Sustainability Disclosures

Digital Ocean Ventures Starter Sp. z o.o., acting as the manager of an alternative investment company, and Digital Ocean Ventures Starter Sp. z o.o. Alternatywna Spółka Inwestycyjna S.K.A., are classified, 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 (OJ L 317, 9.12.2019; hereinafter the "SFDR Regulation"), as a financial market participant (Digital Ocean Ventures Starter Sp. z o.o.) and as a financial product (Digital Ocean Ventures Starter Sp. z o.o. Alternatywna Spółka Inwestycyjna S.K.A.), respectively.

In accordance with the SFDR Regulation, Digital Ocean Ventures Starter Sp. z o.o. publishes below the information relating to the conduct of activities concerning sustainable development, in particular information on the strategies adopted in respect of its activities and pertaining to the integration of sustainability risks.

Information on the strategy regarding sustainability risks

Article 3(1) of the SFDR Regulation – Transparency of sustainability risk policies.

The strategy for the integration of sustainability risks into the conduct of business forms part of Digital Ocean Ventures Starter's investment policy. Sustainability factors constitute a material element of the investment assessment. We seek to ensure that the VC Fund's investments have a positive impact on the environment and on society. We acknowledge that, in the case of portfolio companies operating under a B2B or B2B2C model, addressing this area will be unconditionally required in the course of cooperation with prospective customers and corporate partners. The Fund's investment policy is based on international guidelines and good practices regarding ESG, in particular the Principles for Responsible Investment, with due regard for the prevailing EU regulatory requirements (including the CSRD, the SFDR and the EU Taxonomy).

In its investment process, Digital Ocean Ventures analyses prospective investments across the environmental, social and corporate governance dimensions, evaluating their impact on its activities and on the expected return on investment.

ESG due diligence covers, in particular:

• environmental audit – assessment of the impact of the startup's activities on the environment, including waste management and the consumption of energy and natural resources;
• environmental policy and practices – analysis of existing environmental policies, certifications and sustainable‑development practices;
• supply chain analysis – assessment of ethical practices throughout the supply chain, including working conditions and sustainability;
• social policy and community engagement – analysis of policies regarding employees, diversity, social inclusion and contribution to the community;
• governance structure and practices – evaluation of the management structure, composition of governing bodies, ethics policies and risk management procedures;
• transparency and reporting – analysis of the quality and transparency of financial and non‑financial reporting, including ESG reports;
• ESG risk analysis – identification and assessment of ESG risks that may affect the startup's activities and finances;
• compliance and legal risk assessment – review of compliance with applicable legal provisions, any legal disputes and regulatory risk;
• references and opinions – verification of business references, customer feedback and the opinions of business partners.

Integration of ESG factors in the assessment of investment projects

1. Comprehensive ESG assessment. All prospective investments are subject to a thorough assessment of their environmental, social and corporate governance (ESG) practices. This encompasses an evaluation of the sustainability of their business models, the environmental impact of their operations, their social contribution and relations with local communities, and the effectiveness of their governance structures.

2. Application of the PRI Principles. The investment assessment process is guided by the six Principles for Responsible Investment, which means:

   • incorporating ESG matters into the investment analysis in order to better understand the risks and opportunities presented by each investment;
   • acting as active owners and encouraging the application of best ESG practices in our portfolio companies;
   • seeking appropriate disclosure of ESG matters by portfolio companies;
   • promoting acceptance and implementation of the PRI within the investment industry through our practices and partnerships;
   • cooperating with other investors with a view to enhancing our effectiveness in implementing the principles;
   • reporting on our actions and progress in implementing the PRI, thereby demonstrating our commitment to transparency and accountability in ESG matters.

3. Compliance with international ESG standards. In addition to the PRI, the assessment process takes into account other relevant international ESG standards and guidance frameworks applicable to the specific industry or geographic location of the investment (e.g. the SASB Standards, supporting an industry‑specific perspective). This ensures a comprehensive understanding of the sustainability context and aligns our investments with global best practices. In view of the multiple regulatory requirements present along the value chain — affecting both the business partners of the VC Fund and the individual investments — the assessment processes and ESG requirements take into account the prevailing EU regulatory requirements, including CSRD / ESRS, SFDR and the EU Taxonomy (e.g. requirements addressed to suppliers or to entities falling within scope 3).

4. Stakeholder engagement. Recognising the importance of stakeholder perspectives in the assessment of ESG matters, we engage relevant stakeholders, including business partners, customers, communities and employees, as part of our investment assessment and ongoing investment management processes. Such engagement supports our understanding of the social and environmental impact of our prospective investments as a component of the sustainability transition.

5. Continuous monitoring and engagement. Following an investment, we are committed to the continuous monitoring of the ESG performance of our portfolio companies in order to address any emerging issues or opportunities for improvement. Such ongoing oversight ensures that our investments remain aligned with our sustainability objectives and with the expectations of our stakeholders.

Transparency of remuneration policies in connection with the integration of sustainability risks

Digital Ocean Ventures Starter, as an entity carrying on the activity of managing an alternative investment company on the basis of an entry in the Register of Managers of Alternative Investment Companies maintained by the Polish Financial Supervision Authority, in light of the Act on Investment Funds and on the Management of Alternative Investment Funds, and in accordance with the provisions of Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010, is not obliged to maintain, and does not maintain, a remuneration policy.

Transparency in respect of the integration of sustainability risks

In accordance with the SFDR Regulation, Digital Ocean Ventures, prior to the conclusion of an agreement, discloses to each investor information regarding: the manner in which sustainability risks are integrated into the investment decisions taken; the results of the assessment of the likely impacts of sustainability risks on the returns of the financial products; and, where sustainability risks are deemed not to be relevant, a clear and concise explanation of the reasons for considering those risks not to be relevant.

Products promoting environmental or social characteristics, or pursuing sustainable investment objectives

Digital Ocean Ventures promotes sustainable and responsible investment practices and recognises the importance of integrating environmental, social and corporate governance (ESG) matters into the investment decision‑making process for the purpose of building integrated value. Our investment policy expressly incorporates the Principles for Responsible Investment (PRI) and other relevant international ESG standards in order to ensure that our investment activities contribute to a sustainable future.