Legal

Sustainability

Disclosures pursuant to Regulation (EU) 2019/2088

As of 16.12.2024

Leap435 Management GmbH (“Leap435”), LEI: 391200R6SXMXY126B064, is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).

‍Art. 3 SFDR – Sustainability risk policies statement

Leap435 addresses sustainability risks in its investment decision-making process insofar as relevant. “Sustainability risk” means an environmental, social, or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment. When identifying a sustainability risk during the due diligence on potential investments, Leap435 decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk. Leap435 regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.


Art. 4 SFDR – No consideration of principal adverse impacts

Leap435 does not consider principal adverse impacts of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters. Leap435 does not use sustainability indicators. The investment focus of Leap435 on “sustainable mobility” startups encompasses in the majority new software and hardware innovations that are not offered to end consumers stand-alone, but rather are integrated into existing value chains of mobility products and services. These value chains are complex to an extent that as of today no sufficient standards or best practices exist to accurately or quantitatively measure the interdependent effects, of integrating these innovations, on the sustainability impact of other dependent parts of the supply chain. When and if this situation changes and accurate measures of interdependent sustainability impacts of changes in complex industrial production processes of mobility products and services become widely accepted standards Leap435 will reconsider its position on the consideration of principal adverse impacts.

Art. 5 – Remuneration disclosure

As a registered alternative investment fund manager within the meaning of the KAGB, Leap435 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 remuneration.

Further Sustainability Related Disclosures for our Financial Product

As of 16.12.2024

Art. 10 SFDR – Sustainability-related information about financial products that promote environmental or social characteristics

Leap435 Management GmbH (“Leap435”), LEI: 391200R6SXMXY126B064, is the alternative investment fund manager of Leap435 Fund GmbH & Co. KG (“Leap435 Fund”) within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).

Summary

This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment. The Leap435 Fund promotes sustainable mobility and applies investment restrictions. 100% of the investments will be in line with its investment strategy and investment restrictions.

No reference benchmark has been designated to attain the environmental or social characteristics promoted by the financial product.

Zusammenfassung

Dieses Finanzprodukt bewirbt ökologische oder soziale Merkmale, strebt aber keine nachhaltigen Investitionen im Sinne der Definition des Art. 2 Nr. 17 SFDR an. Der Leap435 Fund fördert „sustainable mobility“ und schließt bestimmte Sektoren für Investitionen aus.

Es wurde kein Referenzwert benannt, um die mit dem Finanzprodukt beworbenen ökologischen oder sozialen Merkmale zu erreichen.

No sustainable investment objective

This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.

Environmental or social characteristics of the financial product

The Leap435 Fund will invest in early-stage technology companies with a focus on sustainable mobility. In particular into companies with innovative new products or services in the following sectors:

  • Upcycling and recycling of mobility hardware
  • Autonomous mobility solutions
  • Battery tech & lifecycle management
  • Scope3 CO2 footprint reduction of mobility services
  • Automotive supply chain management and ESG compliance
  • Charging solutions for electrified mobility
  • Autonomous driving tech
  • Maintenance & repair services for electrified mobility
  • Software-defined vehicle protection and cybersecurity
  • In-vehicle entertainment, health & wellbeing
  • Autonomous logistics
  • Next generation vehicle development & manufacturing
  • Omnichannel sales optimization

Further promoted environmental and/or social characteristics are investment restrictions:

The Leap435 Fund may not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities:

  1. whose business activity consists of an illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Leap435 Fund or the relevant company or entity, including without limitation, human cloning for reproduction purposes), or
  2. which substantially focus on:
    1. the production of and trade in tobacco and distilled alcoholic beverages;
    2. the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies;
    3. casinos and equivalent enterprises; or
    4. the research, development or technical applications relating to electronic data programs or solutions, which (x) aim specifically at supporting any activity referred to under (i) to (iii) above; internet gambling and online casinos; or pornography; or which (y) are intended to enable to illegally enter into electronic data networks or to illegally download electronic data.

No reference benchmark has been designated for the purpose of attaining the environmental and social characteristics promoted by the Leap435 Fund.

