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Sustainability-related disclosures pursuant to Regulation (EU) 2019/2088 (“SFDR”)

Date of publication: 1st June 2024

I. Sustainability risks

GOLDTRACK Ventures GmbH (LEI: 391200DXOSXQOI68SX53, “GOLDTRACK”) considers sustainability risks

as part of its investment decision-making process. Sustainability risks are 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. GOLDTRACK considers sustainability risks as part of its due diligence process prior to

any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted

by using a questionnaire. The results of such assessment are taken into account when the investment decision

is being taken. However, GOLDTRACK remains free in its decision to refrain from investing or to invest despite

sustainability risks, in which case GOLDTRACK can also apply measures to reduce or mitigate any sustainability

risks. At all times, GOLDTRACK will apply the principle of proportionality taking due account of the strategic

relevance of an investment as well as its transactional context.

II. No consideration of adverse impacts of investment decisions on sustainability factors

GOLDTRACK does not consider any adverse impacts of its investment decisions on sustainability factors and

hence does not use the sustainability indicators listed in Annex I of the Delegated Regulation (EU) 2022/1288

(as amended from time to time, “RTS”) to identify and assess potential adverse impacts as required by Art. 4

SFDR. Sustainability factors are environmental, social and employee concerns, respect for human rights and

the fight against corruption and bribery.

Given that the SFDR, the Regulation (EU) 2020/852 (“EU Taxonomy”) and the accompanying RTS, which

determine the sustainability indicators to be used and provide details on mandatory processes to obtain the

respective data at portfolio company level, are relatively new legislative acts, there is – as of now – only little

practical experience with regard to the application of their respective provisions. Therefore, substantial legal

uncertainties would remain when applying those provisions to the strategies pursued by GOLDTRACK.

Moreover, the burden associated with considering adverse impacts on sustainability factors by using

sustainability indicators is disproportionate in light of the very limited relevance that such impacts could have

in the context of GOLDTRACK’s investment strategy: GOLDTRACK pursues an active venture capital strategy

and invests in portfolio companies which, at the time of the partnership’s initial investment, are innovative

companies with high growth potential in their seed and early stages which develop as main business any

activity comprising the renewal and enlargement of a range of products and services and their associated

markets; with a focus on new medical technology and devices, new methods of diagnostics and therapeutics

as well as digital solutions (especially for the life science sector). Such early-stage companies are unlikely to

cause severe adverse impacts on sustainability factors and, as a result, GOLDTRACK’s investment decisions

are expected to hardly ever have an impact on sustainability factors. Furthermore, the consideration of

principal adverse impacts will largely depend on the availability of the relevant data from the underlying

portfolio companies. Especially on early-stage companies, the collection and provision of such data might put

an undue burden. Given that the Fund will only hold minority interests in the portfolio companies which are

generally not sufficient to encourage the companies to collect and report the relevant data, it is currently not

foreseeable for GOLDTRACK whether the information for the identification and assessment of principal adverse

impacts can be obtained from all portfolio companies on a regular basis as required by Art. 4 SFDR

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If and to the extent that the legal uncertainties will be resolved, a practicable market and administrative

practice will evolve and data availability can be ensured, GOLDTRACK will re-evaluate considering principal

adverse impacts of its investment decisions as required by Art. 4 SFDR in due course, at the latest by the end

of 2024. In the meantime, GOLDTRACK remains free in its decision to use part of the sustainable indicators

listed in Annex I of the RTS and/or an own set of indicators.

III. Remuneration disclosure

As a registered alternative investment fund manager within the meaning of section 2 (4) of the German

Investment Code (Kapitalanlagegesetzbuch, “KAGB”), GOLDTRACK does not have and does not need to have

a remuneration guideline or policy in accordance with the requirements of the KAGB.

IV. Sustainability-related disclosures for GOLDTRACK Ventures Fund I GmbH & Co. KG

Financial product: GOLDTRACK Ventures Fund I GmbH & Co. KG (the “Fund” / der “Fonds”)

LEI: (LEI: 391200DXOSXQOI68SX53, “GOLDTRACK”)

Summary

The Fund considers certain environmental and/or social characteristics as part of its investment decisions and

monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The Fund

aspires to integrate responsible investment practices into its entire investment process from origination to exit.

The consideration of environmental and/or social characteristics is carried out both before and after an

investment. For this purpose, information is initially and regularly obtained from the portfolio companies by

means of qualitative queries. The Fund incorporates inclusion (positive screening) as well as exclusion

(negative screening) aspects during the decision-making process. Thereby the Fund considers several ESG

themes to be the key to responsible investing. The actions and decisions described in the following section are

each made by GOLDTRACK for and on behalf of the Fund.

