SFDR Article 9

SFDR (Sustainability Related Disclosure Regulation)

As required by the Sustainable Finance Disclosure Regulation EU 2019/2088 (SFDR), Shamrock Ventures Management B.V. provides insight about the policies and procedures considered during our investment decisions. Next to sustainability-related risks and adverse sustainability impacts, an overview is provided of the impact strategy that we adhere to.

  1. Early-stage Impact Fund

Shamrock Ventures looks for outstanding founders with an impact-driven mission, that are able to carry out their vision with an innovative and scalable tech solution. We strongly believe that some of the environmental and societal challenges that we face today can be tackled by innovative and commercially viable solutions.

Shamrock Ventures aims to invest in early-stage businesses, consisting of mainly pre-seed and some seed investments. With this investment philosophy, we try to fill a certain funding gap in the Dutch VC landscape, where a significant amount of startups struggle to raise capital in such early stages. We try to look beyond the inevitable risks, and invest when we believe the founders have the potential to make an impact. The impact that we look for consists mainly out of sustainability-related impact, and could thus exist of startups relating CO2 reduction, biodiversity enhancement, reduction of consumption and others.

This impact-driven vision results in Shamrock investing in four main impact-driven investment areas:

  • Circular Economy
  • Sustainable Mobility
  • CleanTech
  • Agri/FoodTech

Each of these investment areas fit within our investment philosophy, and will help us build an impactful portfolio of companies to build towards a more sustainable planet.

We apply a broader Environmental, Social and Governance (ESG) framework to assess the true impact that our investment can make. Our ESG policy sets out our values, how we implement those values through our investment process and how we manage ESG risks on a structural basis. All the startups in which we invest are required to have an inherent positive impact on the environment or society, and this is combined with a structured ESG risk management system to ensure no significant harm is done against other ESG characteristics. Naturally, considering our tech-related focus of our funds, we try and focus on ESG factors that are relevant for software, digital technology or IT companies.

  1. Sustainability risk policies and procedures (SFDR Article 3)

Our sustainability risk policies and procedures are available upon request. Please e-mail Tommy Hurley at tommy@shamrockventures.nl

  1. Adverse Sustainability impacts (SFDR Article 4)

In line with SFDR Article 4, we do not consider the Principal Adverse Impacts at the Fund Manager level. Considering that our portfolio companies are not required to publish this data, we cannot guarantee accurate and complete reporting to fulfil the requirements. If this data is available, we will monitor the complete series of PAIs. On a fund level, we do monitor and evaluate a range of possible adverse sustainability impacts of potential portfolio companies relating to climate and other environment related indicators. Furthermore, we monitor other factors such as indicators for society and employees, respect for human rights, anti-corruption and anti-bribery matters, as displayed by the EU as part of the SFDR.

  1. Remuneration (SFDR Article 5)

Shamrock Ventures’ remuneration policy seeks to reward and incentivize team members fairly. This encourages behavior to contribute to our mission of supporting outstanding tech entrepreneurs with an impact-driven mission.

The Shamrock Ventures funds are entitled to up to 30% carried interest, over the preferred return hurdle rate.

  1. Sustainable investment objectives of our funds (SFDR Article 10)

We aim to support entrepreneurs with a vision to make environmental impact with our knowledge, experience, network and funding. As such,  Shamrock is able to serve as a catalyst in its objective to building a better, sustainable world. Both Shamrock Funds are subject to disclosure under SFDR regulation.

Sustainable Investment Objectives

Our investment objective is to invest in solutions that align with SDG’s 7, 9, 11, 12, 13 and 15. All of these SDGs align with Shamrock Ventures’ vision to create a sustainable planet.

To reach these goal, Shamrock Ventures adheres to an impact-led strategy. We target pre-seed or seed opportunities with a clear positive impact in their value proposition. Impact assessment is incorporated throughout our investment processes and impact is deeply embedded and maximized in our portfolio

  1. Qualification financial product

Based on the above explanations and disclosures, Shamrock believes that it qualifies as Article 9 compliant products.