Yes, PSV cares about a conscious future. As a venture house, our mission is to clear the path for founders who build companies that matter. In doing so, considering the environmental, social, and governance externalities that arise from our business operations is an integral part of everything we do. We firmly believe that the integration of ESG helps generate long-term value, and ensure superior performance.

Our hybrid setup, comprising PSV Foundry, PSV Lab, and two unique venture funds, PSV Tech and PSV Hafnium, sets us free from adhering to a singular method. Rather we rethink existing ways and models to maximise our impact beyond any individual firm or investment. The following ESG policy covers all PSV entities, however does not include fund specific ESG, sustainability, and impact initiatives for the individual venture funds. For more information on how PSV Tech and PSV Hafnium integrate sustainability risks into their operations and investment decisions, please see the SFDR website disclosures.

Our view on ESG

Building the businesses of the future comes with great responsibility. At the core of how we work with “our” founders, is that we are damn curious about people and their ideas. We want to know and understand everything – from the big vision down to the nitty-gritty detail. We cannot emphasise enough how that reaches far beyond what can be measured in metrics and facts – not least when it comes down to helping our portfolio founders understand the main drivers of the positive and negative externalities their business will cause, and how it will change depending on the growth strategies they choose.

We think this is especially important in the pre-seed stage, where immediate impact might be limited, but where the core foundation and vision are shaped, which sets the direction for the long-term impact.

As investors, we act actively in urging founders to act with the same deep conviction to create a positive impact as to building a prosperous business – in other words thinking and acting ‘human first’.

Both in our portfolio and our contributions to the Danish tech and deeptech community, we aim to merge a mindset for hypergrowth with a mindful and sustainable approach to building businesses that contributes to the well-being and livelihood of humans.

The PSV approach to ESG

We integrate ESG in our operations across three layers; internally within PSV, in our investment process, and across our portfolios. Our hybrid set-up allows us to work with ESG from both a risk reducing and opportunity enhancing perspective, partnering with community stakeholders, and developing our own PSV ESG tools benefiting the ecosystem at large.

Internally within PSV

ESG is firmly embedded within PSVs internal operations. PSV Foundry, our evergreen investment arm that circulates returns to strengthen and give back to the ecosystem, allows the venture house to heavily invest in internal resources to strengthen our ESG capabilities.

At large, our internal focus emphasises that to support our founders in the best way possible, we need to have walked down the road ourselves. Furthermore, we recognise that investments often create a reinforcement cycle, where the importance of us, as a venture house, practising what we preach becomes incremental.

Our focus

That is why we, among other things, focus on
Promoting diversity, equity and inclusion: At PSV, we aim to build a strong and ambitious workforce, through attracting, motivating, and retaining a diverse group of people. We strive to create an open and transparent work environment, where equal opportunity is the foundation, inclusiveness is the tool, and diversity is the goal. In order to do so, we’ve developed and implemented a DE&I strategy, anchored in our DE&I policy. PSV annually tracks both gender diversity across all seniority levels and positions, as well as employee satisfaction and inclusiveness.

Measuring our carbon footprint: PSV is committed to lowering our environmental footprint. In order to do so, we’ve calculated our Scope 1, 2 and 3 GHG emissions (including financed emissions). Office initiatives have been taken to lower our footprint, including eliminating plastic water bottles, and waste management.

Engaging in partnerships: We can’t build a strong ecosystem on our own. This is why a cornerstone in our ESG efforts lies within supporting bright minds and community heroes on their mission to strengthen the Nordic tech scene. At PSV, we do so through selected partnerships with organisations and initiatives who drive an agenda we see as fundamental to finding and building the businesses of tomorrow. Such partnerships include, but are not limited to, TechBBQ – the largest tech summit in the Nordics, Diversity Commitment – a partner driven diversity commitment, Tech Nordic Advocates – a women-in-tech community and mentorship program, VentureESG – an organisation driving the adoption of ESG in the VC industry, and Invest for Impact Denmark – a national partnership that collectively contributes with experiences, skills, and ambitions across all impact actors in Denmark.

Co-founding initiatives: Our evergreen investment arm PSV Foundry allows us to found and support beyond the traditional VC boarders. Together with DTU (Technical University of Denmark), PSV has co-founded DTU EarthBound (now discontinued) a climate tech catalyst with the aim to spin out more climate technologies out of the university.

In our investment processes

Being at the center of what we do, integrating ESG into our investment process is essential. Assessing the ESG risks and opportunities of a potential investment does not only allows us to gain a proper understanding of the investee company, but also forms the basis for our post-investment support.

Exclusion list: PSV has an exclusion list, outlining industries and sectors in which we don’t engage. In addition, our PSV venture funds have individual exclusion lists, in agreement with their LPs.

Screening & Pitch: The investment team conducts high-level industry-related screening for ESG risks. In cases where such obvious risks appear, the PSV ESG team is opted in for a second opinion. If not, the PSV ESG team gets involved during the pitch to understand the business case and potential ESG implications.

Term sheet: The PSV term sheets include an ESG clause, outlining our expectations in terms of ESG engagement and reporting, to which the portfolio company agrees to adhere.

Due diligence: The PSV ESG team and/or fund partners conduct an ESG (and in some cases/funds – impact) focused meeting with the founders, during which industry and case-related material ESG matters are discussed from a risk-mitigation and opportunity-enhancing perspective. The aim of the meeting is to understand the material ESG matters of the company, the founders’ motivation and willingness to work with such, and align on PSV’s expectations going forward. Findings from the due dilligence are gathered in the ‘Investment Recommendation’ document, which is used as decision material for the investment team. If an affirmative investment decision is made, an ESG clause is included in the SHA. It outlines ESG sessions planned post-investment, which are designed based on the deep dive’s outcomes.

The process may differ slightly between the two PSV venture funds. For a more detailed description of how PSV Tech and PSV Hafnium integrate sustainability risks, please see SFDR website disclosures.

In our portfolios

As an early-stage investor, our largest externalities lie in the startups we find, develop, and support. At PSV, we believe that considering ESG externalities at the very early stages of building a company is key to ensuring the right set of foundations being embedded in the company’s core. We take it upon ourselves to support the founders in understanding and tackling the ESG whirlwind adapted to the stage in which they operate, actively urging founders to act with the same deep conviction to create a positive impact as to building a prosperous business – in other words thinking and acting ‘human first’.

Founder Toolbox: Our PSV team has spent the last two decades taking the startup journey with +450 startups. The early stage is our craft. With the benefit of experience, we’ve built a Founder Toolbox to help our founders anticipate and tackle the next pitfall or inflection point out on the horizon. The toolbox, among other things, includes our two PSV ESG tools, The ESG Napkin and ESG Sprint, as well as templates for ESG policies, DE&I strategies, and B Impact Assessment support.

