Portuguese Sustainability Policy

Introduction

This Sustainability Policy (hereinafter referred to as the “Policy”) of Buenavista Equity Partners Portugal, SCR, SA (hereinafter referred to as the “Company”) is intended to comply with the provisions of Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, hereinafter referred to as the “SFDR”).

Through this Policy, the Company will seek to invest taking into account environmental, social, and governance criteria (known by the acronym “ESG,” which stands for Environment, Social, and Governance).

This Policy applies to the Company and the Funds it manages, regardless of the sectors in which they operate.

Sustainability risks

According to Article 2(22) of the SFDR, sustainability risk means an environmental, social, or governance event or condition that may cause a significant negative impact on the value of the investment.

The Company seeks to incorporate these types of risks into its decision-making process, particularly with regard to the funds under its management.

Integration of sustainability risks into the investment decision-making process

Sustainability risks are taken into account during all stages of the investment process for all funds managed by the Company:

Sourcing

During the process of researching new investment opportunities, sustainability risks are considered, in particular the type of sector in which companies operate.

Investment analysis

After the initial analysis, based on external factors, the information is reinforced, in particular with information provided by the target entity, allowing for a more detailed analysis of the existence of this type of risk.

Due diligence

During the due diligence process, carried out by external consultants, this type of risk must be taken into account and, whenever it is identified, mitigation measures must be suggested.

Investment decision

During the decision phase, all risks must be considered and, for any risk detected, the operational and financial impacts must be calculated and the necessary mitigation measures defined.

Portfolio monitoring

Throughout the duration of the investment, and during its regular monitoring, in addition to the usual indicators subject to monitoring, sustainability risk monitoring indicators will also be considered, accompanied by mitigation measures whenever necessary.

ESG monitoring

The Company is part of the Buenavista Group. This independent group, founded in 1996, operates in various geographical areas and has a stable, competent team with proven experience in venture capital and private equity transactions. The Buenavista Group has an ESG-friendly ethos at its core and incorporates these principles into the selection of its portfolios. In this context, the group has been a signatory to the Principles for Responsible Investment (PRI) agreement since 2016.

Consequently, the Company, as an integral part of the Buenavista Group, is also firmly and seriously committed to implementing ESG policies across the board, and has been since it began operating as a venture capital fund manager. This approach will also be extended to the investees of the funds under management.

The action plan under the ESG-friendly Ethos Program includes the following objectives to be implemented over the next two years:

Objectives to be implemented at the company level

Include in the investment strategy all the principles inherent to a responsible investment strategy, fully integrated into the operational procedures implemented at the level of the company’s governance structure and culture.

Define measurable sustainability objectives and targets, to be set out in an action plan approved by the Board of Directors, in accordance with the overall strategic plan defined within the Buenavista Group (hereinafter also “BD”).

Analyze and assess the Company’s contribution in the context of the Sustainable Development Goals (hereinafter “SDGs”).

Participation in training and workshops for the entire Company team.

Inclusion and identification of the SDGs in the investment dossiers to be made available to the Investment Committee and which will subsequently be considered in the investment decision meetings by the BoD.

Objectives to be implemented at the level of all portfolio companies

Support our Subsidiaries in establishing ESG policies and implementing best practices.

Analyze our subsidiaries’ contribution to the SDGs.

Collect and evaluate KPIs on ESG issues for all companies in the portfolio, defined on a case-by-case basis according to the sector and investment phase in which they find themselves.

Include specific clauses on compliance with ESG metrics in all Shareholder Agreements.

Governance

Transparency
Fiscal transparency
Compliance
Whistleblower channels
Avoiding negotiations with high-risk countries
Anti-corruption measures
Business ethics
Independence and segregation of duties
Shareholder rights
Institutional relations
Transparent remuneration practices

Social

Human Capital Management
Privacy and Data Protection
Labor Practices
Diversity and Equality
Human Rights
After-Sales Responsibility
Consumer and Supplier Satisfaction Surveys
Training and Development

Environmental

Recycling
Environmental Impact
Pollution
Biodiversity
Clean Technologies
Sustainable Water Use
Carbon Emissions
Energy Efficiency
Sustainable Resources
Ecological Footprint
Waste Management
Emissions Reduction

ESG reporting is carried out annually at group level, with the definition of goals and challenges for future years.

Failure to consider the negative impacts of investment decisions on sustainability factors

Given that, on the one hand, the Company is not subject to the procedures set out in paragraphs 3 and 4 of Article 4 of the SFDR and, on the other hand, it does not market financial products (within the meaning of Article 2(12) of the SFDR) that promote or aim at sustainable investments, the Company considers the negative impacts of investment decisions on sustainability factors to be limited, namely for the following reasons:

There is little public information available on the markets in which the funds under management operate, particularly with regard to ESG criteria;
Obtaining information by other means would be costly and insufficient, considering the companies in which investments are typically made, seed and early stage;
The companies in which the funds under management invest do not have ESG procedures in place because they are in an early stage of development.

Should there be any changes to the circumstances described above, the Company will inform its Participants and other stakeholders.

Disclosure

This Policy, as well as any subsequent amendments thereto, shall be distributed and disclosed to all employees, investors, and other stakeholders of the Company for whom the Policy is relevant, including through the Company’s website, with the Board of Directors being responsible for clarifying any questions that may arise.

Final Provisions

This Sustainability Policy of the Company was reviewed and approved by the Board of Directors on December 4, 2024.