While building the portfolio of investments, Momenta has not designed and adopted an internal policy with respect to the integration of sustainability risks in the investment decision-making process. Sustainability risks are defined as environmental, social or governance events or conditions that Momenta considers could have a principal adverse impact on the value of one or more investments in the Fund in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector, as amended or supplemented from time to time (respectively “Sustainability Risks” and “SFDR”).

Having due regard to the singular nature of start-ups, the diversity of the industries into which they are developing their businesses, it is expected that it will be difficult to identify common sustainability factors applicable to all the targeted companies and to be provided with reliable data from such early-stage companies. As a result, it is not deemed relevant to integrate Sustainability Risks into the investment decision-making process of within the meaning of Article 6 (1) §2 of SFDR.

Identifying and integrating Sustainability Risks common to the portfolio of assets could prevent Momenta to deploy its investment policy in a timely manner if it had to ensure that each targeted company would be able to meet its objectives in terms of sustainability and to provide appropriate and reliable data in respect thereto. As a consequence, Momenta will not assess the likely impact of such Sustainability Risks on the returns of our investments.

Nevertheless, Momenta is working towards the establishment of guiding principles with respect to the integration of environmental, social and governance risk factors that will be applicable to our investments in the course of their development and that Momenta will strive to follow.