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1. Purpose

Stableton Financial AG (the “Company”) aims to create a successful, sustainable, diverse, inclusive, and mission-driven technology ecosystem. The purpose of this policy is to establish Company’s objectives and standards in responsible investing and managing Environmental, Social, and Governance (“ESG”) issues within its business operations and to establish principles and procedures which will allow the Company to achieve them.

2. Scope of Application

This policy applies to all employees of the Company. Furthermore, this policy applies to all existing and future investment structures managed or advised by the Company, as well as to Company’s own operations. Notwithstanding that the investment structures may have more restrictive ESG strategies.

3. Definitions

3.1. Environmental, Social, and Governance - ESG

The Company defines ESG as a combination of:

  • Environmental factors such as pollution and contamination, legal and regulatory compliance, eco-efficiency, waste management, natural resource management, climate change effects, biodiversity, and the development of sustainable technologies and markets;

  • Social factors such as employee treatment, human rights, discrimination, diversity and inclusion, supply chain management, and the treatment of all stakeholders;

  • Governance factors such as anti-corruption measures, business ethics, accountability, transparency, conflict of interest, whistleblowing, and the governance of environmental and social factors.

The above definition is not exhaustive and may be reviewed, refined, and expanded as deemed necessary.

3.2. ESG Approach

The Company believes that great companies can come from anywhere and that entrepreneurs are the key to a better world. The Company understands the vital role that ESG issues play in the success of investments made and the impact some of its portfolio companies have. Therefore, the Company is committed to promoting responsible business practices and generating superior long-term performance.

The Company’s approach is not only focused on mitigating risks but also on adding value by using ESG factors to improve business practices. Where possible and appropriate, the Company provides portfolio companies additional guidance on implementing best practices (e.g. access to relevant resource centers). The Company may work with third-party data & service providers to capture and monitor ESG-related KPIs in its portfolio companies, while ensuring a neutral third-party review where appropriate.

3.3. Commitment to ESG

The Company’s commitment to ESG includes:

  • maintaining strong ESG governance within the Company’s own operations,

  • nominating a body responsible for the oversight of the implementation of this Policy,

  • providing staff with specific training and resources, 

  • implementing ESG considerations at level of portfolio companies both in the investment selection process (as part of the investment screening and due diligence), as well as throughout the holding period, where possible and appropriate.

4. Organization and Responsibility

4.1. Executive Board

The Executive Board is responsible for implementation of this policy in relation to the Company operations.

4.2. Investment Committee

The Investment Committee is responsible for implementation of this policy in relation to portfolio companies.

4.3. Investment Process

The Company acknowledges that product-specific approaches to ESG integration may vary based on the characteristics of individual investment products.

The Company maintains separate Product Guidelines, which outline application of the policies to the relevant product or group of products. Among other aspects, the Product Guidelines define criteria for selecting, managing, and monitoring investments in alignment with the ESG objectives of each product or product group.

4.4. Transparency towards investment structures

The Company aims to be highly transparent on ESG topics with the investment structures it advises and manages. Reporting modalities are specified in the Product Guidelines.

4.5. Transparency towards wider stakeholders

The Company actively engages with all relevant stakeholders and annually reports its ESG activities to the UNPRI, who publishes the report on its website. 

4.6.  Environmental footprint

The Company is conscious about the environmental impact of its day-to-day operations.

4.7. Promoting diversity, inclusion and equality in the workplace

Diversity and Inclusion are embedded in the core of the Company across all its levels and are reflected in the Company’s Personnel Policy. The Company’s goal is to be a leading and top performing European technology investment platform that contributes meaningfully to a better future. The Company is an equal opportunities employer and respects and celebrates the diversity of its employees. The Company’s objective is to attract, motivate, develop and retain a diverse and talented group of people while also providing a working environment that promotes both inclusion and equality. The Company has an inclusive culture and practice of open sharing of information; transparent decision-making and providing an accessible environment for all. 

4.8.  ESG in remuneration framework and code of conduct

Employee remuneration is governed by the Company’s Personnel Policy. In general, employee compensation includes a variable component based on an annual appraisal process which includes the extent to which employees promote the Company’s guiding principles and adhere to the Company’s policies. A significant portion of compensation of senior employees is also linked to the long-term performance of investment products advised or managed by the Company. The Company considers that in addition to the internal Code of Conduct policy, this approach aligns the interest of employees with those of our clients and is appropriate to promote a culture of reducing long-term ESG risks within the portfolio companies and thus creating long-term value and financial performance.

4.9. Principal Adverse Impact Statement

The Company is not subject to Sustainable Finance Disclosure Regulation 2019/2088 (“SFDR”) as it operates under Swiss law. The Company further does not consider principal adverse impacts on sustainability factors due to the fact that accurate data is often lacking from portfolio companies, in particular in early stages of development. Principal adverse impacts may however be considered where the Company has the sufficient resources to collect and report on accurate ESG data. 

5. Monitoring

Compliance with this directive is monitored by the Executive Board. At the request of the Compliance Officer, employees are obliged to allow the Company full access to their activities and documentation and to provide related information.

6. Annual Review

This policy shall be reviewed annually and amended as necessary.

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