SFDR

FinTech Collective – Sustainability‑related Disclosures

Regulation (EU) 2019/2088 (SFDR)

Publication version: 1.0
Publication date: July 24, 2025
Publication URL: fintech.io/sfdr

1 Fund Manager and Fund Information

FinTech Collective Fund IV (Europe) SCSp (CSSF 00011763) (the “Fund”) is managed by FundRock LIS S.A. (LEI: 549300SFZJMMBDUEUE73) (the “Fund Manager”) as its alternative investment fund manager ("AIFM"). FundRock LIS S.A. is a Luxembourg‑registered AIFM regulated under Directive 2011/61/EU (AIFMD) as transposed into Luxembourg law by the law of 12 July 2013.

The Fund pursues an early‑stage venture capital strategy focusing on technology companies that reshape financial services. The Fund does not promote environmental or social characteristics and is therefore categorised as an Article 6 financial product under SFDR.
This decision reflects (a) the early‑stage nature of portfolio companies and the consequent lack of reliable data, and (b) the disproportionate administrative burden relative to the Fund’s size. The position is reviewed at least annually and may evolve as data availability improves.

2 Integration of sustainability risks in the investment decision-making process

Fund Manager firmly believes that finance and ethics should never be in contrast. As a guiding principle, for every company we engage with, we ask ourself the fundamental question of: Does this product or service provide a real positive impact for its customers, and is the world going to be a better place if this company succeeds? Therefore, when making investments, the Fund Manager considers the ethical, environmental, and societal consequences of such investments.

The Fund integrates sustainability (environmental, social and governance) risks into its investment decision‑making and ownership processes as follows:

  • Dynamic‑materiality screening – An internal GPT‑powered “ESG‑bot” screens every potential investment against the Fund's exclusion list and maps material ESG risks using the SASB materiality framework.

  • Founder engagement – Target‑specific follow‑up questions are addressed with founders to validate risk level and existing mitigants.

  • Investment Committee memo – A concise ESG roadmap, including identified risks and proposed mitigations, accompanies every Investment Committee decision.

  • Post‑investment roadmap & monitoring – Stage‑appropriate ESG resources are shared with portfolio companies and progress is reviewed at least annually by the ESG Committee.

Key sustainability risks that could materially affect value for early-stage fintech companies (as outlined in the SASB Software & IT Services Standard) include:

(i) environmental footprint of hardware infrastructure (energy, water and other impacts tied to cloud and data-centre use);

(ii) data privacy & freedom of expression (responsible collection, use and disclosure of customer data, plus compliance with content-governance requests) ;

(iii) data security (prevention, detection and remediation of cyber-attacks and breaches) ;

(iv) recruiting & managing a global, diverse & skilled workforce (attracting, retaining and engaging talent while fostering inclusion) ;

(v) intellectual property protection & competitive behaviour (litigation and antitrust exposures linked to patents or market dominance) ; and

(vi) managing systemic risks from technology disruptions (service outages, downtime and business-continuity planning for cloud-based operations) .

The Fund applies the principle of proportionality to ensure that ESG expectations remain practicable for start-ups, while aiming to mitigate the most material risks.

3 No Consideration of Principal Adverse Impacts (PAI)

At this time the Fund does not consider principal adverse impacts of its investment decisions on sustainability factors for the purposes of Article 4 SFDR.
This decision reflects (a) the early‑stage nature of portfolio companies and the consequent lack of reliable data, and (b) the disproportionate administrative burden relative to the Fund’s size. The position is reviewed at least annually and may evolve as data availability improves.

4 Investment Exclusions

Aligned with the Fund Manager, the Fund will not invest in, guarantee or otherwise provide financial or other support, directly or indirectly, to companies engaged in the production or trade (modelled on the IFC’s exclusion list):

  • Products or services deemed illegal under host country laws or regulations, or international conventions and agreements
  • Produce/are involved in the production of fossil fuels, including unconventional extraction of fossil fuels, such as oil sands and deep-sea drilling in particularly sensitive areas
  • Produce/are involved in the production or use of, or trade in, weapons, including weapons of mass destruction, or inhuman weapons or technologies, which are subject to existing international prohibitions
  • Produce/are involved in the production or use of illegal or criminally sanctioned activities
  • Produce/trade in tobacco (and other addictive substances), pesticides/herbicides (subject to international phase-outs / bans), sex work, pornography, gambling or casinos, as well as companies where more than five percent of total sales come from the distribution of these products

We will also exclude companies who/whose:

  • The entity has operations in countries that are on the sanctions lists of the European Union, the United States, or the United Nations.
  • The company does not comply with international standards and conventions regarding human rights, the environment, anti-corruption or labor laws
  • Product/service / business model is rooted in / reliant on exploitative tactics or deceptive business models, either of a certain demographic or an at-risk group

Additional tailored exclusions may apply at the Fund or deal level where specific ESG risks are identified.

5 Remuneration Policy

Fund Manager’s remuneration policies are structured to the effect that these do not encourage excessive risk-taking with respect to sustainability risks. Further, Fund Manager’s remuneration structures are linked to risk-adjusted performance.

6 Updates to These Disclosures

This statement will be reviewed at least annually and updated in the event of:

  • significant amendments to SFDR, its Regulatory Technical Standards or related EU legislation;

  • material changes to the Fund’s investment strategy or ESG Policy; or

  • the Fund’s decision to begin considering principal adverse impacts.

For further information please contact [email protected].

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