Article 3, 4 and 5 SFDR

Version dated March 2026

Context and objectives

In accordance with Article 3 of Regulation (EU) 2019/2088 (“Disclosure” or “SFDR”) and Article L. 533-22-1 of the French Monetary and Financial Code (stemming from Article 29 of the Energy-Climate Law), financial market participants publish information on their websites regarding their policies for integrating sustainability risks into their investment decision-making processes. For French players, this includes risks associated with climate change and biodiversity. The objective of this policy is to enhance transparency on how Slate Venture Capital (“SlateVC”) incorporates relevant sustainability risks (ESG risks), significant or potentially significant, into its investment decision-making processes.

The policy is based on the principle of double materiality in accordance with European regulations:

• Financial materiality or simple materiality: Analyses the impact of societal, social and environmental issues on the economic performance of the company or financial product.

• Impact materiality (negative sustainability impacts): Assesses the effect of investments on external sustainability factors, such as environmental and social objectives.

The information contained in this policy applies to the fund currently managed by SlateVC, “SlateVC Climate Fund One”, which is classified as Article 9 SFDR.

Definition of sustainability Risks

A sustainability risk is an environmental, social, or governance event or condition which, if it occurs, could have a material, actual or potential negative impact on the value of the investment.

More specifically, the negative effects of sustainability risks may affect issuers through a variety of mechanisms, including: a decrease in revenues, higher costs, damage to or depreciation of asset value, regulatory risks. For companies, sustainability risk can take different forms. For example, in relation to the environment, companies may face physical risks, transition risks related to climate change, or biodiversity-related risks.

Integration of Sustainability Risks into the investment process

Sustainability Risks are considered at all stages of the Slate Venture Capital investment process.  The Management Company has implemented thorough internal policies ensuring that key ESG factors are incorporated into investment proposals.

Pre-selection

SlateVC Climate Fund One pre-selects companies based on their ability to contribute to its sustainable objective of mitigating climate change by reducing greenhouse gas concentrations.

The Fund also applies sectoral (e.g., tobacco, gambling, weapons, fossil fuel extraction) and ethical exclusions (e.g., human rights violations, forced or child labor). A preliminary review assesses management’s ESG commitment and compliance with the Do No Significant Harm (DNSH) principle.

Due Diligence

The due diligence process includes:

• A systematic external ESG audit covering environmental, social, governance, and stakeholder risks and opportunities, review of ESG controversies, consideration of Principal Adverse Indicators (PAIs), and definition of an ESG action plan.

• An impact analysis assessing alignment with the Fund’s sustainability objective and the SDGs

• Definition of a preliminary impact plan for the portfolio companies, including at least three key impact indicators

• Approval of the investment project by the Fund’s ESG & Impact Committee.

• Integration of ESG clauses in legal documentation, including ESG governance, regular ESG and impact reporting, implementation of an ESG action plan, diversity and inclusion policy, GHG emissions measurement and a decarbonization plan.

Portfolio Monitoring

During the holding period, the Fund ensures compliance with ESG commitments and addresses ESG matters at least once a year at board level. It supports portfolio companies through ESG action plan implementation, access to tools and providers, and sharing best practices.

The team collects and analyzes annual ESG and PAI data, reports annually on ESG & Impact performance, and complies with French and European regulatory requirements.

Exit

At exit, the Fund conducts a review of ESG & Impact performance, identifies lessons learned, and assesses the buyer’s ESG and impact ambitions.

Roles and responsibilities

SlateVC takes ESG very seriously and has established a robust ESG and impact organization. One of the founding partners, Sébastien Léger, oversees ESG management, which is critical for tracking the fund's ESG & impact performance.

There is an internal ESG & Impact Committee playing a central role in ensuring that the Fund delivers on its commitments. It has the following responsibilities:

• Defining the ESG ambition and validating the ESG processes and tools

• Overseeing the ESG topics related to the portfolio companies

• Being part of the investment process with a veto right on the investments. It meets before the Investment Committee.

Likely impact of Sustainability Risks on Fund’s performance

SlateVC is convinced that poor ESG practices or unmanaged sustainability issues can hinder long-term growth and operational resilience. The integration of ESG factors helps identify potential vulnerabilities and supports value creation throughout the holding period.

Consideration of Principal Adverse Impacts (PAIs)

The Fund “SlateVC Climate Fund One” (Article 9) considers the principal adverse impacts (“PAIs”) of investment decisions on sustainability factors, in accordance with Article 7 of Regulation (EU) 2019/2088 (“SFDR”). These impacts relate to environmental, social and employee matters, respect for human rights, anti-corruption and anti-bribery.

The Management Company considers principal adverse impacts (PAIs) on sustainability factors throughout the investment process. PAIs are evaluated during the pre-investment stage, as well as through the annual collection and assessment of ESG metrics. Certain adverse impacts, such as exposure to fossil fuels, controversial weapons or violations of international norms, are addressed via exclusion lists at the screening stage.

Communication and reporting

SlateVC is committed to transparency in integrating sustainability risks into its investment processes and managing principal adverse impacts (PAIs). It provides targeted and meaningful disclosures through the following channels:

• Pre-contractual disclosures (in line with SFDR article 9) to outline how sustainability risks are assessed during due diligence and portfolio management.

• Annual periodic reports (in line with SFDR article 9 periodic reports) including specific disclosures on how sustainable investment objectives are met.

• Annual reports to limited partners (LPs) – first reporting year 2025 - including qualitative insights on ESG & Impact integration, material sustainability risks identified in portfolio companies, and progress toward ESG and impact related milestones.

• Portfolio company engagement: SlateVC works closely with the portfolio companies to track and report on relevant ESG & Impact metrics (e.g., carbon footprint, diversity, or governance practices) where feasible, recognizing the early-stage nature of many investments.

While the asset class may limit the scope of quantitative disclosures, SlateVC ensures that reporting remains proportionate, accurate, and aligned with SFDR requirements. Updates are provided annually or as material developments occur. LPs and stakeholders can request additional details through direct engagement with the ESG team.

Information relating to Regulation (EU) 2020/852 on the “Taxonomy”

The Taxonomy Regulation (EU) 2020/852 aims to establish a framework for classifying environmentally sustainable economic activities, while amending certain disclosure obligations under SFDR. It sets out harmonized criteria to determine whether an economic activity can be considered environmentally sustainable and describes a series of disclosure requirements intended to improve transparency and enable an objective comparison of financial products regarding the proportion of their investments contributing to environmentally sustainable economic activities.

Given the Fund’s focus on early-stage companies, which often operate in sectors not yet covered by the Taxonomy or for which reliable data is not available, the Fund does not commit to any minimum proportion of investments in environmentally sustainable activities within the meaning of the Taxonomy Regulation.

Integration of sustainability risks into remuneration policy

As set out in the firm's Remuneration Policy, employee remuneration takes into account sustainability risks, including environmental, social and governance risks.[SL1] 

Limitations and Methodologies

The methodologies used to assess certain ESG indicators are continually evolving. We rely primarily on data provided by our portfolio companies and external service providers, while actively monitoring data consistency and encouraging ongoing improvements.