PAI

Currently, Innovestor AIFMs (Innovestor Ventures Oy and Innovestor Life Science Oy) do not consider adverse impacts of investment decisions on sustainability factors as described in Article 4(1) of the EU Regulation 2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”). The main reason for this is the unclear regulatory environment since the more detailed requirements relating to the consideration of adverse impacts of investment decisions on sustainability factors (so called regulatory technical standards) are still in draft form. Additionally, the official guidance on the topic is insufficient or it does not exist.

Especially measuring the adverse impacts is challenging when the portfolios of our funds consist of several minority investments in unlisted companies where sufficient data might not even exist. However, based on the scope and nature of our business and current portfolio companies we believe there would not be material adverse effects if measurable.

Once there are more detailed regulations and guidelines as well as market practices regarding measuring, considering, and reporting adverse impacts on sustainability factors, Innovestor AIFMs will reconsider their approach to the foregoing.

The aforesaid also applies to all Funds managed by Innovestor AIFMs. None of the Funds considers adverse impacts of investment decisions on sustainability factors as described above at this point.