
Country (Website URL)
Year FoundedStage
Other (Investment from Sub-Fund C,D etc.)
RISK ANALYSIS
Number of Employees
Product is manufactured/hardware?
Does the company have employees / offices/ factories in developing countries?
Supply chain and sales in developing countries?
Do you have an ESG strategy?

ESG QUESTIONNAIRE

KPIs

Basic
weightAdjustedweightGeneral Environmental
1

Environment Commitment

Y/N

3

3

2

External environmental certification

Y/N

2

2

GHG emissions(tCO2)ENVIRONMENTAL

Carbon Footprint
3

Carbon Footprint Measurement

4

4

4

Net Zero targets

n/a

3

3

5

Achieved carbon performance targets

n/a

2

2

6

Reduction initiatives (Servers / Transportation)

n/a

5

5

renewable
electricity/ heating

3

3

Material management
7

Renewable source of energy consumed

8

Water consumption management & measurement

n/a

2

2

9

Waste measurement & management

n/a

3

3

Supply chain
10

Environmental & Social procurement policy in supply chain

Y/N

4

4

11

Supply chain engagement for responsible practices

n/a

4

4

Employees
12

Human rights internal policy

n/a

2

2

13

Contractors

n/a

3

3

14

Professional development initiatives (training availability)

n/a

4

4

15

Employees satisfaction

Employees NPS

4

4

n/a

3

3

SOCIAL

Well being and health policy (incl. work-life balance and16
parental leave)
Customers
17

Customer Satisfaction data

Customer NPS

4

4

18

Cyber security Initiatives

Y/N

4

4

19

Data Privacy Policy & Management (e.g. GDPR)

Y/N

5

5

20

Responsible product design

n/a

3

3

Community
21

Contribution to the community

n/a

2

2

22

Procurement and cooperation with local suppliers

n/a

2

2

n/a

Diversity & inclusion
23

Diversity & inclusion policy

3

3

24

% females inDiversity & Inclusion performance (i.e. percentage, wage gap) management (C &C-1 level)

4

4

25

# female board
members2

2

Board member diverse representation

GOVERNANCE

Governance General
26

Anti-corruption code of ethics

n/a

3

3

27

Impact / SDG / purpose-driven strategy

n/a

4

4

Board of directors
28

Independent member on the Board

Y/N

2

2

29

Proper management of the Board

n/a

5

5

Risk
Management

Urgencyscore

Investor Notes

Risk assessment broad areas
First, we perform the assessment of the several broad areas, which assess the start-up operations
based on industry best practices, global trends and Inven’s values. These results can influence theweights
of
the
ESG
KPIs
followingly:oNumber of Employees▪ A large number of employees results in a higher need to manage social best practices andneeds and therefore the weight and emphasis put on social aspect of ESG increase. The
relevant weights are increased in our risk analysis if a start-up has more than 100
employees.

oDoes the company manufacture products/ hardware?
▪ As the production of a product increases the likelihood of a higher carbon footprint,
increased materials use and waste creation, the weight of the environmental KPIs will behigherforcompaniesthat
manufacture
hardwareproducts.

o

Does the company have employees/ offices/ factories in developing countries?
▪ Operations in developing countries contribute to a higher risk of human rights violations
and corruption. These two indexes could help identify countries that require a higher
weighton
thoseissues:Humanrights:https://freedomhouse.org/countries/freedomworld/scores?sort=asc&order=Total%20Score%20and%20Status
Corruption:
https://www.transparency.org/en/cpi/2020/index
The relevant weights are increased in our risk analysis if a start-up has operations indeveloping countries.

oSupply chain and sales in developing countries?
▪ There is an increased risk of human rights violations in operation of suppliers fromdeveloping countries. Thus, the need to manage the start-up’s procurement process isincreased. The relevant weights are increased in our risk analysis if the supplier has
operations
indeveloping
countries.

o

Does the start-up have an ESG strategy?
▪ The risk analysis of each start-up is a complex process, many indicators can affect thisanalysis and the framework that is presented in this document is not custom made. As aresult the best risk management will occur with an internal risk management process. All
weights are decreased in our risk analysis if the start-up has an ESG policy in place.

Risk assessment ESG KPIs
After the broad areas are assessed, a specific risk assessment of 29 ESG KPIs is performed. The
company’s performance is evaluated according to the management of each of the ESG KPIs/indicators
belonging to the 10 clusters listed above. These indicators are scored on a scale of 1-3 (1=Well
Managed, 2=Some Management, 3=Not Managed). The determination of the management level ofeach indicator will be done by the investment manager based on the general guidelines listed below
and the acquired knowledge of Inven investment managers.

