SFDR POLICY

FMV First Momentum Ventures Management GmbH (“First Momentum”), LEI: 391200NFOQ6U1LCIW121 is an alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB“) and the EuVECA-Regulation 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”).

First Momentum 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. During the due diligence on potential investments, First Momentum conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, First Momentum 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. First Momentum regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.

First Momentum does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters. First Momentum does not use sustainability indicators. The standardized catalog of PAI indicators (“PAII”) provided by Annex I of the regulatory technical standards issued under the SFDR is not tailored to the specific needs of the early-stage investment strategy pursued by First Momentum.In many instances, data will be insufficient for analyzing PAI, and on occasions where data is obtainable, it tends to offer limited comparability and provides only minimal additional insights for First Momentum. Therefore, collecting data on PAII will not only increase the administrative burden and costs but also fail to provide a new perspective for First Momentum.

As a registered alternative investment fund manager within the meaning of the KAGB and the EuVECA-Regulation, First Momentum does not have, nor is required 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.

‍Updated 01.03.2026 to reflect recent updates in the ESG Policy.

Download the sustainability-related disclosures for Fund II here and for Fund III here.