The PSV ESG Napkin: Built on interviews with investors, founders and experts, we developed the ESG Napkin, an tailor-made inspirational ESG framework for early-stage tech founders on where to start, what to focus on, and why considering ESG is important. Find the full introduction to the Napkin here.

The PSV ESG Sprint: With the foundation in the ESG Napkin, we developed the ESG Sprint – a two hour workshop where the founders (together with us) sit down to lay out an ESG action plan. The workshop consists of 4 exercises with the aim to understand the company’s material ESG topics, and how to work with them going forward. Find the full introduction to the Sprint here.

Mental health: For many good reasons, startup founders suffer from psychological strains much more acutely than others. This doesn’t only threaten to erode their personal wellbeing, but also compromise the endeavors they dedicated their lives to build. That makes it both morally imperative and critical to the success of our portfolio companies that we support the mental health and personal growth of ‘our’ founders. At PSV, we have developed several initiatives to support our founders mental health, including our Founders Circles – a program where founders meet founders, facilitated by an external coach and business psychologist.

Monitoring diversity: As a part of our partnership with The Diversity Commitment, we annually track gender diversity across our portfolio companies, their management teams, and their boards.

PSVs commitment to ESG is a continuous process. We aim to improve across all three layers, developing and implementing new initiatives to ensure we, and our portfolio companies, scale with people and planet in mind.

Together, we can punch above our weight.

Sustainable Finance Disclosures Regulation (SFDR) website disclosures
Publication date: 20 June 2024
Version: 1.0
Last updated: 20 June 2024
Publication URL here

PSV Hafnium Management ApS, CVR-no. 43 10 74 88 (the “Management”) manages the alternative investment fund PSV Hafnium Fund I K/S, CVR-no. 43 11 15 31 (the “Fund”).

1. BASIC INFORMATION
1.1 Integration of sustainability risks in the investment decision-making process

1.1.1 A “Sustainability Risk” is an environmental, social or governance (“ESG”) event or situation which, if it occurs, could have an actual or potential material adverse impact on the value of an investment. A “Venture” is a private company that the Fund owns or aim at owning equity in. This Sustainability Risks Integration Policy (hereafter the “Policy”) sets out how the Management integrates Sustainability Risks in its investment decision-making process. The Policy applies to the financial products managed by Management with the purpose to ensure that the Management’s financial products are protected from or can cope with Sustainability Risks.

Awareness of Sustainability Risks is built into all of Management’s investment processes, from screening and due diligence of potential Ventures to governance and monitoring such Ventures. The integration of sustainability risks follows the investment process steps (see figure 1. ‘ESG & Impact investment process’ in section 1.1.1.):

– Initial screening
– Due Diligence
– Investment documents
– Monitoring & Reporting

Management looks at the Sustainability Risks that, if they occur, could cause a negative impact on the value of the investments of the Fund. The following risks are assessed to be the Sustainability Risks the Ventures are most exposed to:

• legislative changes;
• market risks, operational risks, liquidity risks
• employee health and safety hazards;
• integrity failures of leadership;

The likelihood of these Sustainability Risks occurring is assessed to be low.

In addition, and based on the assessment of relevant Sustainability Risks, Sector and Activity specific restrictions are further included in the Fund’s investment policy and outlined below under section (d) Investment Strategy.

During the due diligence and investment phase the Management identifies the Sustainability Risks and any additional, potential Sustainability Risks.
During the holding period, Management uses the result of such due diligence to ensure that the Sustainability Risks are continuously monitored, evaluated, mitigated, and reported. This ensures that Sustainability Risks are being handled and eventually minimized in the investment decision-making processes. This process is ensured and overseen by the general partners of the Management, and Management ensures that the Venture actively works with the identified Sustainability Risks, including that these are continuously monitored and assessed throughout the Fund’s holding period. If the Fund has a significant influence on the Venture’s governance, the Management ensures that the Fund exercises such influence at the board of directors of the Ventures.

1.2 Remuneration policies

The Management does not apply a remuneration policy in relation to the integration of Sustainability Risks.

2. ADDITIONAL INFORMATION FOR FUND MANAGERS MANAGING E/S PROMOTING FUNDS

(a) Summary

English:
The Fund promotes the following environmental and/or social characteristics: 1) reduction or reverse climate change, 2) reduction of energy consumption, 3) ensure sustainable use of resources and 4) improvement of quality of life. The Fund does not have sustainable investment as its objective, but it will have a minimum proportion of 65 % sustainable investments in economic activities with an environmental objective not qualifying as environmentally sustainable under the EU Taxonomy Regulation, which do not significantly harm other sustainable objectives and follow good governance practices.

The Fund will invest in early-stage technology companies within GreenTech, HealthTech and Industry 4.0 (“Sectors”) but outside certain prohibited sectors and activities (“Prohibited Sectors & Activities”).

The investment strategy consists of three binding elements used to select the company (“Venture”): 1) the Venture is within the Sectors, 2) the Venture is not operating within any of the Prohibited Sectors and activities and 3) the Venture reaches a score of ‘medium’ or ‘higher’ in the Fund Manager’s ‘ESG and Impact’ screening. While the Manager does not take into consideration the principal adverse impact of its investment decisions for Ventures that may qualify as a sustainable investment, relevant principal adverse sustainability impact indicators are considered when performing the ‘do not significantly harm’ test.

The due diligence phase is conducted through an ESG & Impact assessment of sustainability risks. Workshops will be carried out with the Ventures. On this basis it will be assessed whether the Ventures meet the “medium” or “higher” impact criteria and qualify as sustainable investments as well as an identification of Venture-specific KPIs and indicators. Good governance is assessed during the due diligence phase based on a set of governance questions, including board oversight, employee relationships, anti-bribery & corruption, financial & process control, tax control and IT safety & security.

The methodology used to measure the attainment of the social or environmental characteristics promoted is based on an ESG questionnaire including an assessment of product and operational impact as well as workshop with the Ventures. The environmental and/or social characteristics promoted by the Fund and the proportion of sustainable investments are monitored through access to Ventures and their data as well as through potential board seats.

The primary data source is quarterly and annual reporting from Ventures. The amount of reported data is expected to increase as the Ventures mature, however, initially a large proportion of data is expected to be estimated. The responsible investment manager and general partners will validate the data and if necessary third-party consultants will take part in the process.

Due to the early stage of the Ventures, measurement practices and methodologies are associated with limitations which will be addressed through ongoing actions such as regular review of methodologies to ensure the most up-to-date approach.

