ACT Venture Partners Coöperatief U.A. (“ACT Venture Partners”) invests in innovative, purpose-driven technology startups. We acknowledge that investment decisions may have environmental and social impacts, and we aim to promote responsible business practices in our portfolio.

Responsible investment is part of our mission to create long-term value for investors and companies. Our approach is guided by recognised practices, including the UN Sustainable Development Goals (SDGs) and Invest Europe ESG guidelines.

1. Scope and Principles

This policy applies to all investment activities conducted by ACT Venture Partners. In practice, we adhere to the following principles:

• Integrate ESG considerations into due diligence and, where relevant, into ongoing portfolio discussions.
• Assess potential sustainability risks as part of our overall risk review during investment decision-making.
• Encourage portfolio companies to adopt basic ESG practices appropriate to their stage of development.

For clarity, KCV Fund qualifies as an Article 6 fund under SFDR. ESG considerations are integrated into the risk management framework, but the Fund does not promote environmental or social characteristics (Article 8) nor does it have sustainable investment as its objective (Article 9).

2. Investment Process

Pre-Investment: ESG Assessment
During due diligence, ACT Venture Partners conducts an ESG assessment to evaluate a company’s ESG practices and risks. The assessment includes inquiries such as:

• UN SDG Contribution: Which SDGs does the company contribute to, and how?
• Policies: Does the company have, or is it willing to adopt, the following policies: ESG/Sustainability Policy, Health and Safety Policy, Insurance/Compensation Policy, HR/Labour Practices Policy, Anti-Discrimination & Diversity/Inclusion Policy, Data Privacy and Security Policy, Anti-Bribery & Corruption Policy, Code of Conduct, etc.
• ESG Oversight: Is there a named person responsible for ESG matters within the company?
• Risk Awareness: Are there any key ESG risks relevant to the business (environmental, social, governance)?
• Standards and Certifications: Are there ESG-relevant standards or certifications (e.g. ISO 14001, ISO 27001, BCorp, EcoVadis, industry-specific) that the company should obtain, given its sector, clients, or regulatory environment?

This assessment is not intended to exclude companies but to ensure that risks are identified, improvements are encouraged, and opportunities for positive impact are recognised.ACT Venture Partners monitors its portfolio companies' compliance with international standards and encourages them to adopt a long-term vision that addresses sustainability challenges.

Post-Investment: ESG Initiatives for Portfolio Companies
After investment, ACT Venture Partners encourages portfolio companies to:

• Implement or strengthen ESG-related policies.
• Address material ESG risks identified during due diligence.
• Consider relevant certifications or standards where useful for clients or regulators.
• Integrate ESG topics into board-level discussions when appropriate.

3. Monitoring and Review
ESG practices are monitored primarily through ongoing dialogue and board involvement.

This Policy is reviewed periodically and updated as practices and expectations evolve.

ACT Venture Partners is committed to transparency with investors regarding the integration of ESG into its investment process.