Note on Regulatory Status: While Übermorgen Ventures AG (hereinafter referred to as "Übermorgen") is a climate-tech investor focused on decarbonization, mitigation, and adaptation, it acts solely as the Swiss Investment Advisor to the Fund(s). Übermorgen is not a regulated financial market participant under the EU Sustainable Finance Disclosure Regulation (SFDR). However, the General Partner Übermorgen Ventures Management Sarl (“General Partner”) advised by Übermorgen is a regulated AIFM and the Fund  Übermorgen Ventures Investment Fund SCSp
(“Fund”) managed by the General Partner and advised by Übermorgen is currently classified as Article 6. Therefore the following disclosures are provided to support the Fund’s transparency requirements in accordance with EU SFDR 2019/2088.

1. Integration of Sustainability Risks (Article 3)

A sustainability risk is an environmental, social, or governance (ESG) event or condition that, if it occurs, could cause an actual or potential material negative impact on the value of an investment.

In its capacity as Investment Advisor, Übermorgen believes that identifying ESG factors is essential to protecting the value of the investments it recommends. We integrate sustainability risks into our advisory process by:

• Pre-Investment Due Diligence: Evaluating potential portfolio companies for governance risks, ethical standards, and significant environmental liabilities before recommending them to the Fund.

• Risk Assessment: Analyzing how physical climate risks or transitions in environmental regulations might affect a startup’s business model and long-term financial viability. 

2. No Consideration of Sustainability Adverse Impacts (Article 4)

Übermorgen does not currently consider the "Principal Adverse Impacts" (PAI) of investment decisions on sustainability factors in the specific manner prescribed by Article 4 of the SFDR.

• Rationale: As an advisor to early-stage startups (Pre-Seed and Seed), the granular and standardized data required for formal PAI reporting is not yet consistently available from investee companies..

• Future Review: We actively support founders in building sustainable companies. We will review our position on PAI reporting as the portfolio matures and data availability in the venture capital ecosystem improves.

3. Remuneration Policy (Article 5)

Our remuneration policy is designed to promote sound and effective risk management. It does not encourage excessive risk-taking, including with respect to sustainability risks. Compensation for our advisory team is linked to the overall performance of the fund, which includes the mitigation of material ESG-related risks that could impact financial returns.

4. Taxonomy Regulation Disclosure

The following statement is required by Article 7 of the Taxonomy Regulation for all Article 6 funds: "The investments underlying this financial product do not take into account the EU criteria for environmentally sustainable economic activities."

Disclaimer regarding SFDR and Regulatory Status

Disclaimer: Übermorgen is an investment advisor based in Switzerland and is not subject to the European Union’s Sustainable Finance Disclosure Regulation (SFDR) (EU) 2019/2088 or the EU Taxonomy Regulation (EU) 2020/852.

The disclosures provided on this page are for informational purposes only and are intended to assist the Fund(s) (the "Financial Product") and their respective Alternative Investment Fund Manager (AIFM) in meeting their regulatory obligations under EU law. Übermorgen does not exercise discretionary management over the Fund(s) and does not hold itself out as a regulated EU Financial Market Participant. Any investment decision is made solely by the authorized AIFM of the Fund. While Übermorgen incorporates ESG considerations into its advisory services, these services do not constitute a guarantee of specific environmental or social outcomes.