Article 9 Website Disclosure
Entity Level
To support our investors in making informed decisions on sustainable investment, Soulmates Ventures a.s. (Soulmates Ventures), the founder of the Soulmates Ventures Fund SICAV, a.s. (the “Fund”), has published entity-level sustainable finance disclosure as per the Sustainable Finance Disclosure Regulation (SFDR, Regulation 2019/2088) requirements.
Integration of principle adverse impacts (PAI)
The Fund integrates Principal Adverse Impacts (“PAIs”) into its ongoing portfolio monitoring and stewardship activities. These activities are carried out on behalf of the Fund by Soulmates Ventures, acting as a delegated sustainability adviser. PAIs represent the most significant negative impacts of investment decisions on environmental, social, and governance factors and form a core component of the Fund’s sustainability risk management.
Therefore, all portfolio companies are required to report annually on the mandatory PAI indicators listed in Table 1 of Annex I of the SFDR RTS, together with two additional indicators relevant to the Fund’s sustainability objectives: (i) the absence of carbon-emission reduction initiatives and (ii) exposure to companies active in the cultivation of tobacco. This reporting forms the baseline for the systematic identification, assessment, and monitoring of adverse impacts over time and is collected through a selected software solution.
While PAIs are not applied as automatic exclusion criteria, they form an integral part of the Fund’s active ownership approach by guiding dialogues with founders and shaping sustainability action plans. PAI insights and outcomes are summarised Fund’s annual Sustainability Report and SFDR disclosures, ensuring transparency and accountability to stakeholders.
Integration of sustainability risks
Sustainability risks are integrated into the Fund’s investment decision-making process.
These activities are implemented on the Fund’s behalf by Soulmates Ventures. Sustainability risks refer to environmental, social, or governance events or conditions that, if they occur, could materially affect the value or performance of an investment.
As part of its standard procedure, the Fund conducts a structured sustainability due diligence prior to investing, including assessments based on recognised frameworks such as the OECD Due Diligence Guidance for Responsible Business Conduct (OECD RBC Guidance), the UN Principles for Responsible Investment (UN PRI), and tools for evaluating sustainability risks. The results of these assessments inform investment decisions. Where material sustainability risks are identified, the Fund may proceed with an investment only where appropriate mitigation measures or engagement actions are established.
Following investment, sustainability risks are monitored on an ongoing basis through annual sustainability reviews, risk reporting, and active engagement with portfolio companies to ensure that risks are managed effectively and that sustainability objectives are supported.
Remuneration policy
Article 5 of the Sustainable Finance Disclosure Regulation (SFDR, Regulation 2019/2088) requires financial market participants, including alternative investment funds managers, to disclose how their remuneration policies are consistent with the integration of sustainability risks. Soulmates Ventures currently does not incorporate sustainability performance into its remuneration policy. However, sustainability risk considerations are integrated into investment decision-making processes and governance practices.
Fund Level
Summary
Soulmates Ventures Fund SICAV, a.s. (the “Fund”) is classified as an Article 9 financial product under the Sustainable Finance Disclosure Regulation (SFDR), as it has sustainable investment as its objective. The Fund invests in early-stage companies whose core activities generate positive and measurable environmental and/or social outcomes while supporting long-term sustainable value creation.
The Fund’s sustainable investment objective is pursued through investments in innovative startups developing scalable solutions across eight sustainability streams: Air, Water, Energy, Food & Agriculture, Circular Economy, Mobility, Healthcare, and Education. Each investment is required to contribute to at least one clearly defined environmental or social objective, such as climate change mitigation or adaptation, resource efficiency, pollution reduction, sustainable use of natural resources, access to essential services, or improved social outcomes.
The Fund ensures that its investments do not cause significant harm to environmental or social objectives by applying a comprehensive monitoring and engagement framework. Portfolio companies report annually on Principal Adverse Impact (PAI) indicators in line with the SFDR Regulatory Technical Standards, complemented by additional indicators relevant to the Fund’s sustainability objectives. Sustainability risks, governance practices, and value creation KPIs linked to the UN Sustainable Development Goals (SDGs) are monitored on an ongoing basis, supporting compliance with the Do No Significant Harm (DNSH) principle.
The investment strategy focuses primarily on Seed and Series A startups with scalable, purpose-driven business models. Sustainability considerations are embedded throughout the investment lifecycle, from screening and due diligence to post-investment monitoring and active ownership. Investee companies formalise their commitments through a Sustainability Term Sheet and are supported through hands-on engagement and tailored acceleration programmes.
