Updated:
Monday 19th January 2026
Website Disclosure Pursuant to Article 8 of Regulation (EU) 2019/2088
Product name: Sagona Europe Equity SCSp and Sagona U.S. Equity LP (referred to as “the financial product”)
Legal entity identifier: 254900YGSRZVSN46K520 / 254900X1ALKWHEO4JL03
(a) Summary
This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.
The product promotes environmental characteristics specific to each investment universe. These criteria cover environmental, social, societal and governance themes. This choice reflects the fact that each investment sector has distinct environmental and social impacts.
The investment strategy focus on financing:
- Deeptech companies specialized in services and AI products, blockchain, fintech and enterprise software
- Heath tech companies that develop or manufacture medical devices, diagnostics, digital health solutions, therapeutics, or healthcare-supporting technologies. These investments fall within our four themes: early detection and preventive screening, robotics and precision medicine, Brain-Computer Interface (BCI) and neurotechnology, and digital health
- Sustainability companies whose core business relates to water resource management and, waste management. The strategy is organized around four themes per industry:
o Water sector (advanced water treatment and PFAS and contaminants remediation, smart water infrastructure and IoT management, industrial water reuse and zero liquid discharge, water-as-a-Service and decentralized treatment)
o Waste sector: (AI-powered sorting and robotics for material recovery, chemical recycling and advanced material processing, EPR compliance and digital material tracking, industrial waste valorization and resource recovery)
- Greentech companies whose activities are eligible under the European Taxonomy and covering the following topics : climate change mitigation and adaptation, renewable energy, sustainable agriculture, climate-smart agri-technology, resource efficiency and sustainable resource management etc
Sustainability factors are integrated throughout the investment lifecycle via binding eligibility criteria, environmental and social due diligence, and ongoing monitoring to ensure alignment with the promoted environmental and social characteristics.
A minimum of 90% of the product’s investments are aligned with the environmental and social characteristics promoted. The remaining 10% includes fees necessary for the ongoing operation of the product (e.g. management fees). These expenses mainly cover legal fees for reviewing employee and supplier contracts, tax advisors for ensuring tax compliance, and accountants for reviewing financial statements. The product invests 90% directly in companies and 10% through SPVs.
The attainment of the promoted characteristics is monitored using dedicated sustainability indicators, depending on the investment theme and the E/S characteristics to be promoted. Monitoring is conducted on an ongoing basis and reviewed annually by the Investment Committee.
Environmental and social characteristics are measured using activity data, standardized frameworks and methodologies, and annual ESG questionnaires completed by portfolio companies. Internal validation processes ensure consistency and comparability across companies.
Data is primarily sourced from portfolio companies based essentially on activity data. ESG data is consolidated and processed through a dedicated ESG data management platform. The risks of data inaccuracy are mitigated by internal controls, consistency checks, and periodic reviews.
A structured due-diligence process is applied prior to each investment to assess financial, legal, technical, and ESG risks and to confirm alignment with the environmental and social characteristics promoted by the product; external experts are engaged where relevant, and due-diligence findings are documented and reviewed by the Investment Committee.
The product engages with portfolio companies team’s management throughout the entire life cycle of the investment to monitor ESG performance, address identified risks, and ensure continued alignment with the promoted environmental and social characteristics.
No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the financial product.
(b) No Sustainable investment objective
This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.
(c) Environmental or social characteristics of the financial product
The E/S characteristics this financial product promotes are customized for each investment universe:
Deep tech:
- Corporate governance: Good governance principles are promoted across portfolio companies, recognizing that Deep tech value depends heavily on technical integrity. Through its investment operations, Sagona enforces best practices in governance risk management. Investee companies define ethical practices and anti-corruption measures based on their maturity level and risk exposure. These measures are formalized in company processes and aligned with international standards (OECD Principles of Corporate Governance, UN PRIs).
- User Impact and Data Management: The fund's investment practices ensure proper protection and use of user data, as well as appropriate handling of sensitive information. Policies and processes are implemented to identify, prevent, and mitigate misuse, dual-use, or unintended consequences of models, tools, or data breaches.