Risks are managed on an ongoing basis and in dialogue with the Ventures. The Fund and Management support and exercise potential influence on Ventures through their potential board seats.

No index has been designated as a reference benchmark.

Danish:
Fonden fremmer følgende miljømæssige og/eller sociale karakteristika: 1) reduktion eller vending af klimaændringer, 2) reduktion af energiforbruget, 3) sikre bæredygtig anvendelse af ressourcer og 4) forbedring af livskvaliteten. Fonden har ikke bæredygtig investering som sit mål men den vil have en minimumsandel på 65 % bæredygtige investeringer i økonomiske aktiviteter med et miljømål, men som ikke kan kvalificeres som miljømæssigt bæredygtige i henhold til taksonomiforordningen, og som ikke gør væsentlig skade på andre bæredygtige mål og følger god ledelsespraksis.

Fonden vil investere i teknologivirksomheder i det tidligere stadie indenfor GreenTech, HealthTech og Industry 4.0 (”Sektorer”) men udenfor visse ikke-tilladte sektorer og aktiviteter (”Ikke-tilladte sektorer og aktiviteter”).

Investeringsstrategien består af tre bindende elementer, der bruges til at udvælge virksomheden (”porteføljeselskab”): 1) porteføljeselskabet er indenfor Sektorerne, 2) porteføljeselskabet opererer ikke indenfor nogen af de Ikke-tilladte sektorer og aktiviteter og 3) porteføljeselskabet når en score på ”medium” eller ”højere” i Fondsforvalterens ’ESG and Impact’ screening. Mens Fondsforvalteren ikke tager hensyn til investeringsbeslutningernes vigtigste negative indvirkninger, vil Fondsforvalteren for investeringer, som kvalificeres som bæredygtige investeringer, tage i betragtning de relevante negative bæredygtighedsindikatorer som en del af ”ikke at gøre væsentlig skade”-testen.

Due diligence-fasen gennemføres gennem en ESG & Impact-vurdering af relevante bæredygtighedsrisici. Der vil blive gennemført workshops med porteføljeselskaberne. På den baggrund vil det blive vurderet, om porteføljeselskaberne opfylder kriterierne for ”medium” eller ”højere” impact og/eller kvalificerer sig som bæredygtige investeringer, ligesom porteføljeselskabs-specifikke KPI’er og indikatorer vil blive identificeret. God ledelsespraksis vurderes under due diligence-fasen på baggrund af en række spørgsmål relateret til ledelse, herunder bestyrelsestilsyn, medarbejderforhold, antibestikkelse og korruption, økonomi- og proceskontrol, skattekontrol og it-sikkerhed.

Den metode, der anvendes til at måle opnåelsen af de sociale eller miljømæssige karakteristika, der fremmes, er baseret på et ESG-spørgeskema samt en vurdering af porteføljeselskabets produkt- og driftsmæssige impact samt workshops med de pågældende porteføljeselskaber. De miljømæssige og/eller sociale karakteristika, som fonden fremmer, og andelen af bæredygtige investeringer monitoreres gennem adgang til porteføljeselskaberne og deres data såvel som gennem potentielle bestyrelsesposter.

Den primære datakilde er den kvartalsvise og årlige rapportering fra porteføljeselskaberne. Mængden af rapporteret data forventes at stige i takt med, at porteføljeselskaberne modnes, men indledningsvis forventes en stor mængde af data at være estimeret. De ansvarlige investment manager og general partner vil validere dataen, og om nødvendigt vil tredjepartskonsulenter tage del i processen.

Grundet porteføljeselskabernes tidlige modningsstadie vil de anvendte metodikker være forbundet med begrænsninger, som vil blive adresseret løbende, herunder ved regelmæssig gennemgang af de anvendte metoder med henblik på at sikre den mest optimale og i markedet anvendte tilgang.

Risici styres løbende og ved dialog med porteføljeselskaberne. Fonden og Fondsforvalteren støtter og udøver potentiel indflydelse over porteføljeselskaberne gennem deres potentielle bestyrelsesposter.

Der er ikke angivet et indeks som referencebenchmark.

(b) No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investments as its objective. The Fund will, however, have a minimum proportion of 65 % sustainable investments in economic activities with an environmental objective that do not qualify as environmentally sustainable under the EU Taxonomy Regulation.

The sustainable investments undertaken by the Fund will be analysed against the Fund’s ‘do not significantly harm’ criteria as an integrated part of the Fund’s investment process to ensure that they do not significantly harm any of the sustainable investment objectives. The ‘do not significantly harm’ criteria only apply to those investments underlying the Fund that are considered ‘sustainable investments’.

By their nature, all the Ventures are start-ups with limited revenues and market share, hence typically falling below the threshold for “significant harm” in their industry or geography. However, we actively screen ESG risk factors already during the initial screening and investment due diligence based on a questionnaire and workshop, that covers aspects of principal adverse sustainability impact indicators (PAI) and factor the results into our investment decision. We have also applied an exclusion list of areas where we do not invest at all (see Schedule 1 – negative list)

The Fund investment policy requires a screening where PAI indicators are considered during the investment process, as well as an ongoing monitoring of potential negative impacts during the holding period. For the investment focus of the Funds, often the climate-related indicators, such as the GHG emissions of a company or its products and services are relevant. Some other PAIs might not be applicable.

The Fund intends to follow the principles set out in the UN Global Compact Initiative and Principles for Responsible Investment (PRI); however not with respect to reporting obligations.

(c) Environmental or social characteristics of the Fund

The Fund promotes one or more of the following environmental and/or social characteristics:

a) reduction or reverse climate change (E)
b) reduction of energy consumption (E)
c) ensure sustainable use of resources (E)
d) improvement of quality of life (S)

(d) Investment strategy

The Fund will invest in early-stage technology companies within GreenTech, HealthTech and Industry 4.0 (“Sectors”). The Fund aims at investing in Ventures that have the potential to significantly provide a long-term financial return without compromising a sustainable planet. The Fund is prohibited from investing in the activities listed in schedule 1 (“Prohibited Sectors & Activities”). The binding elements of the investment strategy are:

1. The Venture is within the Sectors
2. The Venture is not operating within any of the Prohibited Sectors and activities
3. The Venture reaches a score of ‘medium’ or higher in the Fund Manager’s ‘ESG and Impact’ screening.

During the due diligence phase, Management identifies governance attributes such as the effectiveness of the Venture’s management body (its composition, governance, remuneration practices and oversight of the Venture’s operation), whether the Venture’s audit, risk, and compliance controls meet best practice standards, the Venture’s overall compliance with tax, anti-money laundering, anti-bribery and environmental standards and the Venture’s commitment to employment rights. Upon the identification of such governance attributes, Management carries out a ESG (‘Operational’) & Impact (‘Product’) workshop with the Venture where certain action points and KPIs are identified.

