Marvelous Management GmbH (“Marvelous”) is an alternative investment fund manager within the meaning of the German Capital Investment Act (Kapitalanlagegesetzbuch, “KAGB”) and as such publishes the following information in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability disclosure requirements in the financial services sector (“SFDR”).
Article 3 SFDR
Marvelous addresses sustainability risks in its investment decision-making process insofar as relevant. “Sustainability risk” means an environmental, social, or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.
Throughout the due diligence process Marvelous has a multi-step sustainability screening and evaluation methodology in place with the objective to identify actual or potential sustainability risks. If any actual or potential sustainability risks have been identified, Marvelous decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk.
Marvelous regularly reviews its policies to ensure that they address new and emerging risks as well as investors’ concerns.
Article 4 SFDR
Marvelous does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social and employee matters, respect for human rights, anti‑corruption and anti‑bribery matters.
While Marvelous tracks all mandatory and certain additional PAI Indicators (“PAIIs”) outlined in Annex I of the regulatory technical standards (“RTS”) under the SFDR, it has developed its own evaluation process tailored to the specific context of early-stage investments.
At this stage, Marvelous believes this is sufficient to effectively assess potential adverse impacts across the portfolio.
Reporting on PAI in the required form of the RTS would not only increase the administrative burden and costs but also fail to provide more valuable insights.
Marvelous remains open to reporting PAI indicators as outlined in the SFDR in the future, should it become evident that doing so would significantly enhance Marvelous’ ability to identify and mitigate possible adverse impacts of the investments while maintaining operational efficiency and cost-effectiveness.
Article 5 SFDR
As a registered alternative investment fund manager within the meaning of the KAGB, Marvelous does not have and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not considered with respect to the determination of remuneration.
Published: 31st July, 2025
Sustainability-related information about financial products that promote environmental or social characteristics in accordance with Article 9, 10 SFDR for Marvelous Venture Capital Fund GmbH & Co. KG (“Marvelous Venture Capital Fund”) managed by Marvelous Management GmbH an alternative investment fund manager within the meaning of the German Capital Investment Act (Kapitalanlagegesetzbuch).
Summary
Marvelous Venture Capital Fund is a venture capital fund with a focus on deep tech ventures in the sectors agriculture/food/land use, buildings and heavy industry. All investments are sustainable investments with an environmental objective.
Marvelous Venture Capital Fund only invests in a portfolio company if it has the potential to enable a reduction of 10 megatons of greenhouse gas emissions per year by 2040 and can demonstrate the potential to significantly contribute to protecting or restoring another critical planetary boundary. The portfolio company must actively prevent principal adverse impacts to ensure alignment with the “Do No Significant Harm” principle, addressing both planetary boundaries and social or governance aspects.
No reference benchmark has been designated for the purpose of attaining sustainable investment objective.
No Significant Harm
The “Do No Significant Harm” (“DNSH”) assessment is part of any ESG due diligence, any annual review, as well as any exit review. On all these occasions, Marvelous Venture Capital Fund assesses or reviews and explains how likely a Portfolio Company’s core business is to manage Principal Adverse Impacts (“PAI”) sufficiently to ensure DNSH criteria are met.
Marvelous Venture Capital Fund estimates the likelihood for DNSH for the environmental, social, and governance dimensions. For each, Marvelous Venture Capital Fund states a likelihood value between 0–100, with 100 being the best possible value.
Two questions drive DNSH likelihood. First, the materiality of ESG aspects. Second, the management maturity for these aspects. A very low materiality combined with a perfect level of management results in a very high likelihood to DNSH regarding the aspect in question (e.g., biodiversity). A high materiality combined with an insufficient level of management results in a very low DNSH likelihood, and thus a red flag.
Marvelous Venture Capital Fund will use a standardized set of indicators including all obligatory PAI indicators while deliberately providing an optional set of multiple indicators for some dimensions where the impacts of a specific investee company can more meaningfully be expressed if each company can select the indicator most relevant to the business activity of the undertaking.
Marvelous Venture Capital Fund has aligned its investment strategy with the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights, emphasizing respect for key principles outlined in the eight core ILO conventions and the International Human Rights Covenants. Using a risk-based approach, Marvelous Venture Capital Fund assesses and addresses potential adverse impacts related to human rights, labor standards, and corporate governance across the investments.
Investment Objective
Marvelous Venture Capital Fund invests in companies that meet three impact and environmental, social, and governance (“ESG”) criteria:
(together the “Environmental Objective”)
Marvelous Venture Capital Fund works together with scientists to support the development and scaling of technologies geared towards delivering on the Environmental Objective and provides long-term support as transfer partners and investors to facilitate commercialization and reduce time-to-market. To achieve the Environmental Objective in the best possible way Marvelous Venture Capital Fund has prioritized three sectors, namely agriculture, construction and resource intense industries as well as three prioritized solution areas, namely advanced materials, waste cascading and carbon capture and use (CCU).
