Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on the disclosure of information related to sustainability in the financial services sector (hereinafter: “SFDR”), establishes harmonized rules for financial market participants and financial advisors regarding transparency with regard to the introduction of sustainability risks into their activities and the consideration of adverse sustainability effects in their operations, as well as with regard to their presentation of sustainability-related information on financial products. In light of the aforementioned regulations, Invento Capital limited liability company is qualified as a financial market participant, and the alternative investment company it manages – Invento Capital limited liability company ASI sp.k. based in Katowice – constitutes a financial product.

Invento Capital spółka z ograniczoną odpowiedzialnością, as of the date of publication of this information, does not have a Strategy for incorporating sustainability risks into its operations in the investment decision-making process, which means that Invento Capital spółka z ograniczoną odpowiedzialnością has not drawn up, at the level of its entire organization, a strategy specifying how to take into account environmental, social or governance situations or conditions that, if they occur, could have, actual or potential, a material negative impact on the value of the investment.

Invento Capital limited liability company, as of the date of publication of this information, does not analyze its investments through the lens of sustainability, and its investment decisions do not take into account adverse effects on sustainability factors in connection with Article 4(1)(b) of the SFDR. This is justified by the peculiarities of ZASI and ASI, in particular the fact that we operate as an Alpha Bridge Fund. This implies a small scale of operations and a number of limitations, which involve investing mainly in equity instruments of unlisted early-stage start-up entities. Bridge Alpha VC funds focus on investing in research and development (R&D) projects in the Proof-of-Principle and Proof-of-Concept phases, the earliest phases in project development. As a result, it is either impossible or highly difficult to obtain from the companies in which ASI has invested the information necessary to reliably perform an ESG analysis.

Nevertheless, the investment portfolio includes companies working on solutions directly for ESG, and most of our portfolio companies are indirectly aiming to build a sustainable enterprise from an environmental, social policy and corporate governance perspective. As a standard, before making an investment decision related to an investment in an entity, Invento Capital limited liability company conducted due diligence, the purpose of which was, among other things, a comprehensive analysis of the company. As part of the study, the area of corporate governance and employee affairs, among others, was verified, and the results of due diligence could result in recommending the introduction of corrective measures, the implementation of which conditioned the investment.

Invento Capital limited liability company does not exclude the possibility of developing a strategy regarding the introduction of risks for sustainable development into the business in the process of making investment decisions in the future, which will involve updating this statement.