During the holding period, Management supports the Venture through personal and team profile (incl. leadership coaching and alignment) and provides support from specialists in the Fund’s advisory network where needed. Each Venture shall quarterly report on its governance practices including the action points and KPIs identified at the investment time and throughout the holding period. The Fund will use any position as board member to influence the Venture to ensure Good Governance practices are in place throughout the holding period.

(e) Proportion of investments

As described in the ‘Integration of sustainability risks in the investment decision-making process’ (section 1.1., figure 1), and ‘investment strategy’ section (section d), 100 % of the Fund’s investments should be ethical and comply with the binding elements of the investment strategy: (pass the negative list screening-questionnaire), be running responsibly (pass the ESG responsible screening-questionnaire with at least a “medium”, Operational), and make an impact (pass the Impact score screening-questionnaire with at least a “medium”, Product). At least 65 % of the Fund’s investments will be sustainable investments which contribute to at least one of the Climate Action & Environment Sustainability objectives (CA&ES).

The sustainable investments underlying the Fund shall contribute to at least one of the following environmental objectives:

1. Climate change mitigation;
2. Climate change adaptation;
3. The sustainable use and protection of water and marine resources;
4. The transition to a circular economy;
5. Pollution prevention and control;
6. Protection and restoration of biodiversity and ecosystems.

To contribute to at least one of the environmental objectives mentioned above, the Venture that is the subject of the investment must be either a) an enabling or supporting activity that allows the scaling of other green solutions, or b) it must have unique green aspects that result in a significantly reduced environmental footprint in at least one tier in the value chain as compared to the displaced alternative solutions.

By their nature, all the Ventures are start-ups with limited revenues and market share, hence typically falling under the threshold for “significant harm” in their industry or geography. However, we actively screen ESG risk factors already during the initial screening and investment due diligence based on a questionnaire and workshop, that covers aspects of principal adverse sustainability impact indicators (PAI) and factor the results into our investment decision. We have also applied an exclusion list of areas where we do not invest at all (see Schedule 1 – negative list)

The Fund’s investment policy requires a screening where PAI indicators are considered during the investment process, as well as an ongoing monitoring of potential negative impacts during the holding period. For the investment focus of the Funds, often the climate-related indicators, such as the GHG emissions of a company or its products and services are relevant. Some other PAIs might not be applicable.

The Fund intends to follow the principles set out in the UN Global Compact Initiative and Principles for Responsible Investment (PRI); however not with respect to reporting obligations.

(f) Monitoring of environmental or social characteristics

To monitor the environmental and/or social characteristics promoted by the Fund throughout the holding period and ensure the right proportion of sustainable investments, the Fund requires access to the Ventures, including to relevant data. Such access is enforced through the legal documentation governing the Fund’s investment and shareholding in the Venture. Further, the Fund will be able to monitor the Venture through its board seats whenever the Fund holds such.

The Fund requires each Venture to annually complete a questionnaire to ensure that the Venture continues to be within the relevant Sector and is not in a Prohibited Sector/Activity. The Ventures will in addition be obligated to report on individual KPI’s that ensures that they meet the investment criteria set by the Fund, on an ongoing basis. Based on the Venture’s performance, the Fund may provide resources to support execution of the agreed KPI’s and/or ESG action plan to help the Venture.

(g) Methodologies

Please see figure 1. ‘ESG & Impact investment process’ in section 1.1.1. where the Fund’s investment process and methodology are described. The questions included in the ESG questionnaire are tailored to the specific environmental and/or social characteristics that the Venture is deemed able to help promote and the maturity of the Venture.

For Product Impact, the focus is to assess the impact of the Venture’s product by:

1. Conducting a preliminary high-level impact business case, forecasting impact potential.
2. Assess whether the Venture is positioned as a better environmental option compared to displaced alternatives.
3. Do no significant harm to other environmental objectives.
4. Assess compliance with Good Governance practices.
5. Assess contribution to at least one of the Sustainable Development Goals (SDGs).

In certain cases, the Fund uses external consultants to investigate key ESG & Impact issues/concerns related to the Venture.

For Operational Impact, the focus is on the operational impact of the Venture, examining through the lens of environmental, social and governance factors, including:

• Assess intentional ESG commitment by the Venture and its Management team
• Identify a short-list of material ESG issues (“areas of inquiries”) and make a ESG action plan to address potential risk and leverage opportunities; The Venture may use our own developed ESG Napkin & Sprint.

The Management takes the two steps above into a workshop with the Venture to collectively agree on the high-level impact business case, identify supporting SDGs, identify contributions to environmental and/or social characteristics, get clear on ESG & Impact value proposition, material ESG issues and leverage opportunities, agree on potential targets and KPIs, and not least make sure the Ventures are mature to follow the potential actions.

Based on these steps, Management will assess whether the Venture is able to meet the ‘medium’ or higher impact criteria, including if the Venture qualifies as a sustainable investment.

Based on the assessment, KPIs are identified and each KPI will be specific for the Venture taking its maturity, industry, the environmental and/or social characteristics it promotes, and the indicator used to measure the attainment of that characteristic(s) into consideration. The level of KPIs will be adjusted as the Venture develops and matures. Examples of which indicators that could be used to measure the attainment of which E/S characteristics:

Promoted characteristics Indicator Chosen KPIs to track (examples)
Enviromental Energy Consumption (if > 20 FTE’s) Percentage of Renewable Energy Consumption
Enviromental CO₂-emissions (if > 20 FTE’s) Reduction in carbon intensity per unit of production or service
Health Good health and well-being (if > 20 FTE’s) Reduction time for patients in hospital

During the holding period, the Management measures each Venture’s progress in achieving the KPIs and will together with the Venture set new KPIs throughout the holding period as the Venture matures. The Venture will become legally committed to fulfilling and reporting on the relevant KPIs.

(h) Data sources and processing

The data sources used the measure the attainment of the environmental and/or social characteristics are primarily the data directly provided by each Venture through quarterly and annual reporting. As the Fund invests in early-stage companies a large proportion of the data is expected to be estimated. It is expected that the proportion of reported data will increase as the Ventures matures. If necessary, third-party consultants and external control mechanisms will be employed to enhance the robustness of our data evaluation processes. The partner responsible for the investments case are responsible for validating the data from the Venture, together with the general partners.

(i) Limitations to methodologies and data

As the Fund invests in early-stage companies, there are limited practice and methodologies for how to best measure impact and the attainment of the environmental and/or social characteristics promoted by the Fund. As such, the Fund has implemented its own developed ESG & Impact process to measure the impact of the Ventures.