Strategy
Marvelous Venture Capital Fund intends to seek long-term capital appreciation through equity and quasi-equity investments primarily in European early-stage deep tech ventures in the sectors agriculture/food/land use, buildings and heavy industry (“Portfolio Companies”). All investments have to contribute to the Environmental Objective.
Marvelous Venture Capital Fund will apply annual ESG reviews and engages the Portfolio Company on ESG-related suggestions and establishes an improvement program for the following 12 months. If necessary, a shorter cycle is agreed upon.
Marvelous Venture Capital Fund also applies “catalyst activities”. The catalyst approach supports impact and DNSH compliance through the following activities:
Allocation
Marvelous Venture Capital Fund will make 100% sustainable investments with an environmental objective. There is no minimum share of taxonomy aligned investments. There will be no investments that are not in line with the Environmental Objective.
Monitoring
During the investment period Marvelous Venture Capital Fund reviews the estimates for the likely contribution to climate change mitigation annually. There will be an annual ESG review based on key performance indicators and regular check-ins to agree how to continuously improve ESG performance with the management teams of portfolio companies.
Methodology
Marvelous Venture Capital Fund estimates the likely contribution to climate change mitigation by comparing the Portfolio Company’s solution for decarbonizing an economic activity in one of its focus sectors with an alternative reference solution or practice. The expected mitigation contribution, i.e., the emissions delta, is identified on a per-unit basis and multiplied by the anticipated number of units deployed and substituted.
The number of units deployed depends on the expected reference growth scenario and the substitution rate—how many reference units the Portfolio Company is likely to replace. The substitution rate is influenced by factors such as market adoption, regulatory acceptance, and technical scalability.
To estimate the likelihood of significant contribution to planetary boundaries, Marvelous Venture Capital Fund evaluates three key driver categories:
Data
Marvelous Venture Capital Fund receives data provided by the Portfolio Companies as part of the due diligence process and at regular intervals after the investment. Where necessary or beneficial, Marvelous Venture Capital Fund also makes use of publicly available data.
Where the Portfolio Companies are not in a position to provide accurate primary data, Marvelous Venture Capital Fund will rely on reputable publicly available data sources or make estimations based on team analysis and expert inputs. Regularly used data sets comprise data from IPCC, UNEP, World Bank, WRI, etc. Data estimations will typically comprise less than one third of all data.
Limitations
Marvelous Venture Capital Fund is partly dependent on information provided by Portfolio Companies during the due diligence process. In addition, in the post-investment phase, Marvelous Venture Capital Fund relies on data reported by the Portfolio Company. In both cases, due to the nature of the investments, complete data may not always be available. The information is only verified if and to the extent that misrepresentation is suspected.
Marvelous Venture Capital Fund makes commercially reasonable best efforts to ensure data quality but acknowledges that some assumptions may be based on inaccurate or incomplete data. However, by applying a robust due diligence framework, investment decisions are based on defensible logic and reasoning that is less susceptible to mistakes due to inaccurate data.
Process
Marvelous Venture Capital Fund’s general due diligence process always involves carrying out an ESG due diligence. The ESG due diligence always includes the four dimensions (1) primary contribution, (2) secondary contribution, (3) DNSH along the value chain, and (4) organizational integration.
Marvelous Venture Capital Fund quantifies (1) primary contribution (i.e., climate change mitigation) and provides structured qualitative perspectives on (2) secondary contribution, (3) management of PAI/DNSH, and (4) organizational integration. The latter is often basic in small organizations, but will grow in importance throughout the lifecycle of the investment.
Every ESG due diligence results in a point estimate of the primary contribution, and ESG scores of up to 100% (best possible value) for the other three dimensions. It typically comes with a list of recommended actions (i.e., post-deal actions). Should red flags arise, Marvelous Venture Capital Fund addresses them in a deep dive and clarifies how to solve them prior to investing (i.e., pre-deal actions).
Engagement
Marvelous Venture Capital Fund actively engages with Portfolio Companies in various ways to support their development and address key challenges.
The “catalyst approach” of Marvelous Venture Capital Fund aims to support the Portfolio Companies’ strategic resource allocation to enhance both the impact and financial performance of the Portfolio Companies. It includes a series of activities aimed at directly strengthening impact and increasing the likelihood of compliance with DNSH principles.
Benchmark
No reference benchmark has been designated for the purpose of attaining the sustainable investment objective. The EU Climate Transition Benchmark (CTB) and the EU Paris-Aligned Benchmark (PAB) are designed to assess the performance of investment portfolios in relation to climate objectives. These benchmarks are primarily tailored for established companies with available historical data on greenhouse gas emissions and other environmental metrics.
Investments of Marvelous Venture Capital Fund focus on the potential for future carbon reductions rather than current emissions. The continued effort toward achieving the objectives of the Paris Agreement is ensured by selecting companies with innovative solutions capable of enabling significant greenhouse gas reductions in the long term.
Published: 31st July, 2025
If you have any questions, please do not hesitate to contact us at communications@marvelous-deeptech.com.