Indicator

1= well managed

2= Some management

General environment
1. Environmental
commitment●

Environmental policy, shortand long-term targets●

Environmental policy ortargets

2. External
Environmental
certification●

ISO 14001 / B corp or any
specific industry certification●

Assessment or guidancefrom an externalorganization/ community

3. Carbon Footprint
Measurement●

Measurement of scope 1-3●

Measurement of scope 1-2

4. Net Zero targets●

Have targets to reduce to Net
Zero●

Have targets to reduce but
not to net zero

5. Achieved carbon
performance targets●

Achieved all targets without
offset●Achieved some of thetargets/ Achieved targets
with offset

6. Reduction initiatives●

Implemented initiatives withthe potential to reduce 5% ormore of total carbon
footprint (annually)●

Implemented initiatives withthe potential to reduce 1%5% of total carbon footprint(annually)

7. Renewable sourcesof energy consumption●

Majority of energy sources
are renewable●

Some of the energy sources
are renewable

8. Water consumption
management &measurement●

Measuring water
consumption
Relative reduction in use toincome●Measuring water
consumption

9. Waste measurement& management policy●

Measuring waste production& recycling percentage
Relative reduction in use toincome●Have waste reduction &recycling initiatives

Carbon footprint

Material Management●●
Supply chain10. Environmental &social supply chain
procurement policy

11. Supply chain
engagement for
responsible practices●

Environmental supply chain
policy including course ofaction when there are
violations of the policy(only possible to receive if the startup is highly engaged with suppliers)●

Environmental & social
supply chain policy●

Assessment of main
environmental/ social risk in
suppliers operation●

Assessment of main
environmental/ social risk in
suppliers operation●

Engagement with suppliers(e.g. they sign the policy/
send data…)

12. Human rights
internal policy●

Human rights policy
implementation (e.g.
employee training, internal
audit, manager ownership
etc.)

●

Human rights policy (can also
be a part of code of conduct)

13. Contractors●

Employees have the option tochoose between contractors
and company employees
Contractors can secure
income comparable toemployees in the similar
sector (workflow
predictability allows for othersources of income if company
not providing enoughworkload)●

Employees have the option
to choose between
contractors and company
employees
Contractors can secure
income comparable toemployees in the similar
sector (workflow
predictability allows forother sources of income if
company not providing
enough workload)●

Majority of the employees
received opportunities for
professional knowledge orpractice training (directly
related to their position)●

Majority of the employees
received opportunities for
professional knowledge orpractice training (directly
related to their position)
Majority of employees had
opportunities of professional
development training(management and leadershipfor non-managers, ongoingprofessional learning)●●

Commitment to employees
Created dialog with●●

Commitment to employees
Created dialog with

Employees●

14. Professional
Development initiatives

15. Employees
satisfaction

●

●

●

16. Well being andhealth policy (incl.
work-life balance andparental leave)●●

employees (surveys,
feedback interviews…)
Incorporated changes
following feedback from
employees or decreased
turnover rate
Parental leave policy
Well-being and employee
health initiatives

employees (surveys,
feedback interviews…)●

Parental leave policy●

Well-being and employee
health initiatives

Commitment to customers
Created dialog withcustomers (surveys, feedback
interviews…)
Incorporated changes
following feedback from
customers●●

Commitment to customers
Created dialog withcustomers (surveys,
feedback interviews…)

Initiative to prevent
cyberattack (accessmanagement, employee
training, phishing exercise…)
Manager ownership withmanpower (SICO)●

Initiative to prevent
cyberattack (accessmanagement, employee
training, phishing exercise…)●

Data privacy policy●

Data privacy policy●

Internal/ external audit●

Manager ownership withmanpower●Analysis of product social/environmental influence●

Analysis of product social/environmental influence●

Set a strategy to address
harmful effects●

Collaborate with externalorganizations●

Commitment to external
stakeholders●

Commitment to external
stakeholder (stakeholdersor

Customers
17. Customer
Satisfaction data●●●

18. Cyber security
Initiatives●●

19. Data Privacy Policy& Management (eg.
GDPR)

and
or

20. Responsible productdesignandOr

Community
21. Contribution to thecommunity●

Initiatives to promote thelocal community relating to
the start-up expertise (techeducation for youth,/students, digital/ techtraining to elderly etc.)●

Commitment to work withlocal suppliers●

Set procurement targets for
local suppliers●More than 20% of suppliers
are local

23. Diversity & inclusion
policy and targets●●

24. Diversity & Inclusion
performance

25. Board member
diverse representation

22. Procurement andcooperation with local
suppliers

outside of the start-up)●

Commitment to work withlocal suppliers

Establish a D&I policy
Set diversity & inclusion
annual targets (e.g. increase
women new-hire, percentageof women in management,
increase minorities, LGBT or
people with a disability)●

Establish a D&I policy●

Must have women in
management initiatives(unconscious bias training,sourcing strategy, brandcampaign…) and achieve highD&I performance●

D&I initiatives (e.g.
unconscious bias training,sourcing strategy, brandcampaign…) / achieve highD&I performance●

Have one woman in theboard (not an observer)●

Have one woman in theboard as an observer●

Have a board member froman underrepresented group(minority, LGBT, disability
etc.)

