ESG Policy

1. Purpose

Stableton Financial AG (the “Company”) aims to create the most successful, sustainable, diverse, inclusive, and mission-driven technology ecosystem among its peers. 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 firmly believes that great companies can come from anywhere and that entrepreneurs are the key to a better world. The Company’s purpose is to invest in companies that generate profits and benefit society. ESG is at the core of the Company’s investment philosophy, purpose, and values. 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 strongly encourages portfolio companies, founders and CEOs to actively engage with ESG implications of their business activities. 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 works with third-party data & service providers to capture and monitor ESG-related KPIs in its portfolio companies, while ensuring a neutral third-party review.

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.

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

4.3.1. Pre-Investment

As part of investment screening process, ESG risks and factors of potential portfolio companies are assessed and analyzed internally by the Investment Team. In addition, in certain cases external ESG data and service providers may be engaged in the analysis. The results of the analysis are an integral part of due diligence documentation presented to the Investment Committee, and as such are assesses with due care. Should the Investment Committee find that the ESG risks are too great and/or cannot be appropriately mitigated in a reasonable timeframe, the investment proposal in the portfolio company is rejected.

The Company aims to maximise performance of its investment products by selecting portfolio companies with the best and most ambitious founders from a diverse set of demographics, backgrounds, and experiences. The selection process aims to be impartial and designed to consider various perspectives, and identify biases and blind spots.

4.3.2. Monitoring and Encouraging Continuous Improvement

The Investment Team monitors on a regular and recurring basis key ESG factors of portfolio companies throughout their holding period and reports potential adverse findings to the Investment Committee. As part of the Company’s mission to partner with game-changers and to help founders build category-winners, wherever possible the Investment Team will help founders to identify and respond to opportunities to further improve their ESG engagement. On request, the Company may also provide portfolio companies with access to training, materials and other resources.

4.4. Transparency towards investment structures

The Company aims to be highly transparent on ESG topics with the investment structures it advises and manages. To this end, the Company provides ESG information in annual reports of the investment structures.

4.5. Transparency towards wider stakeholders

The Company actively engages with all relevant stakeholders and publishes on its website an annual summary report of its ESG activities.

4.6.  Environmental footprint

The Company is conscious about the environmental impact of its day-to-day operations and mandates an external service provider to assess its own carbon footprint on an annual basis.

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. Stableton runs monthly engagement surveys using 15Five as a well-being measurement tool to help to identify areas for improvements at management level, and acts on change.

4.8.  ESG in remuneration framework and code of conduct

Employee remuneration is governed by the Company’s Personnel Policy, which complies with the FINMA Circular 2010/1 "Remuneration Systems". 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.

7. Entry into force

This policy shall enter into force on 23.02.2023.