Art. 8 SFDR – SFDR Disclosure Website

heal.capital Management GmbH (“heal.capital”) is an alternative investment fund manager within the meaning of the German Investment Code (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 (the “SFDR”).

Art. 3 SFDR – Sustainability risk policies statement

heal.capital backs mission driven founders with capital and health tech-specific expertise in order to noticeably improve medical care through the use of digital technologies. As such, heal.capital’s investment strategy is focused on digital technologies for the healthcare sector.

Healthcare is one of the most regulated investment areas. Due to existing regulatory frameworks in healthcare, heal.capital considers the general sustainability risks as low. heal.capital addresses sustainability risks as part of their investment decision-making process. ‘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. The main concerns we pay attention to are startup governance in general and the startup’s approach regarding data and health studies where applicable.

Based on our investment strategy, we automatically exclude certain companies like:

makers of controversial weapons such as cluster bombs or nuclear warheads and those making indisputably harmful products such as tobacco and firearms, along with companies engaged in human rights abuses such as child labor. Companies engaged in serious corporate governance breaches such as bribery or corruption and that show no willingness to resolve these issues, are also typically excluded.

We regularly review our policies to ensure that they address new and emerging risks as well as investors’ concerns.

Art. 4 SFDR – No consideration of principal adverse impacts

heal.capital does not consider principal adverse impacts of investment decisions on sustainability factors. ‘Sustainability factors’ mean environmental, social and employee matters, respect for human rights, anti‐corruption and anti‐bribery matters. heal.capital does not use sustainability indicators. Considering the numerous legal uncertainties currently related to the application of the provisions of the SFDR and the Regulatory Technical Standards (“RTS”) – in particular with respect to the consideration of adverse impacts – and the administrative burden resulting from such uncertainties, heal.capital is not in a position to commit to such standard in light of its fiduciary duty to its funds and investors. heal.capital will constantly monitor and review the evolution around such regulations and standards and considers changing its position on adverse impacts once (i) a best practice has evolved among market participants, (ii) there is clear guidance by the administrations on the application of such regulations and (iii) the consequences of a commitment towards the consideration of principal adverse impacts are reasonably clear to heal.capital.

Art. 5 SFDR – Remuneration disclosure

As a registered alternative investment fund manager within the meaning of the German Investment Code (Kapitalanlagegesetzbuch, KAGB), heal.capital 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.

Last Version: 07/09/2023

Art. 10 Disclosures
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