The Fund aims to allocate at least 75% of its capital to sustainable investments, targeting 45% with an environmental objective and 30% with a social objective. The remaining portion may be invested in governance-enabling solutions or held as ancillary liquidity, subject to minimum ESG safeguards.
Progress toward the sustainable investment objective is monitored through structured reporting, ESG assessments, and value creation measurement using recognised methodologies, including IRIS+, Invest Europe guidance, ESG_VC, and sustainability risk tools adapted to early-stage companies. Results are consolidated in the Fund’s annual Sustainability Report and SFDR disclosures.
No Significant Harm to the Sustainable Investment Objective
The Fund ensures that its investment activities do not cause significant harm to the sustainable investment objective. To assess this, the Fund applies a comprehensive due diligence and monitoring framework, evaluating Principal Adverse Impact (PAIs) indicators, sustainability risks, and governance practices of startups.
To ensure continuous compliance with the Do No Significant Harm (DNSH) principle, the Fund implements a structured monitoring framework. During the reporting phase, the Fund assesses PAI indicators as outlined in Annex I of the SFDR Regulatory Technical Standards, including all 14 mandatory indicators and several additional indicators relevant to the Fund’s sustainability objectives. The Fund also collects value creation KPIs measured using the IRIS+ framework and linked to the SDGs, together with updates regarding sustainability risks and company developments, as well as conducting a full ESG assessment, ensuring ongoing alignment with its sustainability objectives.
This monitoring approach is informed by internationally recognised responsible business conduct standards, including the OECD Due Diligence Guidance for Responsible Business Conduct (OECD RBC Guidance), UN Guiding Principles on Business and Human Rights (UNGP), and the UN-supported Principles for Responsible Investment (UN PRI). This alignment ensures that the assessment of PAI indicators, sustainability risks, and governance practices is conducted in line with recognised international expectations for responsible investment and business conduct.
Sustainable Investment Objective of the Financial Product
The Fund’s sustainable investment objective is to invest in purpose-driven startups whose core economic activities generate positive and measurable environmental and/or social outcomes, while contributing to the transition towards a more sustainable and resilient economy. The Fund supports business models in which sustainability considerations are integral to value creation and long-term growth.
To achieve this objective, the Fund invests in innovative startups that develop and scale solutions addressing defined sustainability challenges. The investment focus is structured around eight sustainability streams: Air, Water, Energy, Food & Agriculture, Circular Economy, Mobility, Healthcare, and Education, which represent priority streams where technological innovation and scalable business models can deliver tangible environmental or social benefits.
Each investment must demonstrate a clear contribution to at least one environmental or social objective, such as climate change mitigation or adaptation, improved resource efficiency, pollution reduction, sustainable use of natural resources, access to essential goods and services, or improved social outcomes for end-users and communities. The Fund does not pursue all sustainability objectives simultaneously in each investment; rather, it targets specific, identifiable outcomes aligned with the startup’s core activities.
Investment Strategy
The Fund invests in purpose-driven startups that generate measurable environmental and social impact while achieving long-term, sustainable growth. Targeting primarily early-stage companies at the Seed and Series A stages, the Fund focuses on scalable business models aligned with its eight sustainability streams: Air, Water, Energy, Mobility, Education, Healthcare, Food & Agriculture, and the Circular Economy.
The investment strategy prioritises innovative startups that contribute to climate change mitigation, resource efficiency, pollution reduction, and social well-being, ensuring compliance with Article 9 of the SFDR. From the outset, the Fund assesses these startups for their potential to create significant value and positive impact in at least one sustainability focus area.
To systematically measure impact, the Fund integrates leading impact assessment methodologies, leveraging tools such as the IRIS+ framework and Invest Europe reporting forms, and aligning with the SDGs. This approach is complemented by thorough due diligence, ensuring that selected startups demonstrate both financial potential and a strong commitment to sustainability.
These startups formalise their commitment through a Sustainability Term Sheet (TS), agreeing to regular sustainability reporting and the implementation of key sustainability policies. Post-investment, the Fund maintains active engagement through a hybrid model combining venture capital and an innovation accelerator, offering strategic support, tailored acceleration programmes, and hands-on guidance for scaling and international expansion. Financial incentives are linked to participation in these tailored programmes.