Zusammenfassung

Der Fonds berücksichtigt bestimmte ökologische und/oder soziale Merkmale im Rahmen seiner

Investitionsentscheidungen und Monitoring-Prozesse, strebt aber keine nachhaltigen Investitionen im Sinne

der SFDR an. Der Fonds strebt nach einer Integration von verantwortungsvollen Investitionspraktiken in den

gesamten Investitionsprozess, von der Auflage des Fonds bis zum Exit. Die Berücksichtigung von Umwelt-

und/oder Sozialmerkmalen erfolgt sowohl vor als auch nach einer Investition. Zu diesem Zweck werden

zunächst und regelmäßig Informationen von den Portfoliounternehmen durch qualitative Abfragen eingeholt.

Der Fonds bezieht sowohl Inklusions- (positives Screening) als auch Exklusionsaspekte (negatives Screening)

in seinen Entscheidungsprozess ein. Dabei betrachtet der Fonds mehrere ESG-Themen als Schlüssel für

verantwortungsvolles Investieren. Die in diesem Abschnitt beschriebenen Handlungen und Entscheidungen

erfolgen jeweils durch GOLDTRACK für den Fonds.

No sustainable investment objective

The Fund promotes environmental or social characteristics, but does not have as its objective sustainable

investment.

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Environmental or social characteristics of the financial product

The Fund promotes environmental and/or social characteristics by excluding certain environmentally and/or

socially relevant sectors from the Fund’s investment scope (i.e., by implementing certain investment exclusions

in the decision-making process, see section ‘Investment strategy’).

Further, the Fund contributes to the UN Sustainable Development Goal (“SDG”) 3 and promotes health and

well-being as social characteristic by following an investment strategy with a focus on new medical technology

and devices, new methods of diagnostics and therapeutics as well as digital solutions (especially for the life

science sector).

Thereby, the Fund actively contributes to Target 3.2 and 3.41 of SDG 3 which aims for ending preventable

newborn death and the reduction of premature mortality from non-communicable diseases through prevention

and treatment by one third. The Fund aims to reduce the mortality rate by investing into innovative life science

companies addressing high unmet medical needs by developing devices/treatments, diagnostic and digital

health tools as well as novel drugs.

Investment strategy

The purpose of the Fund is to build, hold and manage (including, but not limited to, to divest) a portfolio of

equity and equity-related investments in portfolio companies. The Fund shall, in principle, pursue a long-term

investment strategy.

GOLDTRACK shall ensure that funds equal to 100 % of the total capital commitments drawn down and applied

towards investments are invested in portfolio companies which, at the time of the Fund’s initial investment,

are innovative companies with high growth potential in their seed and early stages which develop as main

business any activity comprising the renewal and enlargement of a range of products and services and their

associated markets; with a focus on new medical technology and devices, new methods of diagnostics and

therapeutics as well as digital solutions (especially for the life science sector).

The Fund’s investment strategy is implemented in the investment process on a continuous basis: Every

investment opportunity will be tested against the Fund’s investment strategy, in particular its investment

exclusions, as part of the due diligence prior to any investment made by the Fund. After an investment, i.e.,

during the holding period, the Fund will monitor its portfolio companies on a regular basis and may provide

support if and where considered relevant

The Fund may only make investments in portfolio companies that fall within the aforementioned investment

scope of the Fund as defined in the Fund’s limited partnership agreement and, thus, (directly or indirectly)

adress particularly SDG 3.

The Fund is bound by the investment restrictions and limitations set out in the Fund’s limited partnership

agreement and shall procure that such requirements, restrictions and limitations are complied with at all times.

The Fund shall not

1 Target 3.2: “By 2030, end preventable deaths of newborns and children”;

Target 3.4: “By 2030, reduce by one third premature mortality from non-communicable diseas-es through prevention and treatment

and promote mental health and well-being.” The Targets and respective Indicators can be found on the UN SDGs Website:

https://sdgs.un.org/goals/goal3#targets_and_indicators.

page 4/7

a) invest in portfolio companies that perform or engage in research and innovation activities

considered as illegal in Germany or according to the legislation applicable to the portfolio company;

b) invest, guarantee or otherwise provide financial or other support, directly or indirectly, to

companies or other entities

i) that do not qualify as Eligible Final Recipients (as defined in the Fund’s limited partnership

agreement);

ii) performing research and innovation activities considered as illegal according to the legislation

applicable in the country of the company or entity;

iii) performing the activities excluded as referred to in Article19 of Regulation (EU) No. 2021/695

of the European Parliament and of the Council:

(aa) research activity aiming at human cloning for reproductive purposes;

(bb) research activity intended to modify the genetic heritage of human beings which could

make such changes heritable (excluding research relating to cancer treatment of the

gonads);