The methodologies referred to in (g) methodologies and data sources referred to in (h) Data sources and processing above only provide a snapshot as projections into the future will always carry uncertainty.

Ongoing actions will be taken to address such limitations: The Fund will regularly review the methodologies and data used to assess the attainment of the environmental and/or social characteristics to ensure the most up-to-date approach possible. When severe limitations are identified, actions will be taken to overcome them.

(j) Due Diligence

The Fund look at Sustainability Risk using the ‘ESG & Impact investment process’ in section 1.1.1. and the section (g) methodologies where the Fund’s investment process and methodologies are described.

During the due diligence phase, the partner responsible for the investment case, do the ESG & Impact assessment as part of the overall investment summary.

The partner responsible for the investment case does the ‘Impact Business Case’ and the ‘ESG Assessment’ in a workshop with the Venture to collectively agree: on the high-level impact business case, identified supporting SDGs, identified contributions to a sustainable objective, get clear on ESG & Impact value proposition, material ESG issues and leverage opportunities, agree on potential targets and KPIs, and not least make sure the Ventures are mature to follow the potential actions.

Based on the results of the workshop, the partner responsible for the investments case will either take additional actions, which could include additional ESG risk reviews internally or by external experts, or finalize the ESG & Impact assessment, including recommendations for improvements, as part of the due diligence. All general partners of the Fund are a part of the process and give input to the assessment.

Based on these steps, Management will assess whether the Venture is able to meet the ‘medium’ or ‘higher’ impact criteria, and identify if the Venture will be a sustainable investment that complies with at least one of the Climate Action & Environment Sustainability objectives (CA&ES) (“GreenTech”).

Based on the assessment, KPIs are identified and each KPI will be specific for the Venture taking its maturity, industry, the environmental and/or social characteristics it promotes, and the indicator used to measure the attainment of that characteristic(s) into consideration.

We assess good governance during the due diligence phase based on a set of governance questions, including board oversight, employee relationships, anti-bribery & corruption, financial & process control, tax control and IT safety & security. Based on the results of the test, we decide if the bar for good governance is met and set targets to (further) improve good governance standards during our holding period.

(k) Engagement policies

The Management ensures on an ongoing basis and in close dialogue with the Ventures that risks are managed properly. In such cases, the Fund may apply appropriate mitigation measures, including but not limited to e.g. implementing new processes and offering training for the Ventures to support their capacity to control, mitigate and/or reduce such risks.

As an active investor, the Fund helps Ventures mature on their impact and ESG journey, e.g. assistance in developing relevant policies, codes of conduct, processes, reporting, calculating impact, and life cycle assessment (LCAs). Where the Fund has a significant influence on the Venture’s structure and governance it will exercise such influence via the board of directors of the Venture ensuring that ESG, impacts, and risks are on the board agenda and are a continued focus of the Venture.

In the unexpected event of an impact or ESG incident, the Fund will always engage in dialogue with the Venture and ask them to mitigate in dialogue with the affected stakeholders.

(l) Designated reference benchmark

Given that there is no relevant benchmark index for early-stage businesses, an index has not been designated as a reference benchmark.

SCHEDULE 1 – NEGATIVE LIST
Negative list The Fund shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities, which have:

(i) activities being illegal in the jurisdiction where such activities take place;

(ii) activities or persons (physical or legal) that are subject to or is managed or otherwise affiliated with persons that are subject to restrictive measures (sanctions) imposed by the United Nations, the European Union or Denmark from time to time;

(iii) the cloning of human beings for reproductive purposes;

(iv) manufacture, sale and/or storage of UN defined unconventional weapons; however the fund may invest in defence technology companies;

(v) activities within pornography; or which can be associated with prostitution;

(vi) fishing activities and/or fishing gear such as bottom trawling, beam trawling, spinning rods and dredges etc., which levels out the sea floor, disrupts the biodiversity and risks bycatching other species; and/or

(vii) activities within fossil raw materials including fossil fueled power plants as well as activities which have drilling, investigations, extractions, refining and sale of crude oil, natural gas and thermal coal or storage of fossil fuels and the underlying infrastructure (pipelines etc.) as its purpose.

(viii) economic activity involving a significant negative impact on primary forest cover;

(ix) economic activity involving a significant negative impact on biodiversity;

(x) economic activity involving a significant negative impact on ecosystem services;

(xi) economic activity resulting in significant pollution of land, water, or air;

(xii) economic activity resulting in significant land degradation;

(xiii) economic activity resulting in significant resource depletion;

(xiv) economic activity involving products categorised as tobacco by the Danish Health Authority;

(xv) activities within artic drilling in relation to the extraction of fossil fuels;

(xvi) activities involving highly polluting extraction methods, such as the extraction of oil from tar sand;

(xvii) activities involving exploitation of disadvantaged social groups, for instance through the use of deceptive or exploitative subscription services;

(xviii) activities enabling illegal access to electronic data networks or illegal downloading of electronic data;
(xix) activities within gambling;

(xx) illegal activities.

Furthermore, the Fund will not make any investments in a company that, to the best of our knowledge, at the time of investment:

(xxi) counteracts the transition to an economy based on renewable energy resources;

(xxii) as the primary business has activities that are based on the use of fossil fuels or fossil fuel related activities;

(xxiii) violates human rights conventions.

(xxiv) exploits disadvantaged social groups, e.g., using deceptive or exploitative subscription services; or

(xxv) has activities which are primarily of a speculative nature, including speculation related to tax matters, counteracts the transition to an economy based on renewable energy resources, engages in activities in which 90% or more of the primary business activities are based on the use of coal or coal related activities, engages in activities which has a substantial negative impact on the local society, people or the environment, engages in activities which violates human rights conventions, or is domiciled in a jurisdiction subject to trade embargoes imposed by the United Nations or the European Union from time to time.

In addition, the Fund will not invest in a company that, to the best of our knowledge, knowingly engage, directly or indirectly, in aggressive tax planning as defined by the EU and OECD which e.g. means doing any of the following:

(xxvi) abuse of double taxation treaties, where holding companies which do not have sufficient substance in line with the OECD Principal Purpose Test, are used for the sole purpose of reducing or avoiding withholding tax,
(xxvii) use of transfer pricing planning where risk and income are systematically shifted to low-tax countries

(xxviii) use of financial instruments for aggressive tax planning

(xxix) use of hybrid companies for aggressive tax planning

(xxx) use of highly leveraged acquisition structures in jurisdictions without general interest limitation rules in line with OECD/US principles with the aim of reducing taxable income, not in line with international market standards.

We refrain from investing in companies that engage in tax evasion of any kind.