The Fund embeds good governance practices throughout its investment lifecycle, adhering to well-established standards like OECD RBC Guidance and UNGP. Governance assessments cover management structures, operational transparency, employee relations, anti-corruption measures, shareholder rights protection, and leadership diversity. Tools used include structured questionnaires, documentation reviews, and direct engagement with founders and leadership teams. Additional factors, such as the presence of independent board members, internal controls, and governance policies, are also considered to ensure high standards of responsible business conduct.
Proportion of Investments
The Fund is committed to allocating at least 75% of its capital to sustainable investments. Of this allocation, 45% is targeted toward investments with an environmental objective, and 30% toward investments with a social objective. This breakdown directly reflects the Fund’s eight sustainability investment streams. The remaining up to 25% of the Fund’s capital may be invested in startups focused on enabling governance or held as ancillary liquidity. Even these investments are screened for minimum ESG safeguards and expected to contribute indirectly to the Fund’s sustainable investment objective.
However, it is important to note that the venture capital landscape is inherently dynamic. While the target allocation remains at least 75%, actual yearly deployment may vary based on the nature and availability of startups in the pipeline. In some years, the Fund may emphasise social streams falling under the Healthcare and Education streams, while in others it may focus on environmental innovation in energy systems or good governance tools like cybersecurity and responsible finance platforms.
Many investment streams are inherently interconnected. For example, improvements in air quality can contribute to both environmental and social goals related to public health. For this reason, the target allocation should be viewed as a guiding benchmark for the Fund’s lifecycle, with flexibility maintained to respond to evolving sustainability opportunities while ensuring overall alignment with the Fund’s sustainable investment objective.
Monitoring of the Sustainable Investment Objective
To ensure alignment with its sustainable investment objective, the Fund implements a structured monitoring and reporting process. Portfolio companies are required to submit yearly updates on operational progress and sustainability risks. In addition, they report annually on PAI indicators (that are monitored in accordance with SFDR requirements) and value creation KPIs, and complete ESG and sustainability risks assessments.
The Fund uses a dedicated software platform to streamline Article 9-aligned data collection and analysis. This ensures the reporting process is smooth and manageable for both startups and the Fund’s internal team. Data is collected primarily via the sustainability data platform used, supported by the Google Workspace ecosystem and complemented with external specialised tools for portfolio and dealflow management.
Furthermore, the Fund benefits from its partnership with the International Sustainable Finance Centre (ISFC), which provides external expertise and technical support to ensure alignment with SFDR Article 9 requirements and to maintain best practices in sustainability integration and regulatory compliance.
Annual ESG assessments and value creation reviews are conducted and summarised in the Fund’s Sustainability Report, which serves as the primary medium for communicating progress to stakeholders. This report highlights not only performance metrics but also key sustainability achievements and strategic adjustments across the portfolio.
Methodologies
The Fund applies a suite of globally recognised methodologies to measure and evaluate sustainability performance in alignment with SFDR Article 9 requirements. These include the IRIS+ framework for defining value creation KPIs and aligning the impact with SDGs, Invest Europe guidelines for assessing ESG maturity, and LogicManager for evaluating sustainability risks.
Together, these methodologies support the consistent identification, classification, and monitoring of sustainability performance across screening, due diligence, and post-investment stages, allowing the Fund to measure and evidence progress towards the attainment of its sustainable investment objective. All methodologies are adapted to the practical realities of early-stage startups to ensure robust, feasible, and credible sustainability measurement.
Where existing standards leave ambiguity or do not fully capture the nuances of early-stage innovation, the Fund applies a proprietary methodology to ensure consistent, transparent, and decision-relevant assessments.
Data Sources and Processing
Data are primarily collected directly from startups through founder surveys, digital questionnaires, and structured interviews. These sources provide the metrics needed to assess the sustainable investment objectives of the Fund, including environmental impact, social outcomes, and governance practices. Startups input their information via platforms such as Atlas Metrics and Affinity, supported by internal tools including Google Drive, Dropbox, and Notion.
The Sustainability & Innovation Manager and Governance Director oversee the data collection process, ensuring consistency, accuracy, and compliance with SFDR reporting requirements. Measures to ensure data quality include standardised templates, internal reviews, cross-checks, and verification in collaboration with external partners such as ISFC, who provide consultancy to ensure alignment with the latest regulatory standards.