- Environmental awareness: Deep tech solutions have environmental impacts. For each investment, the fund will closely review and assess practices related to energy-efficient equipment, responsible water use, and low-carbon energy.
Healthtech:
- Ethical practices: Given the sensitivity of the information processed, the fund implements evaluation procedures to ensure data privacy, patient data security, and compliance with local regulations on medical data security and storage.
- Patient benefits: The fund's objective is to finance products and solutions that have a positive externality for patients. These investments aim to facilitate access to care, diagnostics, and treatment monitoring.
- Environmental awareness: Health tech solutions have environmental impacts too. For each investment, the fund will closely assess practices related to energy efficiency and carbon footprint.
Sustainability:
The fund supports companies and projects that advance water and waste treatment, recovery, and pollution prevention using efficient technologies. These investments finance activities eligible under the European Taxonomy contribute to Green Deal objectives. Beyond environmental goals, Sagona Capital invests in companies with strong governance practices whose business activities do not harm other environmental characteristics.
Greentech:
These investments finance activities eligible under the European Taxonomy: climate change mitigation and adaptation, renewable energy, sustainable agriculture, climate-smart agri-technology, resource efficiency and sustainable resource management etc. Beyond environmental goals, Sagona Capital invests in companies with strong governance practices whose business activities do not harm other environmental characteristics.
(d) Investment strategy
Sustainability factors are integral to our investment strategy and consequently the financial product’s business model.
The investment strategy focuses on financing portfolio companies across four investment areas, each with distinct environmental and social characteristics. The investment universe focuses primarily on:
- Seed and early-stage companies located mainly in the United States and Europe
- SMEs, green infrastructure projects, and sustainable tech–focused ventures located mainly in the United States and Europe.
Additionally, an exclusion list applies to all investments, strictly excluding companies whose core business relies on controversial sectors such as fossil fuel extraction, weapons, and tobacco, as well as companies located in countries listed on OFAC sanctions lists.
ESG oversight is embedded within the product’s investment governance framework. Sagona does not have a standalone ESG committee; ESG matters are integrated into investment decision-making and oversight processes, with a designated ESG expert responsible for coordinating ESG-related reviews and monitoring.
The binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product
The following elements of the investment strategy are applied to ensure that investments selected are aligned with, and contribute to, the environmental and social characteristics promoted by the financial product:
A- Screening:
Greentech: Companies should at least present one environment attribute among the following list:
- Deployment and scaling of renewable energy technologies (solar, wind, hydrogen, energy storage, sustainable smart grid project etc)
- Development and adoption of climate-tech (clean energy, energy efficiency, carbon reduction, carbon capture/offsetting, sustainable materials, low-carbon manufacturing).
- Promotion of sustainable agriculture and agri-tech solutions (climate-smart agriculture, regenerative agriculture technologies, precision farming, resource-efficient irrigation, soil & water conservation, sustainable supply-chain agriculture).
Sustainability: Companies should at least present one environment attribute among the following list:
- Operate in water technologies: wastewater treatment, desalination, water-reuse, water-efficiency
- Operate in waste-management (recycling facilities, waste-to-energy, material recovery, circular-economy innovators)
Health tech: Companies must meet eligibility criteria related to their core business strategy and develop or manufacture medical devices, diagnostics, digital health solutions, therapeutics, or healthcare-supporting technologies.
Preference is given to companies presenting at least one positive environmental or social attribute (e.g., energy-efficient products, strong data-privacy compliance, gender-diverse management, external stakeholder consultation).
Deep tech: Preference is given to companies presenting at least one positive environmental or social attribute (e.g., energy-efficient products, strong data-privacy compliance, gender-diverse management, external stakeholder consultation).
B- Due diligence:
- ESG questionnaires or interviews are conducted to collect key information and sustainable indicators for evaluating environmental, social, and governance practices.
- Interviews assess the company's ESG strategy, ambition, and business impact to ensure full alignment with the environmental and social characteristics.
- For sustainability and green tech investments, a DNSH (Do No Significant Harm) assessment excludes companies whose core business involves environmentally harmful practices.