(cc) research activities intended to create human embryos solely for the purpose of research

or for the purpose of stem cell procurement, including by means of somatic cell nuclear

transfer;

iv) whose business activity consists of an illegal economic activity (i.e., any activity which is illegal

under the laws or regulations applicable to the company or entity), including, without

limitation, human cloning for reproductive purposes;

c) invest, guarantee or otherwise provide financial or other support, directly or indirectly, to

companies o rother entities which substantially focus on:

i) the production of and trade in tobacco and distilled alcoholic beverages and related products;

ii) the production of and trade in weapons and ammunition of any kind and financing of these

activities, it being understood that this restriction does not apply to the extent such activities

are part of or accessory to explicit European Union policies;

iii) casinos and equivalent enterprises;

iv) the research, development or technical applications relating to electronic data programs or

solutions, which

(aa) aim specifically at

− supporting any activity referred to under i) to iii) of this paragraph c),

− internet gambling and online casinos, or

− pornography; or which

(bb) are intended to enable to illegally

− enter into electronic data networks, or

− download electronic data;

v) fossil fuel-based energy production and related activities, as follows:

(aa) coal mining, processing, transport and storage;

(bb) oil exploration & production, refining, transport, distribution and storage;

(cc) natural gas exploration production, liquefaction, regasification, transport, distribution

and storage;

(dd) electric power generation exceeding the Emissions Performance Standard (i.e., 250

grams of CO2 per kWh of electricity), applicable to fossil fuel-fired power and

cogeneration plants, geothermal and hydropower plants with large reservoirs;

vi) energy-intensive and/or high CO2-emitting industries, as follows:

(aa) manufacture of organic and other inorganic basic chemicals (NACE 20.13);

(bb) manufacture of other organic basic chemicals (NACE 20.14);

(cc) manufacture of fertilisers and nitrogen compounds (NACE 20.15);

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(dd) manufacture of plastics in primary forms (NACE 20.16);

(ee) manufacture of cement (NACE 23.51);

(ff) manufacture of basic iron and steel and of ferro-alloys (NACE 24.10);

(gg) manufacture of tubes, pipes, hollow profiles and related fittings, of steel (NACE 24.20);

(hh) manufacture of other products of first processing of steel (NACE 24.30, incl. 24.31-

24.34);

(ii) aluminum production (NACE 24.42);

(jj) manufacture of conventionally-fuelled aircraft and related machinery (sub-activity of

NACE 30.30);

(kk) conventionally-fuelled air transport and, airports and service activities incidental to

conventionally-fuelled air transportation (sub-activities of NACE 51.10, 51.21 and

51.23).

Notwithstanding the above, investments in sectors mentioned in section vi) items (aa) – (kk)

including, shall be allowed if confirmed that the investment either (A) qualifies as

environmentally sustainable investment as defined in the EU Taxonomy, or (B) is eligible under

the European Investment Fund’s Climate Action &Environmental Sustainability (CA&ES)

criteria for green financing.

In addition, when providing support to the financing of research, development or technical

applications relating to (x) human cloning for research or therapeutic purposes or (y)

genetically modified organisms (“GMOs”), the Fund shall ensure the appropriate control of

legal, regulatory and ethical issues linked to such human cloning for research or therapeutical

purposes and/or GMOs. Notwithstanding the aforementioned, research activities (xx) aiming

at human cloning for reproductive purposes, (yy) intended to modify the genetic heritage of

human beings which could make such changes heritable (excluding research relating to cancer

treatment of gonads), and (zz) intended to create human embryos solely for the purpose of

research or for the purpose of stem cell procurement, including by means of somatic cell

nuclear transfer are also excluded.

Good governance practices are assessed through an informal process as appropriate in light of the

circumstances of each individual case as part of the due diligence prior to any investment. Such practices

include, in particular, sound management structures, employee relations, remuneration of staff and tax

compliance at investee level. Moreover, the Fund will conduct regular monitoring of the good governance

practices at investee level during the holding period. If the Fund becomes aware of severe governance issues,

it will investigate them and work with all parties involved to find an appropriate solution.

Proportion of investments

The Fund will invest fully in line with its investment strategy and investment restrictions, i.e., will only make

investments which are aligned with its environmental and/or social characteristics. The Fund does not make

and does not intend to make sustainable investments within the meaning of Art. 2 no. 17 SFDR or

environmentally sustainable investments within the meaning of Art. 3 of the EU Taxonomy; hence, no portion

of its investments will be aligned with the EU Taxonomy.

