SFDR article 3 requires fund managers such as Skyfall to publish on their websites information about their policies on the integration of sustainability risks in their investment decision-making process. Sustainability risks are defined in the SFDR as environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of the investment.
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Skyfall integrates such risks in its investment decision-process for all its funds under management mainly by avoiding investments in sectors or business models that may be especially vulnerable to sustainability risk due to the products or services they offer, such as companies operating within fossil fuel extraction or deforestation-linked industries, or due to their behavior, such as companies with poor labor practices. For Skyfall Ventures Fund III AS ("Fund III"), Skyfall will also conduct, as part of its due diligence of a potential investment, an assessment seeking to identify and evaluate any sustainability risk specific to the target company or its industry and, where relevant, include covenants in term sheets that require the company to take specific actions for the purpose of mitigating any identified such risks.
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Similar to how Skyfall integrates other types of risks in its investment decision-process, it will for Fund III not invest in a company that in Skyfall's assessment is associated with unacceptable sustainability risk. Each such exclusion and its rationale will be documented in Skyfall’s internal systems.

SFDR article 4 requires fund managers such as Skyfall to publish and maintain on their websites information on whether they consider principal adverse impacts (PAI) of investment decisions on sustainability factors and, if they do not consider adverse impacts of investment decisions on sustainability factors, clear reasons therefor, including, where relevant, information as to whether and when they intend to do so. Sustainability factors are environmental, social and employee matters, respect for human rights, anticorruption and anti-bribery matters, and PAI are the most significant negative impacts of investment decisions on these factors.
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Skyfall does not consider adverse impacts of investment decisions on sustainability factors. The reason for this is that Skyfall finds the administrative and financial burden on Skyfall and its funds' portfolio companies that would result from having to collect, compile, review and report on the necessary data to disclose under point (a) of article 4(1) of SFDR, is disproportionate for the potential benefits of such reporting.
Skyfall has not set a future date for when it intends to consider PAI in its investment decisions, but will regularly review its position.

SFDR article 5 requires fund managers such as Skyfall to publish on their website information on how their remuneration policies are consistent with the integration of sustainability risks.
Skyfall is not required to adopt a remuneration policy, and has not done so voluntarily. Skyfall will ensure that any future remuneration policies are consistent with Skyfall’s integration of sustainability risks as outlined above.

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment. The Fund promotes the environmental and social characteristic of aiming to contribute some or all of certain environmental and social goals. The aim is that at least 50% of the of the Fund's portfolio companies should be classified as contributing to one or more of those environmental or social goals.
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The Fund shall invest in technology companies, in the earliest stages of the companies' lifetime, and Skyfall shall comply with the Fund's ESG investment policy (the "Policy") in its management of the Fund. All of the Fund's portfolio companies must follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.
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The Fund monitors environmental and social characteristics through defined Impact KPIs for each portfolio company, covering both positive contributions and potential negative externalities. Methodologies to measure how the social or environmental characteristics promoted by the Fund are met include a structured impact and ESG investment analysis that screens each investment against exclusion lists and identifies relevant KPIs. Data used to attain each of the environmental or social characteristics promoted by the Fund is sourced primarily from company reporting and KPI disclosures, ESG due diligence during investment, and external frameworks (EU Taxonomy, UN SDGs, OECD, UNGPs). The methods have limitations, particularly the reliance on companies' own reporting, but these are mitigated through active ownership and close dialogue. Skyfall conducts due diligence and exercises active ownership to strengthen ESG practices, reduce risk, and ensure that companies address any sustainability-related challenges.
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No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the Fund.

This financial product promotes environmental or social characteristics, but does not have as its objective sustainable investment.

The Fund promotes the environmental and social characteristic of aiming to contribute some or all of the following environmental and social goals:

The following environmental objectives:
- climate change mitigation,
- climate change adaptation,
- the transition to a circular economy, and
- pollution prevention and control.

The following UN Sustainable Development Goals (SDGs):
- Good Health and Well-being (SDG 3),
- Quality Education (SDG 4),
- Gender Equality (SDG 5),
- Affordable and Clean Energy (SDG 7),
- Decent Work and Economic Growth (SDG 8),
- Industry, Innovation and Infrastructure (SDG 9),
- Sustainable Cities and Communities (SDG 11),
- Responsible Consumption and Production (SDG 12),
- Climate Action (SDG 13), and
- Promote peaceful and inclusive societies for sustainable development, provide access to justice for all and build effective, accountable and inclusive institutions at all levels (SDG 16).

The investment strategy used to meet the environmental or social characteristics promoted by the Fund
Skyfall shall comply with the Fund's ESG investment policy (the "Policy") in its management of the Fund. The Policy sets out, among other things that Skyfall shall apply certain inclusion criteria in the investment selection process for the purpose of identifying investments that contribute, as determined by Skyfall in accordance with its assessment criteria, to one or more of the defined environmental or social goals.
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In determining whether a potential investment could contribute to one or more of the environmental or social goals described above, Skyfall first assigns each potential investment to one or more categories (e.g., A1, B9 etc.), and then assigns one of the following four contribution levels to the potential investment: (i) No contribution; (ii) weak contribution; (iii) medium contribution; or (iv) strong contribution. Companies assigned the levels of "medium" or "strong" by Skyfall will be deemed as contributing the relevant goal(s).