Investment strategy

The Leap435 Fund intends to seek long-term capital appreciation through equity and quasi-equity investments in early-stage technology companies with a focus on sustainable mobility predominantly in Europe.

No investments are made in the area of exclusions. As part of the due diligence and ongoing investment management, the investment team for the Leap435 Fund will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies.

Policy to assess good governance practices of the investee companies

As part of the due diligence and ongoing investment management, the investment team will review whether a potential investee company has good governance practices in place. This might include using ESG (environmental, social, and governance) criteria to evaluate companies' performance in areas such as labor practices, human rights, and corporate governance, conducting due diligence on investee companies to assess their management structures, employee relations, and tax compliance, engaging with investee companies through to encourage improvements in governance practices if necessary. The intensity of the assessment is carried out in accordance with the principle of proportionality. Where the manager sees higher risks of non-compliance, they will intensify the audit.

Proportion of investments

The Leap435 Fund will invest fully in line with its investment strategy and investment restrictions. The Leap435 Fund will not invest a portion of its capital in any other asset class.

Monitoring of environmental or social characteristics

For monitoring Leap435 will collect and evaluate ESG data using the 17 UN Sustainable Development Goals (SDGs) as orientation. The impact of the portfolio companies will be measured at least for the following SDGs:

  • 3 Good health and well-being
  • 7 Affordable and clean energy
  • 8 Decent work and economic growth
  • 9 Industry, innovation and infrastructure
  • 10 Sustainable cities and communities
  • 12 Responsible consumption and production
  • 13 Climate action
  • 15 Life on Land

For each investment a qualitative (and where applicable a quantitative) analysis of its impact on these SDGs is conducted and reflected in the investment decision process. For SDG 13 a quantitative indicator of a new technology could e.g. be CO2 reduction; for SDG 10 an appropriate indicator could be the number of kilometers driven per person / or freight product.

The investment team for the Leap435 Fund will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies. The Leap435 Fund will not make any investment in the excluded sectors unless previously approved by the advisory committee.

Methodologies for measuring environmental or social characteristics

Leap435 will strive to use valid quantitative methodologies for measuring social and/or environmental characteristics. Eligible existing methodologies, including SDG Indicators, EU SFDR and CSRD, GIIN IRIS+, and IFRS Sustainability, will be complemented by proprietary qualitative methodologies whenever necessary. Further information on Leap’s methodologies will be included with our yearly sustainability reports.

Data sources and processing

The Leap435 Fund receives data provided by the portfolio companies as part of the due diligence process and at regular intervals after the investment. Where necessary or beneficial, the Leap435 Fund also makes use of publicly available data. Data processing is exclusively internal and DSGVO compliant.

Limitations to methodologies and data

Leap435 is partly reliant on the information provided by portfolio companies during the due diligence process. Moreover, in the post-investment phase, Leap435 is reliant on the company’s reported data. In both cases, complete data may not always be available due to the nature of the investments. The information is verified only if and to the extent misrepresentations are suspected.

Since the Leap435 Fund’s investments are made for a multi-year investment period, Leap435 places a high priority on establishing a trusting working relationship with the portfolio companies to ensure that data is submitted reliably and completely and that the above restrictions are met.

Due Diligence

Leap435 considers the promoted ESG aspects when sourcing new portfolio companies for the Leap435 Fund and during the due diligence on targeted portfolio companies. The due diligence is performed by obtaining all information relevant to the Leap435 Fund using a due diligence questionnaire, which is then reviewed internally. If necessary, further specific information is also obtained from the potential portfolio companies, should this still be necessary after the detailed questioning. The due diligence process is not externally monitored.

Engagement policies

The Leap435 Fund invests in the portfolio companies for a period of several years. Therefore, Leap435 makes it a priority to establish and maintain a trusting working relationship with the portfolio companies in order to continuously comply with the investment restrictions. Leap435 thus also intends to establish or strengthen the consideration of sustainability risks at the portfolio level. Leap435 is in constant dialogue with the portfolio companies, but as a venture capitalist without majority ownership, the influence Leap435 can exert on the portfolio companies is limited.