Sustainability-related disclosures (SFDR)

1. Summary

VitaminC I Fund SCSp is classified as a financial product promoting environmental and social characteristics in accordance with Article 8 of Regulation (EU) 2019/2088 (SFDR). The Fund invests in early-stage ventures that contribute to climate change mitigation and human adaptation and resilience to climate change, while integrating environmental, social and governance (ESG) considerations throughout the investment process.

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2. Environmental and social characteristics

The Fund promotes the following main characteristics:

  • Climate change mitigation through technologies and business models that can reduce or remove at least 100,000 tons of CO₂e per year within approximately five years after investment.

  • Human adaptation and resilience by strengthening the resilience and health of at least 100,000 people per year within approximately five years after investment.

  • Good governance practices at portfolio company level, including ethical conduct, transparency, human rights, labour standards and anti‑corruption.

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3. Investment strategy and binding elements

The Fund pursues an early‑stage venture capital strategy focused on climate-tech and adaptation solutions in Europe (approx. 70%) and globally (approx. 30%). Binding elements include:

  • Strict impact threshold (100k tons CO₂e / 100k people) and positive correlation between revenue and impact.

  • Exclusion of sectors such as fossil fuel exploration and production, weapons, tobacco, gambling and adult entertainment.

  • Mandatory impact and ESG due diligence (Theory of Change, impact calculation, ESG questionnaire).

  • Contractual clauses in term sheets/shareholder agreements on ESG policies, impact KPIs, DNSH, LCA and reporting.

4. Proportion of investments

All portfolio investments are #1 Aligned with E/S characteristics under the SFDR Annex II template; no assets are allocated to “#2 Other”. Within #1, 70% of investments are expected to be sustainable investments with an environmental objective that are not aligned with the EU Taxonomy (early‑stage climate mitigation).

30% of investments are expected to be sustainable investments with a social objective, primarily climate adaptation and human resilience/health.

The Fund does not currently commit to any minimum share of Taxonomy‑aligned investments; the minimum Taxonomy‑aligned share is 0%.

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5. Monitoring of environmental and social characteristics

The Fund monitors attainment of its characteristics through:

  • Pre‑investment impact calculations and ESG due‑diligence questionnaires for each investment.

  • Contractually agreed impact KPIs and quarterly reporting by portfolio companies.

  • Annual ESG reporting on policies, key risks, mitigations and incidents.

  • Board‑level engagement on impact and ESG topics where the Fund has representation.

6. Methodologies

Impact is assessed using a Theory of Change and a high‑level greenhouse‑gas reduction or resilience calculation for each investment. For climate‑mitigation ventures, companies are required to conduct a Life‑Cycle Assessment (LCA) by Series A/B or once the business model is sufficiently mature. The Fund uses qualitative DNSH checks and ESG risk assessments mapped to the principal adverse impact (PAI) indicators in Annex I, focusing on material issues rather than full quantitative PAI reporting.

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7. Data sources and processing

The Fund primarily relies on:

  • Information provided directly by portfolio companies (questionnaires, policies, management interviews, reporting).

  • Public or third‑party sources where available (e.g. preliminary LCAs, market benchmarks, expert reports).

  • Internal estimates and high‑level calculations for early‑stage ventures where data is incomplete.

  • Data limitations are disclosed to investors; the Fund applies a proportional and forward‑looking approach and supports portfolio companies in building more robust ESG and impact data over time.

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8. Limitations to methodologies and data

As a pre‑seed and seed investor, the Fund faces limitations regarding completeness, consistency and auditability of ESG and impact data. These limitations are mitigated by conservative assumptions, qualitative cross‑checks, external validation where appropriate, and iterative improvement of reporting requirements as companies mature.

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9. Due diligence

Impact and ESG due diligence is integrated into the investment process and documented in each investment memorandum. It includes impact potential assessment, DNSH and PAI‑related risk analysis, governance review, and, where relevant, external expert input.

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10. Engagement policies

The Fund actively engages with portfolio companies to strengthen impact and ESG performance by:

  • Supporting the development of ESG and sustainability policies.

  • Including impact and ESG topics on board agendas.

  • Providing access to tools, experts and networks.

  • Requiring remediation in case of material ESG incidents.

11. Designated reference benchmark

No specific index is designated as a reference benchmark to determine whether the Fund is aligned with the environmental or social characteristics it promotes. Instead, alignment is assessed through the Fund’s own impact and ESG monitoring at venture and fund level, as described above.

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