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This document contains key information about the PSV Hafnium investment product. The document does not serve any marketing purposes. The information is required by legislation to help anyone understand the type of investment product and compare it to other products.

Download the document here

PreSeed Ventures Management Tech Fund I ApS, CVR-no. 41 39 83 02 has PreSeed Ventures Tech Fund I K/S, CVR-no. 41 44 50 41 under management as an alternative investment fund (“PSV Tech”).

Integration of sustainability risks in the investment decision-making process

A “sustainability risk” refers to 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.
When making investments, consider the ethical, environmental, and societal consequences of such investments.
We are not philanthropists, nor are we merely cynical investors. We believe that now more than ever, sustainable and conscious businesses will lead the way in solving the greatest global problems of tomorrow, and hence we are naturally devoting more and more attention in terms of our investment practices on startups with a clear and positive impact.
We adhere to the Six Principles of Responsible Investment (PRI) which is formulated by United Nations. Read more about the PRI, the principles, and the objectives for responsible investment activities here.
The principles form the basis on which we seek to enhance our investment activities. The increased amount of focus on responsible and conscious practices shines through in every step of our investment funnel – from the very early screening of potential investment cases until the ink on the term sheet is dry (and beyond but we address this later). Let’s start from the top.

Early screening and assessment

A fundamental part of every VC’s investment practices is located in the early sourcing and screening of startups. Every year we screen hundreds of startups in the pursuit of identifying the most promising Danish tech-startups. In this process, we have implemented specific initiatives that will help us take a 360° view of the potential investment case and make sure that no stone is unturned – also when it comes to ESG considerations.

ESG in Due Diligence

An integral part of our investment process is of course conducting thorough due diligence, which also includes investigating the positive and potential negative impact of the investment.

We hold ourselves accountable to the highest standards and PSVTech is proud to have Limited Partners as ATP and EIFO that we know do the same. Initially, that means eliminating all businesses in verticals like selling weapons, pornography, or in any way violating human rights – just to name a few (see the full Negative Investment Criteria list here).

In due diligence, all startups are as well evaluated based on our own ESG checklist (see the full checklist for PSVTech here).

In this process, the ESG assessment is an integrated part of our pre-investment due diligence and our Investment Recommendation. Each case is screened based on impact intentionality and contribution, as well as ESG risks and opportunities. Some of the ‘Human first’ parameters we look for when evaluating the potential investment are diversity in the founder team, the mental resilience of the team and the ethics of their work culture, strong data ethics and practices complying with legislation, UX and product design for low environmental impact, diversity, inclusion and so on (Humane technology).

We furthermore look into the legal and financial compliance. We impose strong demands and ask for founder warranties when it comes to tax matters, ensuring that all our portfolio companies comply with and pay their taxes in Denmark in a responsible way.

Deep-diving into ESG as an investment theme

We do not only assess investments based on ‘Human first’ parameters, it is also a separate theme of our investment thesis. This is part of our hypothesize about high-potential technological trends and key drivers within specific verticals.
Methodologically zooming in on specific verticals allows us to promote the tech startups that will become the next front runners of conscious, sustainable business models.

There are four core reasons for integrating the ESG framework into our investment thesis:

• It is vital to mitigating risk in the investment. Companies who neglect to consider ESG risks are more vulnerable to regulation and legislation.
• Consumers are increasingly concerned with the social and environmental impact of brands, therefore there is huge commercial potential in working strategically with the ESG parameters.
• It is easier to both attract, motivate and retain the best talents to companies taking responsibility for the people and the planet.
• By developing technologies and companies that help humanity face some of the biggest global challenges, founders are tapping into the biggest business potentials and have the opportunity to build defendable, future-proof category winners.
  Some of the technologies that are already tapping into these possibilities are:
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  • Software enabling the transition to renewable energy
  • Vertical farming
  • Fighting climate change and CO2 emissions
  • Democratizing financial opportunities
  • Waste management
  • Digital health to empower everyone to take ownership of their wellbeing

No consideration of sustainability adverse impacts

PSV Management Tech Fund I ApS is to the largest extent possible considering the sustainability risks in its investment decisions.

However, PSV Management Tech Fund I ApS does not consider all of the specific adverse impact indicators as set forth in Table 1-3 of Annex 1 of the Commission’s delegated regulation supplementing Regulation (EU) 2019/2088 (the Sustainable Finance Disclosure Regulation) in its investment decisions. It simply does not make any sense for PSV Management Tech Fund I ApS and the Investment Team of PSV Tech to assess and track the listed factors when investing in tech startups in the pre-seed stage. As provided for in this ESG policy, PSV Management Tech Fund I ApS has taken appropriate steps towards ensuring sustainability in the investments, including the conduction of ESG Due Diligence, filling out a ESG Compliance checklist as well as a ESG napkin.

Remuneration policies

Members of the Investment Team who assess and recommend potential investments on behalf of PSV Tech do and will not receive bonus or additional remuneration to their base salary if they propose investments that are not ESG-compliant. In the same vein, the members of the Investment Team do not obtain any financial or economic benefit if non-ESG-compliant investments are conducted or suggested.
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Accordingly, the remuneration policy of PSV Tech is structured in a way that it does not encourage excessive risk-taking with respect to sustainability risks.
The Investment Team and the management of PSV Tech will soon discuss how the investment team can on the contrary be economically awarded for carrying out ESG-compliant investments.

PreSeed Ventures Management Tech Fund I ApS, CVR-no. 41 39 83 02 has PreSeed Ventures Tech Fund I K/S, CVR-no. 41445041, under management as an alternative investment fund (PSV Tech).

PSV Tech complies with all national as well as EU legislation and best practice guidelines, including OECD-guidelines.

We abide by all local and federal laws in order to be as financially responsible and sustainable as possible. Accordingly, PSV Tech is registered with the Danish Financial Authorities and operates in accordance with the FAIF-regulation applicable. Read our PRIIP Information Document here (in Danish).

Furthermore, PSV Tech has conducted thorough KYC/AML investigations on all limited partners and ultimate owners of limited partners in PSV Tech to secure, that no limited partner of PSV Tech is violating EU-regulation on money laundering or financing of terrorism. PSV Tech has additionally assessed and confirmed that none of its limited partners knowingly engage, directly or indirectly, in aggressive tax planning as defined by the EU and OECD.

