SFDR

Disclosures pursuant to Regulation (EU) 2019/2088

Masawa Management GmbH is an alternative investment fund manager registered under the German Capital Investment Code (KAGB), publishing the following information in accordance with the Sustainable Finance Disclosure Regulation (SFDR). This disclosure has been prepared in accordance with the SFDR, Commission Delegated Regulation (EU) 2022/1288, and guidance from the European Supervisory Authorities (ESAs) and the German Federal Financial Supervisory Authority (BaFin). The information provided may need to be adjusted in light of future regulatory guidance or interpretation.

Art. 3 SFDR — Integration of Sustainability Risks

Masawa Management GmbH integrates sustainability risks into its investment decision-making process. When a sustainability risk is identified during due diligence, the management company evaluates whether to proceed with the investment and, if so, what mitigation measures should be implemented. Sustainability risk policies are reviewed on a regular basis to ensure they remain appropriate and effective.

Art. 4 SFDR — Consideration of Principal Adverse Impacts

Masawa Management GmbH is committed to considering principal adverse impacts (PAI) of its investment decisions on sustainability factors. The Masawa Impact Fund I evaluates the potential negative effects of its investments on environmental, social, and governance sustainability factors. Annual reports on principal adverse impacts are made available on this website.

Art. 5 SFDR — Remuneration Disclosure

As a registered alternative investment fund manager (AIFM) under KAGB, Masawa Management GmbH is not required to maintain a formal remuneration policy. Sustainability risks are not currently considered in connection with remuneration.

Status: November 2024

Sustainability-Related Disclosures (Art. 9 SFDR)

For Masawa Impact Fund I GmbH & Co. KG

Summary

Masawa Impact Fund I is a venture capital fund focused exclusively on mental health and wellness.
At least 90% of the fund's investments qualify as sustainable investments with a social objective.
The fund targets enterprises advancing mental health and wellness outcomes.
A custom metrics framework is used, with Impact KPIs approved by the Impact Advisory Committee.
Example metrics include: PHQ-9/GAD-7 score reduction, user-reported wellbeing improvements, and reduction in problematic app or device usage.

Zusammenfassung

Masawa Impact Fund I ist ein Risikokapitalfonds mit Schwerpunkt auf psychischer Gesundheit und Wohlbefinden.
Mindestens 90% der Investitionen des Fonds sind nachhaltige Investitionen mit sozialer Zielsetzung.
Es wird ein maßgeschneiderter Bewertungsrahmen mit vom Impact Advisory Committee genehmigten Wirkungsindikatoren (Impact KPIs) verwendet.

No Significant Harm to Sustainable Investment Objective

Principal adverse impact indicators are assessed for each investment, with a focus on the characteristics of mental health software companies across ESG criteria:

Environmental: Energy consumption and carbon footprint related to data center operations.
Social: Data privacy and security, user wellbeing, and responsible product design.
Governance: Corporate governance practices and mitigation of algorithm bias.

Alignment with International Principles

Investments are assessed for alignment with established international standards and frameworks, including:

OECD Guidelines for Multinational Enterprises
UN Guiding Principles on Business and Human Rights
ILO Declaration on Fundamental Principles and Rights at Work
International Bill of Human Rights

Sustainable Investment Objective

The fund's sustainable investment objective is to support impact-driven enterprises that advance mental health and wellness. Specific impact goals are defined for each portfolio company, with clear timelines for achievement.

Investment Strategy

The fund pursues long-term capital appreciation through equity and quasi-equity investments in early-stage companies operating in the mental health and wellness sector. Investments undergo rigorous due diligence, continuous monitoring, and assessment of good governance practices.

Proportion of Investments

At least 90% of the fund's investments are sustainable investments with a social objective. A maximum of 10% of the fund's investments may not qualify as sustainable investments; these may include cash holdings or other instruments held for liquidity or operational purposes.

Monitoring of Sustainable Investment Objective

Impact KPIs are approved by the Impact Advisory Committee and monitored on a quarterly basis. Example metrics include:

PHQ-9 and GAD-7 mental health outcome scores
User-reported mental health and wellbeing improvements
Smartphone and app usage patterns (reduction in problematic usage)
Microbiome biomarker data

Methodology

Impact measurement combines quantitative and qualitative methods, tailored to each individual investment. Data sources include business metrics, product usage analytics, and user feedback.

Data Sources and Processing

Data is sourced from portfolio companies during the due diligence process and on a regular basis thereafter. Publicly available data is used to supplement company-provided information when appropriate. All data processing is conducted internally. No estimates are used in impact reporting.

Limitations

Impact measurement is dependent on data provided by portfolio companies. Complete and comprehensive data may not always be available, particularly for early-stage companies. The relationship between the fund and its portfolio companies is trust-based, and data quality relies on the integrity of the reporting processes maintained by each company.

Due Diligence

Due diligence is conducted across three areas:

Profit: Commercial viability and financial sustainability of the business.
Purpose: External impact on mental health and wellness outcomes.
People: Internal impact on employees, founders, and organizational health.

Internal experts cross-verify findings across all three areas. External advisory committees are planned to provide additional independent review.

Engagement Policies

The fund operates with a multi-year investment period, maintaining a trust-based relationship with portfolio companies. As a venture capital fund, Masawa typically holds a limited controlling interest in its portfolio companies and engages through board participation, ongoing dialogue, and impact monitoring rather than directive control.

This statement was last updated on November 30, 2024. For questions, contact us at hello@masawa.fund.