SFDR statement

Atlantic Food Labs Manager GmbH („AFL“) takes into account sustainability risks in its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investments. As part of its standard procedure, AFL conducts a due diligence prior to investing.Such due diligence includes a range of questions relating to environmental, social or governance-related aspects, thereby also providing a basis for assessing potential sustainability risks. The outcome of the due diligence, including any information on sustainability risks revealed through the due diligence, guides AFL’s investment decisions. In its free discretion, AFL may decide to make an investment even if sustainability risks have been determined. In such case, AFL may in its sole discretion decide to apply appropriate mitigation measures. At all times, AFL will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

AFL does not consider adverse impacts of investment decisions on sustainability factors within the meaning of Art. 4 SFDR of the Sustainable Finance Disclosure Regulation (EU 2019/2088) ("SFDR"), i.e. environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. The information that would need to be obtained from portfolio companies in connection with the disclosures required under Art. 4 SFDR is quite extensive and there is currently no market practice or no practical experiences with how the market, in particular co-investors and investees react to and deal with such new disclosure obligations and information requirements. In addition, legal uncertainties remain regarding the applicability of the SFDR and the scope of its obligations. In light of these uncertainties, AFL currently refrains from committing to consider adverse impacts on sustainability factors within the meaning of the SFDR. If and to the extent that these uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, AFL will re-evaluate following them in due course.

As a registered alternative investment fund manager within the meaning of section 2 (4) of the KAGB,AFL does not have, and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of the remuneration.

D. Sustainability-related Disclosures”

Atlantic Food Labs Fund I GmbH & Co. KG (the “Fund”) is a venture capital fund managed by AFL. AFL considers environmental and social characteristics as part of its investment decisions by incorporating certain investment exclusions (negative screening) during its decision-making process. Moreover, AFL invests at least 70% of the Fund’s capital in impact-driven enterprises (i.e. enterprises that, i.a ., have the purpose to achieve societal impact by providing entrepreneurial solutions to a societal issue based on a market-bases scalable approach). Such investments are impact oriented but do not represent sustainable investments within the meaning of Art. 2 no. 17 SFDR, because adverse effects and significant harm to other sustainability objectives are not assessed systematically. Nonetheless, AFL applies its impact methodology and ESG policy to ensure a structured approach towards ensuring a level of protection with regard to environmental, social and governance related aspects of its business.Acting for the Fund, AFL will at all times apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

The Fund focusses a large part of its investment strategy on achieving positive impact, i.e. 70% of theFund’s capital are to be invested in impact-driven enterprises (i.e. enterprises that, i.a ., have the purpose to achieve societal impact by providing entrepreneurial solutions to a societal issue based on a market-bases scalable approach). However, such investments are impact oriented but do not represent sustainable investments within the meaning of Art. 2 no. 17 SFDR, because adverse effects and significant harm to other sustainability objectives are not assessed systematically.

a) Performing research and innovation activities considered as illegal according to the applicable legislation in the country of the portfolio company;

b) An illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Fund or the relevant portfolio company or other entity, including without limitation, human cloning for reproduction purposes);

c) The production of, and trade in, tobacco and distilled alcoholic beverages and related products;

d) The financing and production of, and trade in, weapons and ammunition of any kind;e) Casinos and equivalent enterprises;

f) The research, development or technical applications relating to electronic data programs or solutions, which:

— Aim specifically at: (i) supporting any activity referred to under b) – e) above; (ii) internet gambling and online casinos; or (iii) pornography; or
— Are intended to enable to illegally (i) enter into electronic data net-works; or (ii) download electronic data.

Moreover, the Fund will invest at least 70% of its funds in impact-driven enterprises (i.e. enterprises that, that (i) have the purpose to achieve societal impact by providing entrepreneurial solutions to a societal issue based on a market-bases scalable approach, and expressly state such purpose in their articles of association or other corporate documents; (ii) have a business model which enables them to fund themselves on a non-grant basis to develop self-sustainable business models enabling them to access over time capital from return-seeking investors who hold and sell an interest in them in a way comparable to the venture capital model; (iii) in the frame of their societal purpose, define ex-ante their societal impact objectives within their business plans and specify associated metrics for directing operations and monitoring their impact ex-post; (iv) intend to use their own business growth to advance its pre-defined societal targets; and (v) are managed in an accountable and transparent way, taking into account the interests of employees, customers and other stakeholders affected by its business activities).