Responsible Investment Policy

Introduction

Eir Ventures, as a life sciences venture capital fund, is committed to driving healthcare innovation through investments that benefit patients, healthcare systems, and society. With the Nordic region offering unique opportunities for high-return investments due to its wealth of medical innovation and scarcity of capital, Eir Ventures focuses on developing transformative therapies.

As a signatory of the UN Principles for Responsible Investment (PRI) since 2024, Eir Ventures recognizes its potential impact and integrates Environmental, Social, and Governance (ESG) factors into its investment processes. This commitment is reflected in their active engagement with portfolio companies, aiming to enhance their ESG practices collaboratively. Eir Ventures views responsible investing as essential to fostering positive societal and environmental outcomes while generating attractive financial returns.

The fund also collaborates with leading Nordic universities and leverages its extensive networks and company-building expertise to support companies across various stages of growth. This approach is designed to transform innovative ideas into viable products that address both healthcare challenges and broader societal needs, emphasizing Eir Venturesʼ role in promoting sustainable and impactful healthcare solutions.

Key Principles of Responsible Investment

Eir Ventures is dedicated to promoting responsible investment by integrating environmental, social, and governance (ESG) principles into all stages of its investment processes. Our approach is guided by the Principles for Responsible Investment (PRI), the UN Global Compact, and the UN Guiding Principles on Business and Human Rights, ensuring that we contribute positively to society and the environment while delivering long-term value to our investors.

General key principles:

• Investment discipline: We prioritize investments that generate positive societal impacts, and aim to drive healthcare innovation to the benefit of patients, healthcare systems, investors and society.
• Exclusions: We avoid investments in specific industries (see exclusion list below).
• Investment Strategy: Our goal is to create long-term sustainable value and mitigate risks through our investment processes by a rigorous DD-process including assessing ESG-status by checklist, data collection and interviews with management.
• Active Ownership: Our investments are accompanied by an active and supportive approach towards companies, including their boards and management teams. We encourage these companies to prioritize societal impact and ESG measures, and we closely monitor their progress.
• Collaborations: We partner with international institutions (including UN-PRI, venture RSG and the Knowledge project) to promote responsible investment practices, transparency, and sustainability standards.

Investment Principles

• Financial Returns: We strive to generate strong financial returns for our investors while ensuring that portfolio companies are positioned for long-term, sustainable growth.
• Minimise risks: We want to minimize economic and reputational risks for ourselves, for our portfolio companies and for our Limited Partners.
• Strengthening Management: Eir Ventures actively supports the management teams of portfolio companies, fostering their ability to grow responsibly and implement ESG best practices.
• Societal Solutions: We prioritize investments that address significant societal challenges, within the life sciences sector, such as meeting unmet medical needs and improving healthcare solutions.
• Ethical and Sustainable Healthcare: Our investments are guided by the highest standards of medical ethics, contributing to the development of sustainable healthcare innovations.

Environmental Principles

• Biodiversity and Environmental Conservation: Eir Ventures seeks to minimize any detrimental impact on biodiversity through responsible investment choices and by promoting sustainable practices among portfolio companies.
• ESG Improvement: We engage with portfolio companies to continually improve their environmental performance, encouraging them to adopt sustainability policies and reduce their environmental footprint.
• Compliance with Environmental Laws: All investments comply with relevant environmental regulations, including the EUʼs environmental laws and agreements.

Social Principles

• Human Rights and Labor Rights: We promote the respect and protection of internationally recognized human rights and labor standards, including zero tolerance for forced or child labor.
• Workplace Safety and Satisfaction: Eir Ventures ensures safe, healthy, and inclusive workplaces in its portfolio companies, promoting employee well-being and satisfaction.
• Diversity, Equity, and Inclusion: We actively promote diversity and inclusion across all levels of our portfolio companies, encouraging equal opportunities for all employees and leadership roles for underrepresented groups.

Governance Principles

• Sound Corporate Governance: We work to implement clear governance structures within our portfolio companies, ensuring transparency, accountability, and high ethical standards.
• Business Integrity: Eir Ventures upholds the highest standards of business integrity, rejecting unethical practices such as fraud, bribery, and corruption.
• Ethical Business Practices: We promote the adoption of responsible business practices throughout the value chain, ensuring compliance with relevant laws and international agreements.

Contribution to the UN Sustainable Development Goals (SDGs)

Through our responsible investment approach, Eir Ventures contributes to the following UN Sustainable Development Goals:

• SDG 3: Good Health and Well-being – By investing in innovative life sciences companies that improve healthcare and address unmet medical needs.
• SDG 9: Industry, Innovation, and Infrastructure – Supporting innovation and infrastructure development in the healthcare and life sciences sectors.
• SDG 12: Responsible Consumption and Production – Encouraging sustainable resource use and reducing environmental impacts within our portfolio companies.