In categorizing and determining the contribution level for the potential investment, Skyfall takes into account factors such as:

- Any publicly available goals and ambitions of the potential investment, any goals and ambitions of the potential investment as communicated to Skyfall in investment memos, meetings, interviews, etc.,
- any classification provided by the company on the request of Skyfall if needed to classify the potentialinvestment, and
- any ESG benchmarking to peer companies or to similar companies available through sources such as S&P Global ESG Scores.

The Fund does not commit to exclusively making investments deemed to contribute to any of the above-mentioned goals. Skyfall's aim is that at least 50% of the Fund's portfolio companies should be classified as contributing to one or more environmental or social goals (i.e., be assigned the contribution levels of "medium" or "strong").The policy to assess good governance practices of the investee companiesAll of the Fund's portfolio companies must follow good governance practices, in particular with respect to sound management structures, employee relations, remuneration of staff and tax compliance.Skyfall assesses all potential portfolio companies in relation to these criteria prior to making any investment decision. As basis for its assessment, Skyfall uses information obtained through interviews with, e.g., founders, management, board members and existing investors, review of the company's key governance documents (such as articles of association and any corporate governance policies) and the company's compliance with any specific applicable governance standards and regulations.

Skyfall may also conduct reference checks by way of contacting, e.g., business partners of the company and other stakeholders. If Skyfall finds, in its overall assessment, that the company does not follow good governance practices, the Fund will not invest in the company.Skyfall also monitors the governance practices of the Fund's portfolio companies as part of its engagement with the companies.

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The Fund shall invest in technology companies, in the earliest stages of the companies' lifetime. Investments may be made through equity instruments, convertible debt, and Simple Agreements for Future Equity (SAFEs) or Startup's Lead Investment Papers (SLIPs). The Fund is sector agnostic, and may invest globally.

While Skyfall's aim is that at least 50% of the of the Fund's portfolio companies should be classified as contributing to one or more environmental or social goals, the Policy is complied with in relation to all (potential) investments of the Fund. Specifically, all investments shall be screened against the inclusion criteria (albeit not all investments will be deemed as contributors to a relevant environmental or social goal).

Accordingly, the Fund intends to use 100 % of its investments to meet the environmental and social characteristics promoted by the Fund in accordance with the binding elements of the investment strategy.

The Fund monitors environmental and social characteristics through defined Impact KPIs for each portfolio company, covering both positive contributions and potential negative externalities. Companies are classified by contribution level and tracked annually for development. Monitoring is based on company-reported data, and reviewed during ownership. The monitoring is conducted by internal investment teams, with board-level reviews ensuring additional oversight.

Methodologies to measure how the social or environmental characteristics promoted by the Fund are met include a structured impact and ESG investment analysis that screens each investment against exclusion lists and identifies relevant KPIs. Impact KPIs are tailored to the company’s business model and the relevant environmental or social goals for the investment. These KPIs are co-developed with management, integrated into reporting obligations, and updated regularly to measure attainment of environmental and social goals.

Data used to attain each of the environmental or social characteristics promoted by the Fund is sourced primarily from:
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- Company reporting and KPI disclosures.
- ESG due diligence during investment.
- External frameworks (EU Taxonomy, UN SDGs, OECD, UNGPs).

Quality is ensured by integrating commitments into side letters and requiring regular reporting from investees. Data is processed in internal systems, with impact contribution and adverse indicators tracked systematically. Only a limited share of data is estimated, typically when company reporting is incomplete, and such estimates are validated against sector benchmarks.

Limitations to the methodologies and data referred to above include reliance on company-reported data, varying levels of maturity in ESG reporting, and lack of standardized industry benchmarks for early-stage companies. While this may reduce comparability, Skyfall seeks to remedy the limitations through active ownership, co-designing Impact KPIs with the management of investee companies, and ongoing engagement with management teams. These practices ensure limitations do not compromise the Fund’s ability to meet the environmental and social characteristics it promotes.

Skyfall's due diligence of potential investee companies combines ESG screening, exclusion analysis, and assessment of governance practices. Key factors include environmental/social contributions, adverse impact risks, operational risks, and governance standards. The process is documented in Skyfall’s CRM system and forms part of every investment decision. Internal investment teams lead the analysis, and external references (OECD, UNGPs, UN Global Compact) guide evaluation standards. Board oversight ensures robustness of the due diligence process.

Skyfall applies an active ownership approach, using board participation and direct dialogue to strengthen ESG policies, mitigate adverse impacts, and improve reporting. Engagement focuses on ensuring investees track and deliver against agreed Impact KPIs and take corrective actions where risks are identified. Skyfall expects management teams to address any stainability-related controversies transparently, with Skyfall monitoring remediation and reserving the right to escalate if unresolved.