SFDR

1. General information
Vitamin°C I Fund SCSp (the “Fund”) is classified as an Article 8 product under Regulation (EU) 2019/2088 on sustainability‑related disclosures in the financial services sector (“SFDR”). The Fund promotes environmental and governance characteristics but does not have sustainable investment as its objective within the meaning of Article 2(17) SFDR. The Fund does not designate a reference benchmark for the attainment of its environmental or social characteristics. These disclosures are primarily intended for investors in the European Union and are also made available for information purposes to investors in the United Kingdom and Switzerland.

2. Environmental and/or social characteristics promoted
The Fund promotes environmental and governance characteristics by investing in early‑stage companies whose business models contribute to climate change mitigation and/or climate adaptation and operate in accordance with minimum governance standards.

On the environmental side, the Fund promotes, among others:

  • Reduction of greenhouse gas emissions across Scope 1, Scope 2 and, where relevant and feasible, Scope 3 categories.

  • Avoidance of material negative impacts on biodiversity‑sensitive areas.

On the social and governance side, the Fund promotes, among others:

  • Gender diversity at board and top management level.

  • Adoption of policies and compliance mechanisms aligned with the UN Global Compact principles and the OECD Guidelines for Multinational Enterprises, or comparable grievance and complaints‑handling mechanisms.

3. Investment strategy
The Fund follows an early‑stage venture capital strategy focused on climate mitigation and climate adaptation solutions. The Fund invests primarily in pre‑seed and seed‑stage companies, with a focus on sectors such as energy transition, food and agriculture, carbon removal and adaptation, where impact is intrinsic to the business model.

Prior to each investment, the Fund applies a structured impact and ESG due diligence process and conducts ongoing monitoring and engagement throughout the holding period. The investment strategy includes binding elements that guide the selection of investments to ensure alignment with the promoted environmental and governance characteristics.

4. Binding elements of the investment strategy
The following elements are binding in the Fund’s investment process:

  • Completion of a forward‑looking impact potential assessment evaluating the company’s expected contribution to greenhouse gas emission reduction or climate resilience.

  • Assessment of greenhouse gas emissions exposure across Scope 1, Scope 2 and, where relevant and feasible, Scope 3 emissions, in accordance with the GHG Protocol.

  • Screening for activities negatively affecting biodiversity‑sensitive areas as part of environmental due diligence.

  • Review of the ratio of female to male board members and representation of women in top management.

  • Verification that the investee company has, or commits to adopting, policies to monitor compliance with the UN Global Compact principles or the OECD Guidelines for Multinational Enterprises, or has grievance or complaints‑handling mechanisms in place.

  • Documentation of these assessments in the investment memorandum prior to investment approval.

5. Exclusion policy
The Fund applies a binding exclusion policy and will not invest in companies that are materially involved in:

  • Fossil fuel exploration and production, including coal mining and coal‑fired power generation.

  • The manufacture or trade of controversial weapons.

  • The production of tobacco products.

  • Activities that constitute serious or systematic violations of the UN Global Compact principles or the OECD Guidelines for Multinational Enterprises.

Material involvement is assessed proportionately to the size, stage and nature of the investee company and is applied at the time of the investment decision. Where potential or existing portfolio companies approach, meet or breach these exclusion criteria, the manager applies negative screening, engages to remediate within a defined timeframe and may, as a last resort, consider divestment.

6. Asset allocation
The Fund intends to allocate 100% of its investments (excluding cash and cash equivalents held for liquidity management) to investments that are aligned with environmental and/or social characteristics under category “#1 Aligned with E/S characteristics”, specifically #1B “Other environmental or social characteristics”. The Fund does not commit to making sustainable investments within the meaning of Article 2(17) SFDR; accordingly, the minimum proportion of such sustainable investments (including EU Taxonomy‑aligned investments) is 0%. Temporary cash, cash equivalents or money market instruments held for liquidity purposes may be classified as “#2 Other” and are not used to attain the environmental or social characteristics.

7. Consideration of principal adverse impacts
The Fund does not currently consider principal adverse impacts (“PAI”) on sustainability factors within the meaning of Article 7 SFDR and does not publish a PAI statement at entity level. Given the size of the manager and the early‑stage profile of the portfolio companies, the systematic collection and quantitative reporting of the PAI indicators set out in Annex I of the SFDR Regulatory Technical Standards is considered disproportionate at this stage.

Nonetheless, sustainability risks and material adverse sustainability impacts are addressed qualitatively through the Fund’s investment screening process, exclusion policy, ESG due diligence and ongoing portfolio monitoring. Climate‑related sustainability risks and transition risks are assessed qualitatively at every stage of the investment process, from pre‑selection through to due diligence and portfolio monitoring.

8. Good governance practices
In line with Article 8 SFDR requirements, the Fund assesses good governance practices of investee companies at the pre‑investment stage and monitors them throughout the holding period. The ESG due diligence process evaluates, in a manner proportionate to company size and stage, governance aspects such as management structure, board composition, transparency of decision‑making and the existence or commitment to adopt core policies on anti‑corruption, business ethics, compliance and employee relations.

Where relevant, alignment with internationally recognised standards, including the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, is considered. Governance risks are documented and, where material deficiencies are identified, the Fund may require remedial actions as a condition of investment, monitor progress post‑investment, escalate issues through governance channels or ultimately decide not to proceed or to exit.

9. Use of derivatives
The Fund does not use derivatives to attain the environmental or social characteristics it promotes. If used, derivatives would only serve hedging or efficient portfolio management purposes and would not form part of the impact or sustainability strategy.

10. EU Taxonomy alignment
The Fund does not commit to making sustainable investments with an environmental objective aligned with the EU Taxonomy, and therefore the minimum share of such investments is 0%. The minimum share of sustainable investments with a social objective is also 0%. The Fund does not invest in fossil gas and/or nuclear energy‑related activities that comply with the EU Taxonomy.

11. Jurisdictional note (EU, UK, Switzerland)
These disclosures are made to comply with the EU SFDR framework. For investors in the United Kingdom and Switzerland, this information is provided on a voluntary and non‑binding basis to enhance transparency on the Fund’s sustainability‑related characteristics and investment approach. The Fund is not categorised under the UK Sustainability Disclosure Requirements or any Swiss ESG labelling regime, and no claim is made that the Fund meets any such local labelling or classification.

12. Further information
More product‑specific information, including the Fund’s impact framework, responsible investment policy, ESG policy, code of conduct and periodic reporting, can be requested from the Fund’s manager at hello@vitaminc.vc. Additional information can also be found on the Fund’s website at vitaminc.vc/sfdr.