Adverse impacts of investment decisions on sustainability factors are currently not considered by Northern Startup Funds or Butterfly Venture Fund III within the meaning of Article 4(1)(a) of the EU Regulation on Sustainability‐Related Disclosures in the Financial Services Sector (2019/2088).

We invest in startup companies in their early stages, i.e. micro companies, and also regard our seed entry funds to fall into the category of micro VC funds. The nature and scale of our activities and the kind of funds we manage and fund products we offer, results in that our adverse impact is likely to be very small if even comparably measurable. These factors comprise the reasons for not considering the adverse impacts at the very moment.

We also acknowledge the apparent uncertainties relating to the practical content of the obligation set out in the Article 4(1)(a), and consequently, act in accordance with the Article 4(1)(b) of the EU regulation in question, for the time being.

We target to consider adverse sustainability impacts of investment decisions within the meaning of Article 4(1)(a), after the Regulatory Technical Standards of the EU regulation 2019/2088 are in force and further information on the substantial requirements is available, e.g. through example implementations by mid-sized private equity and venture capital actors, as well as, on any possible equivalence principles applied.


This document was last updated on 21st June 2022. Our contact person for this Adverse Sustainability Impacts Statement is the managing partner of Butterfly Ventures.