●

Have a board member
representation of diverse
background (age, sector
expertise)

and

or

Diversity & inclusionoror

Governance General26. Anti-corruption
code of ethics● Anti-corruption code of ethics
and at least two of:● Anonymous reporting system● Implementation of the codewith employees● Ethical procurement due
diligence● Board member/ C-level
management ownership

27. Impact / SDG /purpose-driven strategy●

Anti- corruption code of
ethics (including anti -bribery
section)Establish an Impact/ SDG/
purpose-driven strategy
Have a quantitative metrics
measurement●

Establish an Impact/ SDG/
purpose-driven strategy●

Independent director on the
board

●

Independent director on the
board

●

Has accounting & financeexpertise●

Has industry expertise in thefield.

●

Board annual frequency is 4
or more●Board annual frequency is 4
or more●Monthly performance report
given on time●Monthly performance report
given on time●

The Board createdsubcommittees or example
for constructive support●●

Board of directors
28. Independent
member on the board
andor

29. Proper
management of the
Board

and

and

and

Appendix 3 – ECS Requirements transaction documentation
Environment and social standards "ECS Requirements" means the environmental, climate and social
obligations to be undertaken by a company to ensure that there is compliance with Environmental
and Social Law;
"Environmental and Social Law" means:(a)

EU Law, including principles and standards;(b)laws of a jurisdiction where the company is incorporated or where it carries out its businessactivities; and(c)applicable international treaties,

in each case of which a principal objective is the preservation, protection or improvement of theEnvironment and/or the protection or improvement of Social Matters;"Environment" means the following:(a)fauna and flora living organisms including the ecological systems;(b)land, soil, water (including marine and coastal waters), air, climate and the landscape (natural
or man-made structures, whether above or below ground);(c)cultural heritage (natural, tangible and intangible);(d)the built environment; and(e)human health and well- being;"Social Matters" means all, or any of, the following:(a)labour and working conditions;(b)occupational health and safety;(c)rights and interests of vulnerable groups;(d)rights and interests of indigenous peoples;(e)gender equality(f)public health, safety and security;(g)

avoidance of forced evictions and alleviation of hardship from involuntary resettlement; and(h)stakeholder engagement;(i)
The company shall, and shall procure that its subsidiaries shall, comply with the national and
EU Environmental and Social Law to which it is subject which is relevant and applicable to its
operations or activities.
(ii)
The company undertakes, within 180 days as of the closing of the transaction documents, to(i) comply, and procure that its subsidiaries comply, with the ECS Requirements, (ii) comply, andprocure that its subsidiaries comply, with the requirements of the GDPR, (iii) and procure that its
subsidiaries, obtain all relevant authorisations to comply with applicable Environmental and Social
laws. The company undertakes to, and procure that its subsidiaries shall, comply with relevant

environmental and social standards and to work towards continuous improvements in environmental,social and governance matters.
(iii)
As promptly as possible and in any event no more than thirty (30) Business Days after
becoming aware of any social, labour, gender-based violence, sexual exploitation and abuse, healthand safety, security, reprisals or environmental incident, accident or circumstance with respect to any
company operations or activities (including those of its subsidiaries) having, or which could reasonably
be expected to have, an material adverse effect or an adverse impact on the implementation oroperation of the company’s (including its subsidiaries) operations in compliance with the ECS
Requirements, the company shall notify Inven Capital (including by way of a written notice to theBoard) of and shall in each case specify, to the extent that it has such information at its disposal, thenature of the incident, accident, or circumstance and the impact or effect arising or likely to arise
therefrom, and the measures being taken, or plans to be taken to address them and prevent any future
similar event; and keep Inven informed of the on-going implementation of those measures.
(h)Excluded activities

The company shall not, and shall make sure that its subsidiaries do not, conduct by itself any of the
excluded activities listed above in Exclusion policy section of this document.

Appendix 4 - Change log
11.5.2023 – Updated ESG KPIs based on implementation of reporting with the Worldfavor
platform
5.6.2023 - Investment process details added, i.e. Termsheet sustainability clause, transaction
documentation clauses; added section Reporting to investors