PSV TECH ll SFDR
Sustainability-related Disclosure (SFDR) – Website disclosures

Publication date: 31.03.2025
Version: 1.0
Publication URL: https://psv.xyz/psv-tech02-sustainability-related-disclosures
Fund Manager: PSV Tech Management ApS, CVR-no: 41 39 83 02
Financial Product: PSV Tech Fund II K/S, CVR-no: 45 18 47 49 (the “Fund”)

BASIC INFORMATION

Integration of sustainability risks in the investment decision-making process

The Fund Manager follows a responsible investment strategy when making investments for and on behalf of the Fund. By doing so, the Fund Manager seeks to capture and identify responsible businesses and mitigate any sustainability risks. A “Sustainability Risk” refers to an environmental, social or governance (“ESG”) event or situation which, if it occurs, could have an actual or potential material adverse impact on the value of an investment.

Awareness of Sustainability Risks is systematically integrated into all stages of the Fund Manager’s investment decision-making processes, from screening and due diligence of potential target companies to governance and monitoring of portfolio companies. More specifically, the integration of Sustainability Risks is carried out through the following measures and, thus, reflected in the Fund’s investment decisions:

• Screening potential investments against environmental, social, and governance (ESG) criteria
• Conducting thorough ESG due diligence on all potential investments
• Incorporating ESG considerations into investment recommendations and decision-making-processes
• Regular portfolio reviews
• Annual monitoring and reporting

The Fund Manager has looked at the Sustainability Risks that, if they occur, could cause a negative impact on the value of the investment. The following risks are assessed to be the Sustainability Risks that portfolio companies are most exposed to:

• data breaches,
• legislative changes,
• employee health and safety hazards,
• diversity and integrity failures of leadership;

The likelihood of these Sustainability Risks occurring and materializing is assessed as low, however, effectively managing these risks is vital for achieving sustainable long-term risk-adjusted returns.

In addition, and based on the assessment of relevant Sustainability Risks, sector specific restrictions are further included in the Fund’s investment policy and outlined below under the section (d) Investment Strategy.

During the due diligence and investment phase, in addition to ensuring that the investment is not within any of the restricted sectors, the Fund Manager identifies the Sustainability Risks set out above and any additional, potential Sustainability Risks.

Throughout the holding period, the Fund continuously evaluates, mitigates, and reports on Sustainability Risks. The results of ESG due diligence are used to monitor and address risks as they arise. This ensures that Sustainability Risks are being handled and eventually are minimized in the investment decision-making process. This process is ensured and overseen by the general partners of the Fund Manager. Further, the Fund Manager ensures that the portfolio company actively works with the identified Sustainability Risks and ensures that even after the investment, the Sustainability Risks are continuously monitored and assessed. In cases where the Fund holds significant influence over a portfolio company’s governance, the Fund ensures that this influence is exercised effectively, particularly at the portfolio company’s board level.

Remuneration policies
The Fund Manager does not have a remuneration policy, and the Fund Manager’s remuneration structures are not linked to the integration of Sustainability Risks. Thus, they are not structured to the effect that they encourage excessive risk taking with respect to Sustainability Risks.

ADDITIONAL INFORMATION FOR FUND MANAGERS MANAGING E/S PROMOTING FUNDS

a. Summary

English:
The Fund promotes the following environmental and/or social characteristics; 1) futureproofing planet earth (environment), 2) trust in technology, and 3) health & wellbeing through investments in early-stage technology companies. It does not have sustainable investment as its objective.

The Fund invests in early stage, i.e. pre-seed and seed portfolio companies from all sectors with innovation capacity and growth potential with a focus on investments in tech enabled companies (“Sectors”) but outside certain prohibited sectors and activities (“Prohibited Sectors & Activities”). The investment strategy is industry agnostic, with particular emphasis on companies in Denmark and the Nordics.

The investment strategy consists of a tailored four-step approach for assessing potential portfolio companies: 1) negative screening, 2) ESG risk and opportunities screening, 3) impact screening, and 4) alignment with the environmental and/or social characteristics of the Fund, while also ensuring that portfolio companies adhere to responsible business practices and good governance standards. On this basis, four binding elements are defined and used to select investments. Further, good governance practices are an integrated part of the Fund’s investment strategy during both the due diligence and holding phase. Thus, the Fund actively seeks investments that address at least one of the United Nations Sustainable Development Goals (SDGs).

The Fund will use best efforts to make at least 50% of the Funds venture investments – (based on the number of investments and monitored upon the expiry of the investment period), with venture investments, according to the Fund, meaning investments where the aggregated invested amount is above DKK 5 million – in portfolio companies meeting the environmental and/or social characteristics promoted by the Fund. The remaining investments will be in tech enabled companies that pass the negative screening test, operate in accordance with responsible business practices, but are not eligible to meet the other binding elements of the investment strategy.

The environmental and/or social characteristics promoted by the Fund – and the sustainability indicators used to measure the attainment of these characteristics – are monitored through access to portfolio companies and their data as well as potential influence on the portfolio companies. The portfolio companies are subject to reporting obligations as a part of the Fund’s annual ESG questionnaire.

To be eligible for investment, portfolio companies must pass two key screenings: 1) Negative screening and 2) ESG risk and opportunities screening. To qualify as an impact startup, i.e. E/S promoting case, that helps promote at least one of the environmental and/or social characteristics promoted by the Fund, the portfolio company must also pass the 3) impact screening test, and 4) demonstrate alignment with the Fund’s specific environmental or social characteristics and show a strong ‘impact interlock’—meaning that impact scales proportionally as the portfolio company grows. Also, company-specific KPIs for environmental and/or social characteristics are identified.

The primary data source is portfolio companies and their yearly reporting. Data quality is ensured through internal review, and if necessary, external review or verification will be carried out. The amount of reported data is expected to increase as the portfolio companies mature, however, initially a large proportion of data is expected to be estimated.

Due to the nature of early stage investing, measurement practices, methodologies and data sources are subject to certain limitations. These limitations will be addressed through ongoing actions such as regular review of methodologies to ensure the most up-to-date approach.

The due diligence carried out includes various steps from consideration of ESG and impact factors to assessments of good governance, risks and contribution to the environmental and/or social characteristics.

Where the Fund has substantial influence on a portfolio company, this influence is exercised at the board level to ensure that ESG priorities, and impact priorities where relevant, are incorporated into the agenda of board meetings.

The Fund does not use an index as a reference benchmark.

Danish:
Fonden fremmer følgende miljømæssige og/eller sociale karakteristika: 1) fremtidssikring af planeten Jorden (miljø), 2) tillid til teknologi, og 3) sundhed og velvære gennem investeringer i teknologi-startups i tidlig fase. Fonden har ikke bæredygtig investering som sit mål.

Fonden investerer i tidlige faser, dvs. pre-seed og seed porteføljeselskaber fra alle sektorer med innovationskapacitet og vækstpotentiale, med fokus på investeringer i teknologidrevne virksomheder (“Sektorer”), men uden for visse forbudte sektorer og aktiviteter (“Ikke-tilladte Sektorer & Aktiviteter”). Investeringsstrategien er sektoragnostisk med særlig vægt på virksomheder i Danmark og Norden.

