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Sustainability Related Disclosure

Eir Ventures I AB

Legal Entity Identifier: 549300OTCYI9VF12XB81

This statement of disclosure for the financial product Eir Ventures I AB (“the Fundˮ), managed by Eir Ventures (“the Managerˮ), has been prepared in accordance with Article 10 of the Regulation (EU) 2019/2088 on sustainability‐related disclosures in the financial services sector (“SFDRˮ) as well as the Commission Delegated Regulation (EU) 2022/1288 of 6 April 2022, supplementing SFDR.

This statement may be subject to changes or revisions, especially following the disclosure of any further legislation, guidance, or recommendations concerning the SFDR (including any delegated acts thereto) by the Danish or EU legislators and/or supervisory authorities.

SUMMARY

The Fund promotes environmental and social characteristics but does not have sustainable investments as its objectives. The detailed environmental & social characteristics promoted by the Fund is outlined in this website disclosure along with investment strategy, the proportion of these investments, methodologies, monitoring of environmental and social characteristics, methodologies, data sources and processing as well as limitations on methodologies and data, due diligence, engagement policies and reference index applied, if any.

NO SUSTAINABLE INVESTMENT OBJECTIVE

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

ENVIRONMENTAL OR SOCIAL CHARACTERISTICS OF THE FINANCIAL PRODUCT

The Fund promotes the following environmental and social characteristics:

The Fund promotes environmental and social characteristics by assessing sustainability impacts as part of the due diligence procedures that screen an investment. The environmental and social characteristics of the Fund are also promoted through refraining from investing in activities listed on the Managerʼs exclusion list. The exclusion list comprises activities that fall within the scope of the following activities:

  • Limiting Peopleʼs Individual Rights and Freedom or Violation of Human Rights: The Fund abstains from investing in activities that directly or indirectly result in harmfull or explotitative forms of forced labor or harmful child labor. These forms of labor are defined by the International Labour Organizationʼs Fundamental Labour Conventions.
  • Prohibited Activities by National Legislation or International Agreements Ratified by the European Union: The Fund avoids investments in activities performed by companies that do not acknowledge or strive to be aligned with the goals of the Paris Agreement. Furthermore, any activities involving significant degradation, conversion, or destruction of crucial habitats is considered uacceptable from an environmental and climate-related perspektive.
  • Prohibited Activities by National Legistlation or International Agreements Ratified by the European Union: The Fund refrains from investing in any products or activities that are prohibited by national legislation or international agreements ratified by the European Union. This includes activities subject to international phase-out or bans, activities prohibited by host country legislation, or internal legal instruments ratified by the European Unionen related to the protection of biodiversity resources or cultural heritage. Addtionally, the deliberate release of genetically motified organisms (GMOs) is considered an excluded actitity.
  • Ethically or Morally Controversial Activities: The Fund avoids investing in ethically or morally controversial activities, such as animal and human reprodutive cloning. Furthermore, activities involving live animals for non-essential scientific and experimental purposes, including gene editing and the breeding of these aniamals are also excluded.

By adhering to these exclusion criteria, the Fund promotes environmental and social characteristics in the investment practices and contributes to a more ethical and responsible life science sector. Moreover, the Fund is dedicated to promoting sustainable and responsible investment practices, which encompases various aspects including environmental awareness, compliance with labour laws, and the implementation or sound governance structures and ethical business practices. This is done thorugh the following:

  • Promotion of an appropriate level of environmental awareness and practice: The Fund actively encourages an appropriate level of environmental awareness among its portfolio companies. This involves fostering practices that comply with current environmental laws and regulations. By ensuring compliance, the Fund aims to minimize adverse effects on the environment resulting from the activities of its portfolio companies.
  • Compliance with labor laws and encouragement of competitive employee remuneration, safe and healthy workspaces: The Fund places significant importance on compliance with labor laws. It encourages its portfolio companies to adhere to applicable labor laws, which include provisions related to employee remuneration, workplace safety, and the provision of healthy working conditions. The Fund promotes the implementation of competitive employee remuneration practices and supports the creation of safe and healthy workpaces in accordence with relevant local legislation.
  • Promotion of Sound Governance Structures and Ethical Business Practices: The Fund actively advocates for the establishment of sound governance structures within its portfolio companies. This included the implementation of effective corporate governance practices.
  • The Fund seeks to influence the portfolio companiesʼ impact on sustainability matters through engagement and active ownership and thereby promoting ethical and energy efficient experimentation and production of medical products with zero-to-minimal toxic waste generation.
  • Environment and social characteristics are being promoted as part of due diligence process while screening on investments.

Specifically, the Fund promotes the UN Sustainable Development Goals (“SDGˮ) by contributing to the SDG 3 (Good Health and Well-being), SDG 9 (Industry, Innovation, and Infrastructure), and SDG 19 (Partnership for the Goals) by partially investing in companies contributing to such goals.

INVESTMENT STRATEGY

The Manager is a life sciences venture capital fund investing in private companies with stellar entrepreneurs developing transformative therapeutic approaches. Optimal and responsible value creation for companies and investors is obtained by working closely with the portfolio companies.

The Fund exclusively invests in life science SMEs in Europe and the USA where the life science field is highly regulated by local legislation and international conventions.