Monitoring of environmental or social characteristics

The Fund has an increased awareness on the impact of environmental or social characteristics on risk

management and thus on the value potential of investments. Accordingly, the Fund undertakes to monitor

page 6/7

(compliance with) its environmental and/or social characteristics on an ongoing basis. Prior to making an

investment, the Fund assesses the attainment of its environmental and/or social characteristics with respect

to every (potential) portfolio company. The Fund uses the sustainability indicators ‘No investments in the area

of investment exclusions’ and ‘Direct or indirect contribution to SDG 3, Target 3.2 or 3.4’, and collects

respective data at portfolio company level in order to assess and monitor the initial and ongoing compliance

with such characteristics. During the holding period, the Fund will consult with the portfolio companies in

regular intervals and carry out further checks if there are indications of potential issues with the Fund’s ESG

approach. Moreover, the ESG policy of the portfolio companies will be reviewed and monitored by the Fund

on a regular basis. External monitoring mechanisms are not in place.

Methodologies for environmental or social characteristics

The Fund applies qualitative assessments with respect to its environmental and/or social characteristics. The

Fund conducts an initial assessment of such characteristics in the course of its due diligence process prior to

any investment by providing its (potential) portfolio companies with a questionnaire. Through this

questionnaire, the investment exclusions, good governance practices and contribution towards the SDGs are

identified and evaluated. Based on the results of this assessment, the Fund identifies whether the

environmental and/or social characteristics promoted by the Fund are met before making an investment.

During the holding period, the so conducted assessment forms the basis to measure and monitor if the

characteristics are continuously being met. By using the sustainability indicator ‘No investments in the area of

exclusions’, the Fund assesses and ensures the portfolio companies’ ongoing compliance with its investment

exclusions. Hence, the Fund measures and evaluates the attainment of its environmental and/or social

characteristics on an ongoing basis.

Data sources and processing

In order to attain each of the environmental and/or social characteristics promoted by the Fund, a

questionnaire is completed by the (potential) portfolio companies in the course of the due diligence process

conducted prior to each investment. Moreover, during the holding period, the portfolio companies provide the

Fund with periodic reports. Hence, most data is obtained from the (potential) portfolio companies. Further,

purely qualitative statements of an environmental or social nature or relating to corporate governance are

requested from the (potential) portfolio companies and then taken into account in the investment decision-

making and monitoring processes. An internal or external review or verification of the data obtained will be

carried out if misrepresentations are suspected.

Limitations to methodologies and data

The data collected from the (potential) portfolio companies is internally or externally verified only if and to the

extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may

remain undetected in certain cases. Further, if data should be estimated or supplemented by external (data)

providers, this data might – by the very nature of estimations – not reflect the actual data situation at portfolio

company level. Further limitations, in particular with regard to the accuracy of the data and reliability of the

data sources used, are currently not foreseeable. As the Fund’s investments are made for several years, the

Fund considers it a priority to establish and maintain a trustful working relationship with its portfolio companies

in order to ensure data quality and compliance with the environmental and/or social characteristics promoted

by the Fund.

page 7/7

Due diligence

In order to attain the aforementioned environmental and/or social characteristics, the Fund carefully selects

its portfolio companies during the investment decision-making process. The Fund conducts a due diligence on

every (potential) portfolio company. As part of this due diligence, the Fund carefully reviews how a (potential)

investment relates to the environmental and/or social characteristics promoted by the Fund. The Fund

incorporates inclusion (positive screening with respect to the SDGs) and exclusion (negative screening with

respect to its investment exclusions) as well as good governance aspects during the decision-making process.

This assessment is conducted by using a questionnaire and, where required based on the inherent ESG risk of

the portfolio company, through an enhanced analysis. An internal or external review or verification of the

information obtained will only be carried out if misrepresentations are suspected.

Engagement policies

Engagement forms part of the environmental or social investment strategy of the Fund. The Fund intends to

engage in managing ESG across its portfolio companies, e.g., by providing an ESG onboarding session which

includes assessing the company’s maturity against a carbon calculator’s ESG framework and developing an

appropriate action plan, and by implementing governance structures that provide an appropriate level of

oversight with regard to ESG factors. Further, the Fund will engage with its portfolio companies should principal

adverse impacts become apparent (see section ‘Statement on principal adverse impacts of investment

decisions on sustainability factors’).

The Fund will, as part of its environmental and social investment strategy, use the following measures to

engage with its portfolio companies – while taking into account the individual circumstances of each company

– in order to attain its environmental and/or social characteristics:

• Contractual target agreements with its portfolio companies (the portfolio companies will be required

to advance ESG-related topics within the term sheets or the investment agreements).

• ESG workshops within the first six months after an investment was made by the Fund together with

an external provider specialized in sustainability consulting, unless such workshop has already been

held at the portfolio company;

• Development of a transparent ESG strategy/roadmap and definition of suitable ESG key performance

indicators; as well as

• Exercise of (minority) shareholder rights in portfolio companies.

The Fund will regularly review and, as necessary, adjust its engagement policy. Further, the Fund will respond

with individual measures when becoming aware of ESG-related incidents or controversies at portfolio company

level.

Designated reference benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics

promoted by the Fund.