C- Monitoring and engagement:
- Obtain annual sustainability and performance data from investee entities, including key ESG metrics and sustainable indicators to monitor ongoing alignment with the promoted environmental and social characteristics.
- Sit at the board and engage with investees to improve their ESG performance.
- For each additional investment, the fund conducts mini audits to ensure ESG alignment with environmental and social characteristics. The due diligence includes reviewing ESG indicator performance, assessing the portfolio company's ESG objectives, confirming the absence of controversies or incidents, and updating the exposure to severe sustainability risks.
This binding monitoring framework allows the product to assess and demonstrate the ongoing attainment of the promoted environmental and social characteristics.
The committed minimum rate to reduce the scope of the investment considered prior to the application of that investment strategy
This financial product has not committed to a minimum rate to reduce the scope of the investments considered prior to the application of this investment strategy.
The investment strategy inherently applies a 100% ESG-aligned filter to all the investment of this financial product, so no additional quantitative reduction of the investable universe is required.
The policy to assess good governance practices of the investee companies
The financial product has established a good governance policy to ensure that all investee entities and key counterparties operate in accordance with high standards of corporate governance. The policy sets out procedures to assess and monitor sound management structures, employee relations, remuneration, and tax compliance.
The good governance policy covers the following key principles:
- Employees’ relations,
- Bribery, corruption and business ethics,
- Accurate reporting of financial and non-financial data
- Tax behavior
- Remuneration structure
Assessment of good governance is embedded at the following stages of the investment decision-making process:
Due diligence phase: interviews and distribution of questionnaires to gather information on company practices and policies related to employee relations, ethical business conduct, tax compliance, and management systems.
Contracting phase: signature of the good governance policy in the shareholders' agreement.
Annual monitoring phase: yearly ESG questionnaire including governance questions for team management of the investee companies. When governance issues are identified, the fund implements remediation and escalation measures
This framework ensures continuous adherence to good governance standards and strengthens the integrity and sustainability of the product’s investments.
(e) Proportion of investments
The minimum proportion of the financial product’s investment allocated to achieve E/S characteristics is 90% and is coherent with the binding elements of the strategy. The minimum proportion is determined based on the nature of the investments and the product’s exclusive four thematic focus. The product invests 90% directly in companies and 10% through SPVs.
The remaining 10% includes fees necessary for the ongoing operation of the product (e.g. management fees). These expenses mainly cover legal fees for reviewing employee and supplier contracts, tax advisors for ensuring tax compliance, and accountants for reviewing financial statements. The purpose of these investments is to ensure effective portfolio administration, and compliance with regulatory and operational requirements.
(f) Monitoring of environmental or social characteristics
The sustainability indicators used to measure the achievement of these goals are:
Deeptech:
1. Corporate governance:
- Compliance with UNPRI and OECD Principles of Corporate Governance
- Code of conduct
2. User Impact and Data Management:
- External stakeholder consultation
- Number of data-privacy / cybersecurity incidents per year
3. Environmental awareness:
- Energy consumption and GHG emissions of the technological solutions (usage/cloud)
- Scope 1 + 2 emissions
Healthtech:
1. Ethical practices:
- Number of data-privacy/ cybersecurity incidents per year
- External stakeholder consultation
2. Patients benefits:
- Number of patients covered by the product/service sold
3. Environmental awareness:
- Scope 1 + 2 emissions
- Energy consumption and GHG emissions of the technological solutions (usage/cloud)
Sustainability:
- Number of eligible environmental EU taxonomy activities covered
- Emissions of water pollutant
- % of recycled waste
- Intensity of waste
- Energy intensity (kWh revenue)
- GHG emissions intensity
Greentech:
- Number of eligible environmental EU taxonomy activities covered
- Impact metrics: for sustainable agriculture indicators (Energy consumption/kg of product, water consumption/kg of product, amount of fertilizers/ kg of product).
- GHG emissions intensity
Sagona applies an internal monitoring and control framework to track sustainability indicators and the environmental and social characteristics promoted by the financial product. Monitoring relies exclusively on internal controls; no external assurance, audit, or third-party verification is currently applied.