The Fund actively advocates for the establishment of sound governance structures within its portfolio companies. This included the implementation of effective corporate governance practices.

The Fund seeks to influence the portfolio companiesʼ impact on sustainability matters through engagement and active ownership and thereby promoting ethical and energy efficient experimentation and production of medical products with zero-to-minimal toxic waste generation.

PROPORTION OF INVESTMENTS

The Fund does not impose mandatory obligation to allocate investments specifically towards sustainable investments with an environmental objective aligned with the EU Taxonomy. Consequently, the Fundʼs minimum investment proportion in such sustainable investments aligned with the EU Taxonomy is 0%.

MONITORING OF ENVIRONMENTAL AND SOCIAL CHARACTERISTICS

To ensure monitoring of environmental and social characteristics are being promoted by the Fund, practices including environmental awareness, compliance with labor laws, and the implementation or sound governance structures and ethical business practices are being implemented.

METHODOLOGIES

The attainment of the environmental and social characteristics promoted by the Fund are measured through the following indicators:

  • The portfolio companies in the Fund are assessed based on the information provided by the portfolio company and public information to identify any potential negative impacts, or any potential negative impacts that can be rectified with reasonable effort.
  • The Fund actively uses exclusion lists and refrain from investing in activities listed on the Managerʼs exclusion list, which includes activities within the scope of various categories: Limiting Peopleʼs Individual Rights and Freedom or Violation of Human Rights, Prohibited Activities by National Legislation or Internal Agreements Ratified by the European Union, and Ethically or Morally Controversial Activities

DATA SOURCES AND PROCESSING

The attainment of the characteristics is ascertained on the assessment of information provided by the portfolio company and on public information, and the outcome presented in the investment documentation.

LIMITATIONS TO METHODOLOGIES AND DATA

Majority of the Fundʼs investment will align with its environmental and/or social characteristics though the Fund maintains flexibility to pursue other investment opportunities involving cash and other investments (referred as ‘othersʼ) that lack sufficient ESG data.

DUE DILIGENCE

Due diligence is done through sustainability analysis promoting sustainability conduct and exclusion criteria. So environmental and social sustainability risks are being assessed and integrated in our investments due diligence, decision making processes and in the management of portfolio companies. Furthermore, by adhering to the exclusion criteria, the Fund seeks to promote environmental and social characteristics in its investment practices and contribute to a more ethical and responsible life science sector.

ENGAGEMENT POLICIES

As part of active engagement, the manager aims to be accessible to all relevant stakeholders and engage with them directly or indirectly through representatives. This allows meaningful dialogues and consideration of varied perspectives.

DESIGNATED REFERENCE BENCHMARK

No designated reference index is used by the Fund for promoting the environmental and social objectives.

EIR VENTURES – Exclusion list

Eir Ventures will not provide financing to companies or activities that meet any of the following criteria:

  1. Violation of individual rights and human rights:
  • Activities that involve forced labor or exploitative child labor, as defined by the International Labour Organization’s Fundamental Labour Conventions
  • Any activity that results in the limitation of individual rights or freedoms, or involves human rights violations
  1. Environmentally harmful activities:
  • Activities that are not aligned with the Paris Agreement’s principles and goals, including those in high-emission sectors.
  • Activities leading to significant degradation, conversion, or destruction of critical habitats.
  • Any activity that endangers biodiversity or habitats.
  1. Prohibited by law or regulation:
  • The production, trade, or use of products or substances that are banned or subject to international phase-out regulations, such as hazardous chemicals, pharmaceuticals, pesticides, or herbicides.
  • Activities involving the deliberate release of genetically modified organisms (GMOs).
  1. Ethically or socially controversial activities:
  • Human and animal reproductive cloning.
  • The creation of human embryos for research, post-mortem medically assisted procreation, or euthanasia.
  • Any activity related to pornography, including the production, distribution, hosting, or marketing of material or activities.
  • The ownership, operation, marketing, or management of gambling facilities, including online gambling.
  • The production, distribution, marketing, or trade in tobacco, tobacco products, or alcoholic beverages.
  • The production, trade, or use of weapons of mass destruction, inhuman weapons, or technologies that are subject to international prohibitions.
  1. Financial or legal distress:
  • Companies that are bankrupt, being wound up, having their affairs administered by the courts, or have suspended their business activities.
  1. Misrepresentation or failure to provide information:
  • Companies that have misrepresented or failed to provide required information in relation to financing under InnovFin Equity.
  1. Involvement in illegal or unsustainable activities:
  • Companies that, in the last five years, have been involved in fraud, corruption, participation in a criminal organization, money laundering, or other illegal activities that could harm the financial interests of the European Union.
  • Companies with operations in countries that are on sanctions lists of the European Union, the United States, or the United Nations.
  • The exploration, mining, refining, or trade in non-renewable energy sources such as thermal coal and oil sands.
  1. Non-compliant jurisdictions:
  • Companies that are based in, or have business relations with, jurisdictions classified as non-compliant by the OECD’s Global Forum on Transparency and Exchange of Information for Tax Purposes.
  1. Unlawful research activities:
  • Research aimed at human cloning for reproductive purposes.
  • Genetic modification of human beings that could result in heritable changes (except for research related to cancer treatment).
  • Creation of human embryos solely for research or stem cell procurement