Principal Adverse Impact Statement

‍No consideration of sustainability adverse impacts on sustainability factors

‍Pursuant to Article 4 of 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 (Disclosure Regulation or SFDR).

‍Principal Adverse Impacts (PAIs) are any negative effects that investment decisions or advice could have on environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters.

While Acurio Ventures acknowledges the importance of such factors into the investment process and the overall positive impact it could have for all relevant stakeholders, in regards to our firm, we will not comply with the entity-level reporting as detailed by the SFDR.

We are not considering it at this time, as we invest primarily in early-stage companies, mainly within the SaaS sector.

While we do not comply with SFDR PAI reporting yet, we do commit to considering ESG criteria throughout our investment process and we require portfolio companies to report on a few ESG KPIs.

This information related to integration of ESG factors in our investment engagement and decision-making process can be found below.

ESG CRITERIA INTEGRATION POLICY
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1. Purpose of the Policy
‍‍This document describes the policy for the integration of environmental, social and corporate governance criteria, known as ESG criteria (hereinafter, «ESG Criteria«)  ACURIO VENTURES PARTNERS, SGEIC, S.A.  (hereinafter «the Company«), which the Company will take into consideration in the development of its activities as a manager of venture capital entities (entidades de capital riesgo).This policy is developed in compliance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information relating to sustainability in the financial services sector.

‍2. ESG Criteria

When referring to the ESG Criteria, reference is made to the following factors:
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- The environmental factor (E): how companies’ activities affect the environment. It focuses on the environmental impact of companies, as well as on the efforts made by companies to reduce the levels of pollution or carbon emissions. It would cover, for example, issues such as waste management, water management and the use of other natural resources.
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- The social factor (S): takes into account the community impact of the activities carried out by companies, for example in terms of diversity, administration, human rights or healthcare. It also includes for example the links established by companies with the community (corporate citizenship and philanthropic initiatives).

- The governance factor (G): studies the impact of the shareholders themselves and on  entity management, and takes into account issues such as the structure of boards of directors, management compensation and shareholders’ rights, as well as transparency in the relationship between shareholders and the management.‍

‍3. Policy for the Integration of the ESG Criteria
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‍‍3.1 The Company’s Positioning on the Integration of the ESG Criteria
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‍The Company is aware of the importance of the ESG Criteria for the achievement of the Sustainable Development Goals «SDGs» (2015-2030).

Notwithstanding the foregoing, for the time being, the Company has decided not to integrate the ESG Criteria in the investment decision-making processes, as it does not yet have a sufficient level of development and detail to assess the impact of such criteria. Furthermore, based on its current positioning, the Company acknowledges that it does not take into account the adverse impact of investment decisions on the ESG Criteria.

‍3.2 Company’s Commitment to the ESG Criteria
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‍The Company is working on the conceptualization of a general framework related to the ESG Criteria, which applies to issues such as:

- investment and divestment decisions;non-financial reporting to be implemented in current and future portfolio companies;
- non-financial reporting to be provided to investors in the vehicles managed by the Company;
-andthe day-to-day running of the Company.

Throughout 2021, the Company evaluated various external ESG providers and ultimately selected one to lead and assist in the implementation of a comprehensive ESG policy and practices. Additionally, the Company has established a collaboration with a portfolio company that has developed specialized software for managing, monitoring, and reporting all ESG activities. This partnership has enabled the Company to effectively integrate and track ESG criteria across all its operations. Beyond legal obligations, the Company remains fully committed to adopting and maintaining robust ESG practices.
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4. Remuneration Policy and Policies for the Integration of Sustainability Risks

‍The Company’s remuneration policy is not affected by not considering the ESG Criteria when making investment decisions.

‍5. Publication of ESG Policy and Documentation

‍The Company, in compliance with Art. 3 of Regulation (EU) 2019/2088, publishes this policy on its website, with the commitment to gradually incorporate any progress that the Company implements as a result of future regulatory changes, as well as of future developments in line with the aforementioned section 3.

‍6. Applied Regulations

‍- Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of sustainability-related information in the financial services sector.

- Law 11/2018, of 28 December, amending the Code of Commerce (Código de Comercio), the consolidated text of the Capital Companies Act (Ley de Sociedades de Capital) approved by RDL 1/2010, of 2 July, and Law 22/2015, of 20 July, on Auditing of Accounts, regarding non-financial information and diversity.

- Directive 2007/36/EC of the European Parliament and of the Council, of 11 July 2007, on the exercise of certain rights of shareholders of listed companies.

- Sustainable Development Goals (SDGs).- Sustainable Finance Disclosure Regulation (SFDR) Statement. Here