Scope of Eir Ventures Responsible Investment Policy

The Responsible Investment Policy applies to all investments managed by Eir Ventures, including investments where Eir Ventures holds board seats and exercises direct influence, as well as investments where our influence is indirect but ESG standards are encouraged through oversight (e.g., the seedling investments).

For all our investments, regardless of ownership magnitude, Eir Ventures promotes the integration of ESG principles. We encourage portfolio companies to adopt and implement ESG practices appropriate to their stage of development—whether in incubation, seed, series A, etc. Our focus is on fostering responsible business conduct, continuous improvement, and a commitment to sustainability.

This policy applies to all stages of the investment lifecycle, including pre-investment screening, post-investment monitoring, and exit strategy development.

Governance of the Responsible Investment Policy

Roles and responsibilities

The overall oversight and control of responsible investment practices at Eir Ventures lies with the Managing Partners. The Managing Partners are responsible for ensuring that ESG principles are integrated into the investment process and that the Responsible Investment Policy is kept up to date. The Managing Partners meet regularly throughout the year to review and discuss key strategic priorities, including the advancement of ESG practices.

Additionally, the ESG Responsible individual oversees the ongoing review and implementation of the Responsible Investment Policy. This role ensures that the policy remains aligned with the evolving regulatory environment and industry best practices.

Eir Ventures is committed to maintaining a responsible investment approach and will continue to actively engage internal and external stakeholders on ESG issues, where necessary, to promote transparency and long-term value creation.

Annual reporting

Eir Ventures is committed to promoting and implementing the principles of responsible investment and ownership within the venture capital industry. As part of this commitment, Eir Ventures will assess the progress made in implementing our Responsible Investment Policy on an annual basis, evaluating the ESG performance of our portfolio companies and the impact of our investments.

Additionally, as a signatory to the UN Principles for Responsible Investment (UN-PRI), Eir Ventures will submit an annual report to the UN-PRI, detailing how ESG factors have been integrated into our investment processes and the progress made toward our responsible investment goals.

This annual assessment provides transparency to our investors and stakeholders, ensuring that measurable and material ESG metrics and impact indicators are tracked.

Update Procedure

Annually, the Managing Partners and the ESG Responsible will review the relevance, quality, and effectiveness of the Responsible Investment Policy and its implementation. This review ensures that the policy continues to align with Eir Ventures’ commitment to responsible investment and evaluates progress in integrating ESG criteria into our investment and engagement practices.

By assessing both the policy and its practical application, Eir Ventures aims to ensure that the integration of ESG principles across our work produces meaningful results. Any updates to the policy will be documented, ensuring transparency and continuous improvement.

Sector Engagement and Collaboration

At Eir Ventures, we believe collaboration drives the greatest impact, especially in the relationships between our portfolio companies and investment teams. In addition to this, broader sector engagement is essential in shaping our responsible investment approach and contributing to the wider venture capital community.

Eir Ventures are a member of the Swedish Venture Capital Association (SVCA) and participates in events and discussions that promote the integration of ESG and responsible investing in the venture capital industry. As members of initiatives like Venture ESG and the Knowledge Project, we regularly share knowledge, experience, and best practices with other General Partners (GPs) and Limited Partners (LPs), contributing to the ongoing development of ESG frameworks and standards.

The Knowledge Project brings together life science venture capital firms to optimize interactions with portfolio companies, improve data quality, and advance coordinated ESG KPIs across numerous portfolio companies. By collaborating with peers, we enhance the effectiveness of our responsible investment approach and contribute to sector-wide progress on ESG integration.

Implementation of Responsible Investments

Our responsible investment principles and ESG policy are included in the whole investment cycle, i.e., during Due diligence, ownership, and exit/post-investment phases.

Due Diligence

Potential investments are screened against Eir Ventures’ Exclusion List, which outlines sectors and activities that we will not invest in, ensuring that our portfolio reflects our commitment to ethical and responsible investing.
As part of our due diligence process, we have developed a mandatory ESG checklist that helps assess sustainability risks and opportunities. This checklist ensures a structured approach to evaluating potential investments, covering key environmental, social, and governance (ESG) factors.

In addition to the checklist, we conduct data collection and interviews with management to gain a deeper understanding of how these early-stage companies manage sustainability risks and how these risks can be mitigated. This process is guided by our Sustainability Risk Policy, which ensures that our decisions align with responsible investment principles.

When the ESG-risk assessment highlights risks that are too significant to address in a timely or satisfactory manner, no investment will be made. For potential investees where improvement areas are identified, we ensure that the company is committed to implementing appropriate remedial measures within a reasonable and jointly agreed timeframe. This approach guarantees that our responsible investment principles are upheld throughout the investment process.

