Compliance

FOV Ventures Fund I Ky is a limited partnership incorporated and existing under the laws of Finland. FOV Fund Management Oy is appointed to manage the partnership. FOV Fund Management Oy is owned by its founding partners David Haynes and Petri Rajahalme. The company is a registered alternative investment fund manager (AIFM) supervised by the Finnish Financial Supervisory Authority.

We adhere to Invest Europe’s Investor Reporting Guidelines and to the International Private Equity and Venture Capital Valuation Guidelines (IPEV).

FOV Ventures does not currently consider adverse impacts of investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the EU Regulation 2019/2088 on sustainability related disclosures in the financial services sector.

FOV’s adverse impact is likely to be very small or not measurable considering the size, nature and scale of activities and the types of investments made.

FOV also acknowledge the apparent uncertainties relating to the practical content of the obligation set out in the Article 4(1)(a), and consequently, act in accordance with the Article 4(1)(b) of the EU regulation in question, for the time being.

Contact for media
Petri Rajahalme, petri@fov.ventures

ESG

FOV refers jointly to the Partnership, its general partner (FOV Partners GP I Oy) and the management company of the Partnership (FOV Fund Management Oy).

ESG matters are recognised at an early stage in any potential investment opportunity and are addressed and monitored throughout the Partnership’s ownership of an investee company.

FOV believe that thoughtful management of environmental, social, and governance (ESG) matters is part of long-term success in investment activities and business. FOV are committed to investing responsibly by integrating material ESG considerations into FOV’s investment processes.

The board of directors of the Management Company coordinates the responsible investment matters, which are covered at the board’s meetings at least 4 times a year. The board ensures that the implementation of ESG matters is achieved across FOV and the Partnership’s portfolio companies. The board reviews the state, progress and development needs of ESG matters in FOV and the investee companies. The General Partner ensures that the Management Company manages the Partnership’s investment portfolio in compliance with this policy.

Professional standards
FOV follow Invest Europe’s best practices for responsible investment (https://www.investeurope.eu/industry-standards/responsible-investment/). Due consideration is also given to other Invest Europe’s and Finnish Venture Capital Association’s (FVCA) guidelines and recommendations such as the Openness and Transparency Recommendations of FVCA (https://paaomasijoittajat.fi/en/fvca/rules-and-guidelines/).

Ten Principles of United Nations Global Compact
FOV acknowledge and follow the Ten Principles of United Nations Global Compact (https://www.unglobalcompact.org/what-is-gc/mission/principles) and will support the investee companies to integrate the principles into their strategies, policies and procedures.

Human rights
FOV respect human rights and recognizes their importance and universality. In order to meet the responsibility to respect human rights, FOV has appropriate policies and processes in place and will support the investee companies to prepare and execute policies and processes appropriate to their size and circumstances. United Nations Interpretive Guide to the Corporate Responsibility to Respect Human Rights is used as a tool in preparing and executing the policies and processes (https://www.ohchr.org/documents/publications/hr.pub.12.2_en.pdf).

United Nations Sustainable Development Goals
FOV believe that environmental and social matters are inherently present within FOV’s core investment thesis around spatial computing. FOV believe that most investee companies will be aligned with one or more of the United Nations’ Sustainable Development Goals (https://sdgs.un.org/goals)

Diversity and Inclusion
FOV are committed to take diversity and inclusion into account in their own businesses and will work with the investee companies to support them create diverse and inclusive workplaces.

Climate Change
FOV acknowledge internationally accepted targets (The Paris Agreement) to strengthen the global response to the threat of climate change by e.g. pursuing efforts to limit the temperature increase to 1.5 °C above pre-industrial levels as well as the Finnish government’s target of carbon- neutral Finland by 2035. FOV will assess the climate impact of the potential investee companies and the investee companies as part of FOV’s investment and investment management processes.

Tax Planning
FOV will not use and expect that the investee companies do not use aggressive tax planning and will pay their income taxes to the country where the value of the business is created.

Corporate Responsibility Risk Assessment
FOV recognize that corporate responsibility risk assessment is an integral part of their regular risk assessment processes. FOV will also support the investee companies in conducting their corporate responsibility assessments.

UN PRI
FOV acknowledge that some of the Partnership’s limited partners (the Limited Partners) are committed to the Principles for Responsible Investment (PRI) instituted by the United Nations (www.unpri.org) and their objective is to comply with and promote considerations related to ESG matters in investment analyses and decisions as well as in ownership policy.

Exclusions
FOV will not invest in companies in weapons, alcohol, pornography, tobacco, human cloning or gambling industries nor in companies conducting illegal activities or companies, which FOV determine to operate unethically. Additionally, FOV will not invest with founders or investors which FOV determine to have serious reputational issues, e.g. a criminal record.

An analysis of the ESG risks is part of FOV’s due diligence process. An ESG Due Diligence Questionnaire has been drawn up to cover the ESG areas, which FOV believe are key to understanding the ESG profile of a potential investee company.

After an investment, a discussion on ESG matters is a part of FOV’s setup process with the investee company. Each investee company develops its own corporate responsibility policy, while FOV provides support to that process. Reviewing ESG matters is part of the investee companies boards’ work and ESG matters are discussed in the board meetings at least once a year.

FOV expect that the investee companies conduct their activities according to the laws and regulations they are obliged to. FOV believes that good corporate governance is the foundation of effective corporate management and will support the investee companies to establish and further develop good governance policies and processes.

FOV will expect all investee companies to foster a healthy work environment and a culture of inclusiveness, fair treatment and diversity.

FOV will put forth measurable ESG KPI’s with investee companies. These will evolve over time. An ESG questionnaire and survey will be issued to investee companies once a year to measure performance against these KPI’s. FOV will hold talks with any investee company not meeting agreed KPI’s. The goal is to explore reasons for not meeting the KPI’s and find ways to plan the year ahead in order to perform better against the KPI’s.

Management Company and General Partner

The ESG policies and processes are part of FOV’s internal development areas. FOV will keep themselves educated about the latest developments and publications by PRI. FOV’s Responsible Investment Policy will be reviewed annually and updated accordingly. ESG matters are on agenda at the board meetings of the General Partner and the Management Company at least once a year.

FOV will conduct their businesses according to the laws and regulations they are obliged to and follow good governance principles. The Management Company will follow its own environmental load. The personnel of the Management Company will favour meetings online or in virtual reality, supporting the creation of a new modern work culture of its own.

The Management Company has designated a person for FOV’s responsible investment matters.