SFDR Fund Level Disclosure_Alma mundi Insurtech II, F.C.R.E.
Sustainable Finance Disclosure Regulation (SFDR)
Website Disclosure Level II
Financial Market Participant: Mundi Ventures
Product name: Alma mundi Insurtech II, F.C.R.E. (the “fund”)
May 2025
Articles 38-49 RTS SFDR
(a) Summary
(Article 38)
Alma Mundi Insurtech II (“the Fund”) is an Article 8 fund which addresses ESG issues through the promotion of environmental and social characteristics in the privately held companies the Fund invests in. Investees are players in InsurTech, FinTech and ClimateTech. While the Fund promotes environmental and social features it will not make sustainable investments as a primary focus.
The Fund’s investments are aligned with, but not limited to, the following SDGS:
Goal 1 – No Poverty
Goal 3 – Good Health and Well-Being
Goal 5 – Gender Equality
Goal 8 – Decent Work and Economic Growth
Goal 9 – Industry, Innovation and Infrastructure
Goal 10 – Reduced Inequalities
Goal 11 – Sustainable Cities and Communities
Goal 12 – Responsible Consumption and Production
Goal 13 – Climate Action
Goal 17 – Partnerships for the Goals
The fund is committed to investing in companies whose economic activities do not substantially contribute to the devolution of environmental / social objectives listed in the EU Taxonomy. The fund fosters the imbuement of ESG factors in portfolio companies business plan, business model and /or business roadmap – this is in line with our goal to support “purpose driven founders” in achieving improved financial performance alongside managing otherwise hard-to-price portfolio risks and opportunities such as climate-related ones.
(b) No Significant Harm to the Sustainable Investment Objective
(Article 39)
The Fund is committed to ensuring that any investment does not cause any significant harm to any environmental or social objective, and that good governance is duly upheld throughout the ownership period, as also reflected in our ESG Investment Policy. Potential adverse impacts of each investment are considered through the investment process and ownership period. Here are the steps taken to consider adverse impacts of our investments:
Pre-Investment
The Fund performs a comprehensive sustainability assessment prior to making any investment. This includes evaluating Principal Adverse Impacts (PAI) and identifying potential unintended negative effects on globally recognized sustainability goals, such as the United Nations Sustainable Development Goals (SDGs) and the EU Taxonomy.
If a prospective investee presents significant environmental or social risks but meets financial and legal due diligence standards, the Fund may require the company to implement specific mitigation actions. These measures—outlined in an “action plan”—may, on a case-by-case basis, be formalized through a side letter to the Shareholders’ Agreement.
The Fund will not proceed with an investment if the prospective company falls within the Fund’s exclusion list or refuses to adopt the action plan deemed necessary by the Investment Committee.
Post-Investment
Identification and quantification of the principal adverse impacts on the sustainability factors of the Fund's investments will be carried out during the annual portfolio management exercise. This to maintain that no significant harm is being caused to any environmental or social objective(s) by investees, particularly for those not aligned with an established Taxonomy / Standard or any that may pivot deviating from their prior established risk profile.
More information on Principal Adverse Impact Indicators (PAI)
The PAI indicators monitored pre- and post- investment comprise of the 14 mandatory indicators stipulated by the SFDR.
More information on Alignment with international principles and standards
The Fund requires Investees to adopt adequate governance frameworks aligned with SFDR Good Governance requirements (2019/2088 Article 2.17) with respect to their operating jurisdictions and the alignment of the investment with respect to:
the OECD Guidelines for Multinational Enterprises,
the United Nations Guiding Principles on Business and Human Rights; and
the eight conventions set out in the ILO Declaration
and the International Bill of Human Rights.
(c) Sustainable Investment Objective of the Final Product
(Article 40)
The fund’s objective is to promote environmental and social in the unlisted companies it takes temporary stakes in. The main activity or business model of the Fund’s investments is related to the following areas: InsurTech, FinTech, ClimateTech and DeepTech.
The SASB® (Sustainability Accounting Standards Board) materiality assessment method is used to identify material ESG issues before making investments.
After making an investment, where possible, we collect the following KPIs from our portfolio companies on an annual basis to monitor and improve environmental and social KPIs n addition to the PAI indicators:
GHG emissions – Scope 1,2,3 emissions (tCO2eq)
Top management diversity
Total number of women in top management (#)
Number of women in senior management (#)
Work-related injuries/accidents
Number of work-related injuries/accidents (#)
Employee engagement
Annual turnover rate (%)
Unadjusted gender pay gap (%)
Code of ethics implemented (Y/N)
(d) Investment Strategy
(Article 41)
The fund’s investment strategy is based on selecting deals, aligned with the Fund’s investment themes, that screen positively during financial, legal, ESG due diligence. The fund looks for startups led by diverse and purpose-driven founding teams; this is achieved by establishing 5 key criteria when conducting an initial analysis:
Alignment with Global Impact Goals
Assessment of whether the problem addressed by the startup aligns with the United Nations Sustainable Development Goals (UN SDGs) or other globally recognized societal challenges. While not a strict requirement, this alignment is considered in the evaluation process.Commitment to ESG Stewardship
Evaluation of the founders’ willingness to improve and integrate environmental, social, and governance (ESG) practices into the startup’s operations.Climate Change Awareness
Assessment of whether the startup currently measures its Scope 1, 2, and 3 greenhouse gas (GHG) emissions and demonstrates a commitment to ongoing measurement and monitoring.Gender Equality
Consideration of gender diversity within the founding team, with particular focus on the proportion of women founders.Corporate Governance Practices
Evaluation of the presence of basic governance structures, such as a Code of Conduct that outlines expectations for ethical behavior and good governance.
