Sustainability Policy



This Sustainability Policy (hereinafter “Policy”) of GED VENTURES PORTUGAL – Sociedade de Capital de Risco, S.A. (hereinafter “Company”), is intended to comply with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on the disclosure of information related to sustainability in the financial services sector ( Sustainable Finance Disclosure Regulation, hereinafter “SFDR Regulation”).

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

This Policy is applicable to the Company and the Funds managed by it, regardless of the sectors in which they operate.


Sustainability risks


In accordance with article 2, no. 22, of the SFDR Regulation, sustainability risk is understood as an event or condition of an environmental, social or government nature, the occurrence of which may cause a significant negative impact on the value of the investment.

The Company seeks to incorporate this type of risk into its decision-making process, namely with regard to the funds under its management.


Integration of sustainability risks into the investment decision process


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

Sourcing: during the research process for new investment opportunities, sustainability risks are considered, namely the type of sector in which companies operate;

Investment analysis: after the initial analysis, based on external elements, the information is reinforced, namely with elements provided by the target entity, allowing a more detailed analysis of the existence of this type of risks;

Due diligence: during the due diligence process, carried out by external consultants, this type should be taken into account of risks and, whenever they are identified, mitigation measures should 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; It is

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 measures of mitigation where necessary.


ESG monitoring


The Company is part of the GED Group. This independent group, founded in 1996, operates in several countries and has a stable, competent team with proven experience in transactions in the areas of venture capital and privaty equity. The GED Group assumes the ethos ESG-friendly in its genesis and incorporates these principles in the selection of its portfolios. In this context, the group has been a signatory to the Principles of Responsible Investment (PRI) agreement since 2016.

Therefore, the Company, as an integral part of the GED Group, also assumes a firm and serious commitment to the implementation of ESG policies across the board, and from the beginning of its activity within the scope of its performance as a manager of venture capital funds. This form of action will also be extended to the holdings of funds under management.

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


At the Society level:


  1. Include, within the scope of the investment strategy, all the precepts inherent to a responsible investment strategy, fully integrated in the operational procedures implemented in terms of the structure of governance and culture of the company;
  2. Definition of measurable sustainability objectives and targets, to be defined through an action plan approved by the Board of Directors, in accordance with the global strategic plan defined within the GED Group (hereinafter also “CA”);
  3. Analysis and evaluation of Society’s contribution in the context of the Sustainable Development Goals (hereinafter “SDGs”);
  4. Participation in training and workshops for the entire team of the Company; It is
  5. 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 Board’s investment decision meetings.


At the level of all Affiliates:


  1. Support our Affiliates in establishing ESG policies and implementing best practices;
  2. Analyze the contribution of our Affiliates to the SDGs;
  3. 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 the investment stage in which they are; It is
  4. Include specific clauses on compliance with ESG metrics in all Shareholders’ Agreements.

Annually, the Reporting ESG is carried out 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 provided for in numbers 3 and 4 of article 4 of the SFDR Regulation and that, on the other hand, it does not market financial products (in the sense of article 2, no. 12 of the SFDR Regulation) that promote or aim at sustainable investments, the Company considers the negative impacts of investment decisions on sustainability factors to a limited extent, namely for the following reasons:

  1. There is little public information regarding the markets in which the funds under management operate, particularly with regard to ESG criteria;
  2. Obtaining information by other means would be costly and insufficient, taking into account the companies in which investments are typically made, seed and early stage;
  3. The companies in which the funds under management invest do not, from the outset, have ESG procedures because they are in an early stage of development.

If there are changes to the circumstances presented above, the Company will inform its Participants and other stakeholders.




This Policy, as well as its subsequent amendments, will be distributed and disclosed to all employees, also through the Company’s website, with the Board of Directors being responsible for clarifying any doubts that it may raise.


Final dispositions


This Company’s Sustainability Policy was reviewed and approved by the Board of Directors on March 24, 2023.