The internal controls implemented are as follows:
- ESG data is collected annually by the ESG expert through the ESG data management platform, based on information received from portfolio companies;
- The collected ESG data is reviewed annually by the ESG expert to assess completeness, internal consistency, and alignment with internal methodologies and framework. Data collected is then reviewed by Portfolios managers to ensure a follow up of the ESG performance;
- Outside the annual cycle, ad-hoc internal follow-ups are conducted where material ESG incidents occur or where inconsistencies or gaps are identified in reported data. A list of two – three ESG metrics are collected quarterly alongside business and financial reporting;
- Internal consistency checks are performed to confirm that ESG data reported through the platform is coherent with supporting documentation. Any material data gaps or inconsistencies are followed up with the relevant portfolio companies’ team management and addressed prior to the finalization of annual SFDR reporting;
- The results of the annual ESG monitoring cycle are consolidated and presented to the Investment Committee to ensure oversight, documentation, and traceability.
(g) Methodologies
The financial product measures the attainment of its environmental and social characteristics using methodologies that are directly linked to the sustainability indicators disclosed and applied consistently across portfolio companies:
· The indicators related to PAIs are aligned with the definition and calculation methodology of SFDR regulations (Compliance with UNPRI and OECD Principles of Corporate Governance, emissions of water pollutant, % of recycled waste, Intensity of waste)
· Scope 1 and 2 emissions are calculated from company activity data and then converted into GHG emissions according to the GHG Protocol methodology
· Energy consumption is calculated based on actual data from billed or consumed usage records.
· Financial intensity ratios are calculated from revenue data in $ and € at the financial year-end.
· Code of conduct is collected and reviewed at least once at the beginning of the investment phase and whenever the document is updated.
· The number of data-privacy/ cybersecurity incidents per year is tracked quarterly with business and financial reporting. Investees must report any IT breach identified in their systems that may impact customer data.
· External stakeholder consultations are conducted at least once before a product or service is launched. These consultations ensure that the main expectations and rights of affected parties are integrated into the design and use of the solutions.
· The number of eligible environmental EU taxonomy activities covered corresponds to the economic activities listed in the European taxonomy to which the companies contribute. Identification is carried out during the activity screening phase as part of due diligence procedures during the investment phase.
· Impact data depends on the nature of the operations financed by the Green vertical. It consists of activity intensity data that tracks the effectiveness of the financed solutions. These metrics are derived from the company's activity data and revenue in thousands of euros.
These methodologies are applied consistently across the portfolio to ensure that the sustainability indicators directly reflect portfolio companies’ performance.
(h) Data Sources and processing
The data sources used to attain each of the environmental / social characteristics
The attainment of the E/S characteristics rely on materiality, measurability, data quality and availability.
This information is collected before each investment phase. The indicators are then monitored and updated at least annually through an ESG questionnaire circulated to portfolio companies.
Where relevant, publicly available reference datasets may complement these primary sources to ensure robust and transparent ESG reporting.
Measures taken to ensure data quality
Supporting documents are requested to verify certain claims, including code of conduct implementation, compliance policy with UNPRI and OECD Principles of Corporate Governance, stakeholder consultation reports, and GHG emission assessments.
Year-end quantitative data undergoes analytical review to document trends and significant events that occurred during the fiscal year and explain variations. When anomalies are identified, clarification requests are sent to the portfolio company management teams. Any at-risk data must be supported with evidence, which is then reviewed by our internal ESG expert.
For specific controls on sensitive indicators, we engage an external verifier with ESG expertise to assess results against benchmark and market practices.
How is data processed
The financial product will collect, consolidate, and manage ESG data through a dedicated digital ESG data management platform. This system will be supported by structured ESG questionnaires completed annually by portfolio companies.
The platform will serve as the central repository for all sustainability-related data, enabling the standardization of environmental and social metrics, facilitating validation processes, and ensuring a clear audit trail for SFDR disclosures. This approach enhances data integrity, transparency, and comparability across the portfolio.
