SFDR

Disclosures pursuant to Regulation (EU) 2019/2088 (SFDR) and Regulation (EU) 2020/852 (EU Taxonomy Regulation)

Summary

APEX Ventures GmbH (“APEX“) is committed to transparency regarding sustainability matters in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (“SFDR”) and Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment (“EU Taxonomy Regulation”).

The financial products managed by APEX do not have sustainable investment as their objective, nor do they promote environmental or social characteristics within the meaning of Articles 8 or 9 SFDR. Accordingly, APEX’s funds are classified as Article 6 products under SFDR.

The investments underlying these financial products do not take into account the EU criteria for environmentally sustainable economic activities within the meaning of the EU Taxonomy Regulation.

Integration of Sustainability Risks (Article 3 SFDR)

APEX considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of an investment.

APEX considers sustainability risks as part of the due diligence process prior to any investment. This includes an assessment of sustainability risks using a questionnaire. The results of such assessment are taken into account when the investment decision is made. APEX remains free in its decision to refrain from investing or to invest despite identified sustainability risks. Where APEX decides to invest notwithstanding sustainability risks, it may apply measures to reduce or mitigate such risks.

At all times, APEX applies the principle of proportionality, taking due account of the strategic relevance of an investment as well as its transactional context.

Principal Adverse Sustainability Impacts Statement (Article 4 SFDR)

APEX considers principal adverse impacts of its investment decisions on sustainability factors before and after investments. Sustainability factors mean environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery.

Description of Principal Adverse Sustainability Impacts

APEX has not identified any material adverse sustainability impacts related to its investments to date. No sustainability indicators within the meaning of the SFDR Delegated Regulation are currently used.

Policies to Identify and Prioritise Principal Adverse Sustainability Impacts

Prior to any investment, APEX conducts due diligence which includes checking whether the investment could have a negative impact on sustainability factors. This check is performed using a checklist, and the necessary information is obtained from the respective portfolio company.
After an investment, during the holding period, a check is carried out at regular intervals to determine whether there have been or could be any adverse effects on sustainability factors. This review is carried out annually based on a checklist. In addition, portfolio companies are expected to notify APEX in writing on an ad hoc basis if any adverse effects on sustainability factors become apparent.
If adverse effects on sustainability factors are identified before or after an investment, they are taken into account in light of the circumstances of the individual case, in particular considering other impacts of the investment, its size, strategic importance and transactional context.

Engagement Policies

APEX decides at its sole discretion whether or not to make an investment in light of principal adverse impacts on sustainability factors, and may apply risk mitigation measures where appropriate. APEX organizes an onboarding session for each portfolio company it invests in. During such sessions, APEX discusses with and explains to the management of those portfolio companies how they can incorporate and implement consideration of adverse impacts into their daily operations.

References to International Standards

APEX is not a member of any international bodies or organizations, nor is it required by any national or international convention or standard to comply with any further requirements beyond those set out in applicable EU and national law.

Remuneration Policy (Article 5 SFDR)

APEX’s remuneration policy is consistent with the integration of sustainability risks. The assessment of employee performance does not incentivize excessive risk-taking with respect to sustainability risks, and sustainability considerations are taken into account in the overall performance assessment where relevant.

Voluntary Exclusion Policy

While APEX’s funds are classified as Article 6 products under SFDR and do not promote environmental or social characteristics within the meaning of Article 8 SFDR, APEX has voluntarily adopted an exclusion policy as part of its internal investment guidelines.

APEX does not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities whose business activity consists of:

the production of, and trade in, tobacco, vaping products, e-cigarettes and related products;
the financing and 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;
casinos and equivalent enterprises; and
pornography.

This exclusion policy is applied on a voluntary basis and does not constitute a commitment to promote environmental or social characteristics within the meaning of Article 8 SFDR.

Fund-Specific Information (Article 6 SFDR)

The following funds managed by APEX are classified as Article 6 products under SFDR. For each fund, sustainability risks are integrated into investment decisions as described above. The likely impact of sustainability risks on the returns of these funds depends on the materialization of such risks in respect of individual portfolio companies. Given the early-stage nature of the investments and the sectors in which the funds invest, sustainability risks are generally considered to have a low to moderate potential impact on returns, although this assessment may vary depending on the specific circumstances of each investment.

Amadeus APEX Technology EuVECA GmbH & Co. KG

This fund focuses on investing in portfolio undertakings in the following technology sectors: (i) artificial intelligence and machine learning, (ii) quantum technologies / photonics, (iii) mobility & space innovation, (iv) autonomous systems and robotics and (v) other emerging DeepTech areas (e.g. novel materials). The fund makes initial investments in the course of Seed and Series A financing rounds as well as selectively in early pre-seed financing rounds (proof-of-concept tickets).

APEX Ventures EuVECA GmbH & Co. KG

This fund’s investment strategy is targeted at early stage investments in DeepTech companies.

APEX Digital Health EuVECA GmbH & Co. KG

This fund’s investment strategy is targeted at early stage investments in medical tech companies.

APEX One Best in Class EuVECA GmbH & Co. KG

This fund’s investment strategy is targeted at follow-on investments in selected portfolio companies of APEX Ventures EuVECA GmbH & Co. KG.

Legal Notice

This disclosure is provided in accordance with Articles 3, 4, 5 and 6 of Regulation (EU) 2019/2088 (SFDR) and Article 7 of Regulation (EU) 2020/852 (EU Taxonomy Regulation). It does not constitute investment advice or an offer to invest in any financial product. The information provided herein is subject to change and will be updated as required by applicable law.

Last updated: November 2025