Disclosures Pursuant to Regulation (EU) 2019/2088

Article 3 SFDR – Sustainability Risk Policies Statement

Outpace addresses sustainability risks in its investment decision-making process insofar as relevant. “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. During the due diligence on potential investments, Outpace conducts a careful analysis of the investment's exposure to environmental, social, and governance risks that could impact its value. When identifying a sustainability risk during the due diligence on potential investments, Outpace decides in light of the specific situation taking due account of the proportionality principle whether it gives up on the investment or proceeds with the investment alongside appropriate measures to mitigate the relevant sustainability risk.

Article 4 SFDR – No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors

Outpace does not consider principal adverse impacts (“PAI”) of investment decisions on sustainability factors. “Sustainability factors” mean environmental, social, and employee matters, respect for human rights, anti‐corruption, and anti‐bribery matters. Outpace does not use sustainability indicators. The standardized catalog of PAI indicators (“PAII”) provided by Annex I of the regulatory technical standards issued under the SFDR is not tailored to the specific needs of the early-stage investment strategy pursued by Outpace.

In many instances, data will be insufficient for analyzing PAI, and on occasions where data is obtainable, it tends to offer little in terms of comparability and fails to provide additional insights for Outpace. Therefore, collecting data on PAII will not only increase the administrative burden and costs but also fail to provide a new perspective for Outpace.

Article 5 SFDR – Remuneration Disclosure

As a registered alternative investment fund manager within the meaning of the KAGB, Outpace does not have, nor is required 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.

Article 10 SFDR – Sustainability-Related Information About Financial Products That Promote Environmental or Social Characteristics

Outpace GmbH, is the alternative investment fund manager of Outpace Fund I GmbH & Co. KG (“Outpace Fund I”), within the meaning of the German Investment Code (Kapitalanlagegesetzbuch) 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 (“SFDR”).

Summary

This financial product promotes environmental or social characteristics but does not have as its objective a sustainable investment within the meaning of Article 2 No. 17 SFDR. The promoted characteristics are investment restrictions. 100 % of the investments will be in line with its investment strategy and investment restrictions.

No reference benchmark has been designated to attain the environmental or social characteristics promoted by the financial product.

No Sustainable Investment Objective

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

Environmental or Social Characteristics of the Financial Product

The promoted characteristics are investment restrictions.

Outpace Fund I shall not invest in companies whose business activity consists of an illegal economic activity or which substantially focus on: (i) gambling, including casinos, online betting platforms, lotteries, (ii) pornographic content, adult entertainment venues, or escort or prostitution‑related services, or (iii) the production of, or trade in, tobacco products, cannabis, narcotic drugs, or distilled alcoholic beverages.

Investment Strategy

Outpace Fund I intends to seek long-term capital appreciation through equity and quasi-equity investments in early-stage technology companies primarily in Europe and North America with a focus on Core AI.

Policy to Assess Good Governance Practices of the Investee Companies

As part of the due diligence and ongoing investment management, the investment team will review whether a potential investee company has good governance practices in place. This might include using ESG (environmental, social, and governance) criteria to evaluate companies' performance in areas such as labor practices, human rights, and corporate governance, conducting due diligence on investee companies to assess their management structures, employee relations, and tax compliance, engaging with investee companies to encourage improvements in governance practices, if necessary. The intensity of the assessment is carried out in accordance with the principle of proportionality. Where Outpace Fund I sees higher risks of a non-compliance, the audit will be intensified.

Proportion of Investments

Outpace Fund I will invest fully in line with its investment strategy and investment restrictions. Outpace Fund I will not invest a portion of its capital in any other asset class.

Monitoring of Environmental or Social Characteristics

The investment team for Outpace Fund I will initially and continuously monitor whether the investment restrictions are abided by and whether the investment falls within the investment policies. Outpace Fund I will not make any investment in the excluded sectors. Therefore, the achievement of the promoted ESG aspects – no investment within the excluded sectors – can be tracked in a simple way.

Methodologies for Environmental or Social Characteristics

Any potential investment is assessed against the list of excluded sectors prior to an investment. Outpace Fund I verifies on an ongoing basis that no investment falls within any of the sectors excluded under the fund’s investment policy.

Data Sources and Processing

Outpace Fund I receives portfolio-related data as part of its due diligence process and on a regular basis following the investment. Where necessary or beneficial, Outpace Fund I also makes use of publicly available data. Estimates of data are not made.

Limitations to Methodologies and Data

Outpace Fund I partially relies on the information gathered during the due diligence process. Moreover, in the post-investment phase, Outpace Fund I is reliant on the reported data. In both cases, complete data may not always be available due to the nature of the investments. The information is verified only if and to the extent misrepresentations are suspected.

Due Diligence

Outpace Fund I considers the promoted ESG aspects when sourcing new investments for Outpace Fund I and during the due diligence on targeted investments. The due diligence is performed by obtaining all information relevant to Outpace Fund I using a due diligence questionnaire, which is then reviewed internally. If necessary, further specific information is also obtained from the potential investments, should this still be necessary after the detailed questioning. The due diligence process is not externally monitored.

Engagement Policies

Outpace Fund I investments are made for a period of several years. Accordingly Outpace Fund I prioritizes building and maintaining a trust-based working relationship with them to ensure ongoing compliance with investment restrictions. In this context, Outpace Fund I also seeks to establish or strengthen the integration of sustainability aspects at the portfolio level, but as a venture capitalist without majority ownership, the influence Outpace Fund I can exert on the portfolio companies is limited.