The Portion of data estimated
The financial product relies primarily on measured operational data for its core environmental indicators. The fund prioritizes collecting data directly from portfolio companies. When data is unavailable, we rely on estimation processes or proxy data.
This estimate and sources are reviewed annually and may evolve over time as data availability and measurement practices improve.
(i) Limitations to methodologies and data
The financial product acknowledges certain limitations related to sustainability data and methodologies, including variations in reporting frequency, partial reliance on portfolio companies internal reporting process and surveillance mechanism, and the use of estimated values where direct measurements are unavailable (e.g., GHG emissions, waste, energy etc).
These limitations do not materially affect the attainment of the environmental and social characteristics promoted by the product, as core environmental indicators and impact KPIs are reviewed and challenged by the fund’s ESG expert. The main objective for portfolio companies is to improve the transparency and accuracy of calculated data each year with the help of the fund’s ESG expert.
To mitigate limitations, Sagona applies internal consistency checks, cross-references data with financial and business data to validate trends, and requests clarification from portfolio companies when discrepancies arise. Methodologies are reviewed periodically to reflect improvements in data availability and industry best practices.
(j) Due diligence
Sagona applies a structured due-diligence process prior to each investment to ensure that investments selected are aligned with the environmental and social characteristics promoted by the product, and that material risks that could undermine those characteristics are identified and addressed.
The Fund establishes a standard due diligence checklist covering financial, legal, product technical, and ESG dimensions for each deal. ESG criteria focus on identifying material sustainability risks. These risks are divided into standard risks (applicable to all investment targets) and theme-specific risks. This list is available in our sustainable risks policy with details on our risk identification and management methodology.
Following this analysis, the fund assesses the alignment of portfolio companies with the Fund's environmental and social characteristics with:
- Collection of information and documents through interviews with portfolio companies on economics and key ESG compliance aspects
- Review and discussion with our experts to validate critical areas. The fund has experts to cover the assessment of business, financial, and ESG criteria. For the most complex and high-risk matters, we engage external experts and technical specialists in law (tax, employment, and economic law), technology (patents and technological specifications), or ESG (risk assessment, performance, and compliance)
- The ESG analyst formalizes the analysis and consolidates findings into a dedicated section of the Investment Committee memo, summarizing key ESG risks, proposed mitigation actions, and any conditions precedent to investment approval.
- All due diligence documentation is stored in a central repository, with internal reviews or audits to confirm completeness, traceability, and consistency across all transactions.
(k) Engagement policies
Sagona applies an active engagement approach throughout the entire holding period of the company to ensure that investments remain aligned with the environmental and social characteristics promoted by the product, and that emerging risks that could undermine those characteristics are identified and addressed.
- Include ESG and compliance clauses in shareholder agreements, requiring adherence to the Fund's environmental and social characteristics.
- Conduct regular follow-ups with investees such as annual ESG questionnaires, biannual calls, or quarterly metrics collection to review risks and performance against agreed ESG metrics and identify areas for improvement.
- When ESG gaps or incidents are identified, the fund implements targeted engagement actions, such as requesting corrective plans, additional reporting, or technical improvements, to ensure alignment with the Fund's environmental and social characteristics.
- Document engagement outcomes and follow-up actions in a central ESG register which are directly shared with the portfolio companies and allow us to monitor the ESG actions to improve.
If material issue, incident, very low ESG performance or noncompliance with shareholder ESG agreements are identified escalation measures are implemented. It may include :
- Issuing formal written requests for remediation to portfolio companies
- Requiring corrective actions as part of shareholders agreement
- Limiting future investments in the portfolio company affected by an incident or in absence of mitigation measure
- Ultimately, considering exit from the capital in cases of proven serious risks of violations of human rights and labor rights, money laundering, corruption or fraud.
Portfolio managers are responsible for implementing our engagement procedures with portfolio companies, supported by the ESG expert. They are responsible for monitoring results and reporting all findings to the investment committee. In addition, Sagona obtains a board seat for each investment to participate in economic, financial, and ESG decision-making. As a significant stakeholder, the fund ensures complete management transparency and maintains ongoing dialogue with investees.
(l) Designated reference benchmark
No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by this financial product.