Pre-investment process
Determine if the prospect matches the fund theme followed by a pre-screening process that involves screening for all excluded activities stipulated in the ESG Investment Policy
Carry out Due diligence – Financial, Legal and ESG. The information gathered is presented to the investment committee to inform decision making.
Post-investment
Tiered ESG value creation taking into account the capacity of the portfolio company and their associated environment and/or social risk profile
Quarterly check-ins and annual data collection designed to facilitate disclosure requirements – Annual Sustainability Report, SFDR disclosure.
Internal ESG Incentive: 10% of the Investment team’s variable compensation is linked to ESG score of their performance throughout the year.
(e) Proportion of Investments
(Article 42)
0% of the investments are committed to the sustainable investments. However, 100% of investees are subject to ESG analysis based on SASB standard pre- and post-investment.
Investment
#1 Aligned with E/S characteristic
EU Taxonomy Aligned
Other taxonomies / Standards
#2 Other
(f) Monitoring of Environmental and Social Characteristics
(Article 43)
During the investment period, compliance with “action plan” is monitored and promoted with the investees through representation on the board and dialogue with the management team. “Action plan” refers to recommendations / targets which may / may not be provided in a side letter to the Shareholders agreement based on results of the ESG due diligence carried out in the pre-investment period.
Once a year portfolio companies are required to complete a questionnaire that includes questions on ESG KPIs, the degree of compliance with the action plan if one was provided and the reporting of principal adverse impacts on sustainability factors.
(g) Methodologies
(Article 44)
Progress toward environmental objectives will be assessed annually based on improvements in key environmental performance indicators (KPIs) across the portfolio. These may include CO₂ emissions, the presence of an environmental policy, water emissions, renewable energy usage, and other relevant metrics.
Similarly, achievement of social objectives will be measured through year-on-year improvements in social KPIs, such as gender balance, gender pay gap, employee turnover, and the impact on specific customer segments. These indicators help evaluate the company’s social and economic development.
Where relevant, additional indicators capturing improvements in stakeholder wellbeing will be used to complement the assessment.
(h) Data Sources and Processing
(Article 45)
Data used to assess the Fund’s environmental and social objectives is primarily sourced from the portfolio companies. Given the early-stage nature of many investments, definition and scope of data often changes year over years (such as measurable Scope 3 emissions) for certain ESG KPIs. To ensure data quality and consistency, the Fund engages a third-party sustainability firm to support data validation and streamline ESG metric collection at the fund level.
The ESG team compiles this data annually into reports and insights for both investees and internal stakeholders. The evolution of Principal Adverse Impacts (PAIs) is tracked through yearly calculations of relevant indicators, and information on PAIs is included in regular investor reporting.
(i) Limitations to Methodologies and Data
(Article 46)
Early-stage investees often face challenges in collecting the data required to calculate ESG indicators, as many are still developing their data tracking capabilities. This can result in gaps in primary data, limiting the Fund’s ability to fully assess its ESG portfolio and establish robust benchmarks.
To address these limitations, the Fund’s ESG team offers tailored support, including accessible tools and resources to help early-stage companies build effective ESG data collection and management systems.
(j) Due Diligence
(Article 47)
The Fund carries out ESG due diligence in addition to Financial and Legal diligence. ESG due diligence provide a clear view a company’s environmental, social and governance scope and would-be targets.
The company’s baseline ESG profile is assessed pre-investment through a questionnaire.
For startups beyond Series B with asset-heavy models, a preliminary climate risk assessment is also conducted.
ESG due diligence outcomes inform investment decisions.
If ESG risks are deemed manageable, the ESG team may recommend actions or set targets, formalized either through regular engagement or in a side letter to the Shareholders’ Agreement.
Post-investment, ESG engagement occurs quarterly, biannually, or annually based on the level of oversight required.
(k) Engagement Policies
(Article 48)
ESG considerations are embedded in the Fund’s daily operations. A portion of the Investment Team’s compensation is linked to the achievement of environmental and social objectives. To build internal capacity, the Fund provides regular climate training to keep the team informed about global climate risks and the impact of investment decisions.
The ESG team also engages with investee companies on a recurring basis, enabling ongoing monitoring and support to help them meet their environmental and social targets.
(l) Attainment of Sustainable Investment Objective
(Article 49)
Given the Fund’s global focus and emphasis on early-stage investments, benchmarking progress toward environmental and social objectives requires a flexible approach. To address this, we have developed a tailored sustainability engagement process that aligns with the nature of our investment strategy and complements our internal operations.