Once collected, data are processed by consolidating responses, validating entries against internal and external benchmarks, and converting raw data into standardised KPIs linked to the Fund’s sustainability investment objective. Analytical tools are used where necessary to calculate derived metrics, for example, emissions footprint calculators to approximate environmental impact.
The Fund prioritises the collection of primary data and seeks to minimise the use of estimated values. However, given the early-stage profile of the startups, certain data may be unavailable, in which case estimates are applied only where necessary, focused on material indicators relevant to the sustainable investment objective, and clearly flagged and documented to maintain transparency.
Limitations to Methodologies and Data
While the Fund employs robust methodologies to monitor its sustainable investment objective, certain limitations exist due to the early-stage nature of its portfolio. Data availability and completeness can vary depending on a startup’s maturity, reporting capacity, and operational focus. Methodological constraints include reliance on self-reported data, the use of estimates where measurements are not yet available, and the evolving nature of startup business models, which may require adjustments to monitored indicators and KPIs.
Despite these limitations, the attainment of the Fund’s sustainable investment objectives is not materially affected. The Fund actively supports portfolio companies in developing reporting capabilities, aligning with regulatory frameworks and providing guidance on ESG and value creation measurement. Methodologies are complemented by scientific approaches, best-available evidence, third-party validation, and continuous engagement with founders to ensure consistency and accuracy. Even when indicators and KPIs are adjusted due to business pivots, the Fund maintains oversight to ensure that the sustainability objectives of its portfolio companies, and the Fund’s overall sustainable investment objective, are tracked and achieved throughout the lifecycle of each investment.
Due Diligence
Throughout the investment process, the Fund applies a rigorous limited due diligence framework that includes negative screening to exclude sectors and activities that contradict its sustainability investment objective, complete ESG analysis including sustainability risk management consisting of consideration of relevant, the definition of value creation KPIs, and governance assessments. Startups are required to sign a Sustainability Term Sheet (TS), committing to regular sustainability reporting and the implementation of key sustainability-related policies.
During the due diligence phase, each potential startup is screened for compliance with applicable laws and regulations, as well as for ethical business behaviour.
Once invested, the Fund continues to monitor sustainability practices through regular sustainability & ESG reviews and questionnaires, founder meetings, and sustainability reporting updates. These reviews help ensure that companies remain aligned with expected governance standards and allow the Fund to identify any potential sustainability risks or areas for improvement. The Fund evaluates good governance across several key areas, including sound management structures, transparent operations, employee relations, anti-corruption policies, and the protection of shareholder rights. Where sustainability gaps are identified, the Fund actively engages with the company to support remediation and capacity-building.
Engagement Policies
Engagement with portfolio companies is continuous and hands-on, beginning at initial investment assessment and continuing through post-investment portfolio management. A tailored guidance throughout the limited sustainability Due Diligence process and reporting is provided to each startup, facilitated by the Sustainability & Innovation Manager. Additionally, Soulmates Ventures also offers a specific Sustainability Acceleration Programme for interested startups to accelerate their sustainability development. Our support includes strengthening governance structures, developing ESG strategies, and enhancing impact reporting. This is delivered through regular ESG check-ins, board-level discussions, and targeted capacity-building.
Startups participate in yearly reviews to report on PAIs, value creation KPIs and risk management. Where adverse impacts or critical sustainability risks are identified, the Fund follows a defined management procedure: issues are assessed, addressed through engagement with the company, escalated to the investment committee if necessary, and monitored until resolved. Furthermore, startups preparing for exits, new funding rounds, or business opportunities receive guidance in documenting and communicating their sustainability performance, ensuring they have robust, non-financial data ready for prospective partners.
Attainment of the Sustainable Investment Objective
The Fund has not designated a reference benchmark; instead, it relies on internal methodologies and external frameworks and standards, as mentioned in the sections above, to attain the sustainable investment objective.
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Disclaimer: This document was published in 2025 and last updated in February 2026. It is provided for informational purposes only and does not constitute investment advice, an offer, or a solicitation to subscribe to any financial product. The Fund invests in early-stage start-ups and seeks to achieve its sustainable investment objectives in accordance with SFDR Article 9. However, investments in start-ups are inherently illiquid, involve a high degree of risk, and past performance is not indicative of future results. The Fund’s methodologies, engagement processes, and data collection practices may evolve over time, and this disclosure may be updated to reflect such changes. Investors should review the relevant documents and consult professional advisers before making any investment decision.