With the aim of reducing information asymmetries and increasing transparency regarding the integration of sustainability risks into investment decisions and the consideration of adverse sustainability impacts, Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the “SFDR”) requires financial market participants to disclose specific information regarding their approaches to these matters.

Green One Capital, SCR, S.A. (“GOC” or the “Company”) has adopted an ESG Policy which it takes into account throughout the entire investment cycle, while always considering any limitations arising from different levels of ownership in an investment and the resulting ability to influence the implementation of ESG opportunities identified from time to time.

In light of the functions it performs as a management company of venture capital funds, and having regard to its size, nature, complexity, scale of activities and the types of instruments in which it invests through the funds under its management, GOC carefully considers relevant financial and sustainability risks as part of its investment decision-making process.

Throughout the investment process, from sourcing and holding to portfolio monitoring, GOC collects information and continuously and diligently identifies, assesses and monitors the various risks that may affect the value of its investments. Sustainability risks and their potential impact are therefore considered on a case-by-case basis, taking into account the specific characteristics of each investment decision.

This risk analysis may be incorporated into the due diligence processes carried out in respect of portfolio companies held by the venture capital funds managed by GOC and may be complemented by the recommendation, implementation and periodic reassessment of measures aimed at mitigating identified risks. Such measures may also contribute to enhancing the value and potential of those companies for all stakeholders.

Where risk analysis is incorporated into the investment assessment phase, GOC identifies ESG best practices in the economic sector in which the relevant asset operates and assesses the opportunity and potential impact of implementing the ESG measures identified. The outcome of this analysis is communicated to GOC’s investment team and should form part of the value creation plan for the relevant asset.

Non-consideration of adverse impacts of investment decisions on sustainability factors

Although GOC recognises the importance of environmental, social, governance and sustainability factors, and progressively incorporates them throughout the investment decision-making process and portfolio management, subject to the technical and financial capabilities of each company, it does not currently consider all adverse impacts of investment decisions on sustainability factors.

GOC considers that the necessary conditions for the proper consideration of such adverse impacts are not yet fully in place. On the one hand, the nature and type of its investment activities, particularly in sectors that are not considered to present a high level of sustainability risk, make such impacts difficult to measure. On the other hand, the insufficiency of available market information, the absence of uniform criteria, the lack of standardised sustainability disclosures by venture capital funds and, consequently, the need to implement methodologies and metrics adapted to the nature and characteristics of the investments made by the funds managed by GOC currently prevent GOC from properly considering such impacts.

Nevertheless, given the careful consideration of sustainability risks in the investment decision-making process and the nature of the investments themselves — which do not include sectors or companies likely to raise significant environmental, social or governance concerns — GOC believes that any adverse impacts arising from its activities are significantly mitigated.

It should also be noted that, as at the date hereof, GOC is not required to consider the adverse impacts of investment decisions on sustainability factors, as it does not meet the thresholds applicable to large financial market participants set out in Article 4(3) and (4) of the SFDR.

GOC may review its position on this matter in the near future and, should the circumstances described above change, nothing prevents it from adopting a different approach and implementing a specific policy, of which its stakeholders will be duly and appropriately informed.

Impact on GOC’s remuneration policy (Article 5(1) of the SFDR): no direct integration of sustainability risks into the determination of employee remuneration

For the purposes of Article 5 of the SFDR, GOC takes into account its policy on the integration of sustainability risks when determining the remuneration of its employees, ensuring that its remuneration policy serves as a key instrument for aligning interests, promoting the creation of permanent and sustainable employment, ensuring job security and providing fair remuneration to all employees.

GOC implements a fair, equitable and non-discriminatory remuneration policy designed to attract, retain and motivate employees. Environmental, social and governance considerations are incorporated, in a manner proportionate to the type of activities performed, into the relevant performance objectives used for the purpose of awarding variable remuneration, while ensuring balanced, efficient and diverse teams.

GOC also adopts policies, procedures and practices that enable the identification, measurement, management and monitoring of certain risks, including sustainability risks. Accordingly, the Company seeks to ensure that its remuneration policies are consistent with sound and prudent risk management, compatible with each relevant risk profile and with the objectives, strategies and needs of the funds under management, while preventing and managing conflicts of interest and rewarding the skills, performance, responsibilities and professional experience of each employee, taking market practice into account.

Accordingly, the Company takes into account the integration of sustainability risks when determining employee remuneration. However, sustainability risks are not, in themselves, treated as a distinct and separate performance component. Rather, they form part of an overall assessment of the relevant employee’s contribution to the Company and of GOC’s overall performance, in a balanced manner and proportionate to the nature of the activities performed (i.e. as part of the indicative performance criteria applicable to the Company as a whole).

GOC’s remuneration policy provides for the possibility of awarding variable remuneration, but such remuneration is not made exclusively dependent on the achievement of positively defined sustainability objectives. The variable component of remuneration is performance-related and risk-adjusted, taking into account individual performance, the performance of the relevant business area and GOC’s overall performance, which includes the achievement of sustainability objectives. Variable remuneration is intended to align employees’ personal objectives with the Company’s long-term interests and, through these, with the interests of the funds under management and their investors.

This information consolidates the statement regarding the non-consideration of adverse impacts of investment decisions on sustainability factors, for the purposes of Article 4(1)(b) of the SFDR.

Final considerations

GOC ensures that all of the information published above is kept up to date and subject to review. GOC’s ESG Policy is reviewed annually, is the responsibility of the ESG Officer and is approved by the Company’s Board of Directors. It is available for consultation and is made known to all employees and regular service providers of the Company.

GOC undertakes to keep its ESG Policy and the information published above up to date.

GOC’s Board of Directors originally approved and published the information set out above on 2 May 2023 and subsequently updated it on 2 July 2024.