During Ownership

Eir Ventures actively engages with its portfolio companies to promote continuous improvement in environmental, social, and governance (ESG) practices through the following methods:

1. Annual ESG reporting: Portfolio companies are required to complete an annual ESG questionnaire. This questionnaire includes key performance indicators (KPIs) aligned with SFDR and Limited Partner (LP) requests, tracking the companyʼs progress in meeting relevant ESG objectives. Transparency is essential to our approach to responsible investment, ensuring timely and relevant information is available to investors. Our annual assessment of ESG factors includes both quantitative and qualitative data gathered from portfolio companies, tracking key ESG metrics such as:
   • Environmental: Resource management, sustainability practices, and risk management.
   • Social: Employee well-being, diversity and inclusion, and workplace safety.
   • Governance: Good governance practices, business ethics, and data privacy.
2. Board engagement: In cases where Eir Ventures holds a board seat, we engage directly with portfolio companies to guide and shape their ESG practices. Through board meetings, we provide ongoing advice on sustainability issues and encourage responsible business conduct.
3. ESG support platform: Eir Ventures provides portfolio companies access to an ESG platform through a third party. This platform offers resources such as ESG information, assistance with policy development, and tools for measuring key metrics like greenhouse gas emissions. This support helps portfolio companies enhance their sustainability practices and align with best ESG standards.

In cases of serious non-compliance or violations of our investment principles, Eir Ventures will engage with the investee to address these issues. If satisfactory resolution is not achieved, appropriate steps will be taken to protect the value of the investment, including potential escalation.

Responsible Exit

At Eir Ventures, we are committed to ensuring that our portfolio companies are prepared for responsible exits. While our investments typically focus on early-stage companies, we work closely with them throughout the investment lifecycle to build strong management teams and ensure that they are well-positioned for future partnerships, acquisitions, or exits.

Our investment strategy, including potential exit timeframes, is communicated clearly during the pre-investment phase. During the post-investment phase, we continuously assess the company’s readiness for exit, considering market conditions and opportunities with potential buyers.

When an exit is being considered, Eir Ventures carefully evaluates the buyer profile, ensuring that the transaction aligns with the companyʼs long-term goals and that the buyer shares a commitment to responsible practices. We also ensure that fair treatment is provided to all shareholders, including employees and stock option holders, throughout the transaction process.

Conflicts of Interest Related to Responsible Investment

Eir Ventures has a Conflicts of Interest Related to Responsible Investment policy that applies to all employees, partners, and associated entities of Eir Ventures, and covers ownership restrictions, disclosure of investment opportunities, pre-existing ownership, and identification and management of conflicts of interest. The policy aims to protect the interests of investors, stakeholders, and portfolio companies by ensuring transparency and accountability in the investment processes, and by prioritizing the interests of Eir Ventures over personal interests or relationships. The policy also outlines the procedures for disclosure, compliance, monitoring, and review of potential conflicts of interest, and the consequences of non-compliance.

Appendix 1: Principles in UN PRI (Principles for Responsible Investing) and UNGC (Ten Principles of the United Nations Global Compact)

Eir Ventures is a Signatory of UN-PRI. The PRI principles serve as a guiding framework for this document and are central to the implementation of responsible investment across our processes, ensuring that we remain committed to sustainable value creation and risk management

Eir Ventures expects its portfolio companies to adhere not only to local and industry regulations but also to the Ten Principles of the United Nations Global Compact (UNGC). These principles cover four key areas: human rights, labor, environment, and anti-corruption. We encourage our investees to integrate these principles into their strategies, policies, and operational procedures, ensuring they are reflected in everyday business practices.
By following the UNGC principles, both Eir Ventures and its investees uphold their fundamental responsibilities to people and the planet, fostering sustainable growth and ethical practices.

Human Rights: Businesses should…

• Principle 1: Support and respect the protection of internationally proclaimed human rights.
• Principle 2: Make sure that they are not complicit in human rights abuses.

Labour Standards: Businesses should uphold…

• Principle 3: The freedom of association and the effective recognition of the right to collective bargaining.
• Principle 4: The elimination of all forms of forced and compulsory labour.
• Principle 5: The effective abolition of child labour.
• Principle 6: The elimination of discrimination in respect of employment and occupation.

Environment: Businesses should…

• Principle 7: Support a precautionary approach to environmental challenges.
• Principle 8: Undertake initiatives to promote greater environmental responsibility.
• Principle 9: Encourage the development and diffusion of environmentally friendly technologies.

Anti-Corruption: Businesses should…

• Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.