Investeringsstrategien består af en skræddersyet firetrins tilgang til vurdering af potentielle porteføljeselskaber: 1) negativ screening, 2) ESG-risiko- og muligheder screening, 3) impact screening, og 4) overensstemmelse med fondens miljømæssige og/eller sociale karakteristika, samtidig med at det sikres, at porteføljeselskaberne følger ansvarlige forretningspraksisser og god ledelsespraksis-standarder. På denne baggrund defineres og anvendes fire bindende elementer til udvælgelse af investeringer. Derudover er god ledelsespraksis en integreret del af fondens investeringsstrategi både under due diligence- og ejerskabsfasen. Fonden søger aktivt investeringer, der adresserer mindst ét af FN’s verdensmål (SDG’er).

Fonden vil bestræbe sig på at sikre, at mindst 50 % af fondens ventureinvesteringer – (baseret på antallet af investeringer og monitoreret ved udløbet af investeringsperioden), hvor ventureinvesteringer ifølge fonden betyder investeringer, hvor den samlede investerede sum er over DKK 5 millioner – går til porteføljeselskaber, der opfylder de miljømæssige og/eller sociale karakteristika, som fonden fremmer. De resterende investeringer vil være i teknologidrevne virksomheder, der består negativ screening-testen, opererer i overensstemmelse med ansvarlige forretningspraksisser, men som ikke er berettigede til at opfylde de øvrige bindende elementer i investeringsstrategien.

De miljømæssige og/eller sociale karakteristika, som fonden fremmer – og de bæredygtighedsindikatorer, der bruges til at måle opnåelsen af disse karakteristika – overvåges gennem adgang til porteføljeselskaberne og deres data samt potentiel indflydelse på porteføljeselskaberne. Porteføljeselskaberne er underlagt rapporteringsforpligtelser som en del af fondens årlige ESG-spørgeskema.

For at være berettiget til en investering skal porteføljeselskaberne bestå to nøglescreenings: 1) negativ screening og 2) ESG-risiko- og muligheder screening. For at kvalificere sig som en impact startup, dvs. en E/S fremmende investering, der hjælper med at fremme mindst ét af de miljømæssige og/eller sociale karakteristika, som fonden fremmer, skal porteføljeselskabet også bestå 3) impact screening-testen og 4) demonstrere overensstemmelse med fondens specifikke miljømæssige eller sociale karakteristika og vise en stærk ‘impact interlock’ – hvilket betyder, at impact skalerer proportionelt, når porteføljeselskabet vokser. Derudover identificeres virksomhedsspecifikke KPI’er for miljømæssige og/eller sociale karakteristika.

Den primære datakilde er porteføljeselskaberne og deres årlige rapportering. Datakvaliteten sikres gennem intern gennemgang, og hvis nødvendigt vil ekstern gennemgang eller verifikation blive gennemført. Mængden af rapporterede data forventes at stige, efterhånden som porteføljeselskaberne modnes. Dog forventes en stor del af dataene i starten at være estimerede.

På grund af den tidlige fase af investeringer er målingspraksisser, metoder og datakilder underlagt visse begrænsninger. Disse begrænsninger vil blive adresseret gennem løbende handlinger, såsom regelmæssig gennemgang af metoder for at sikre den mest opdaterede tilgang.

Due diligence, der gennemføres, omfatter flere trin fra overvejelse af ESG- og impact-faktorer til vurdering af god ledelsespraksis, risici og bidrag til de miljømæssige og/eller sociale karakteristika.

Hvor fonden har væsentlig indflydelse på et porteføljeselskab, udøves denne indflydelse på bestyrelsesniveau for at sikre, at ESG-prioriteter og impact-prioriteter, hvor relevant, indgår på dagsordenen for bestyrelsesmøder.

Fonden bruger ikke et indeks som referencebenchmark.

b. No sustainable investment objective

The Fund promotes environmental and social characteristics but does not have as its objective sustainable investment.

c. Environmental and social characteristics of the Fund

The Fund promotes one or more of the following environmental and/or social characteristics:

1. Futureproofing planet earth (environment): The planet is facing an existential environmental crisis. Climate change, loss of natural resources, and biodiversity harm are all major issues that need to be addressed. Thus, the Fund may e.g. invest in enabled solutions that support the path towards net zero emissions, allows for resilient planetary systems, and can help adapt the societies to the energy transition needed to futureproof planet earth.
2. Trust in Technology (social): Technology advancement, AI agents, artificial general intelligence (AGI) and digitalization gives rise to new, global challenges, while also being the key to better and more efficient ways to solve the current ones. The Fund may e.g. invest in solutions that enable a safe life online, secure data, transparency, reduce inequalities, increase information verification, mitigate technological bias and actively promote sustainable, efficient, and a secure digital future.
3. Health & Wellbeing (social): Changing demographics calls for a fundamental shift in our healthcare system. Through technology, treatment accuracy and efficiency, preventative care and personalisation can improve health and lessen the pressure and cost of existing treatment models. The Fund may invest in companies allowing for such transformational shift, improving health and well-being globally e.g. solutions that can reinvigorate drug development, prevent and diagnose disease sooner, automate administrative workloads, and enable personalised care.

d. Investment strategy

The purpose of the Fund is to build, hold, and manage (including to divest) a portfolio of equity and equity-related investments in portfolio companies. Thereby, the Fund invests in early stage, i.e. pre-seed and seed portfolio companies from all sectors with innovation capacity and growth potential with a focus on investments in tech enabled companies (“Sectors”). The investment strategy is industry agnostic, with particular emphasis on companies in the Nordics and is closely aligned with the Funds overall ESG and impact approach.

As an early-stage investor, the Fund partners with portfolio companies at the very beginning of their journey. The Fund engages with the portfolio companies’ founders to set intentions to promote environmental and/or social characteristics. The Fund places emphasis on the founders’ intention to solve a specific environmental and/or social issue prior to making an investment decision.

The Fund is bound by the investment restrictions and limitations set out in the Fund’s limited partnership agreement and shall procure that such requirements, restrictions, and limitations are complied with at all times.

The Fund follows a four-step approach for assessing all potential portfolio companies. Thus, to be eligible for an investment, the potential portfolio companies need to pass the 1) negative screening and 2) ESG risk and opportunities screening. To be an impact startup i.e. E/S promoting company and, thus, to qualify as an investment that helps attain the environmental and/or social characteristics of the Fund, the potential portfolio company must in addition pass the 3) impact screening test and 4) align with the environmental and/or social characteristics of the Fund.

The Funds four-step approach for assessing the potential portfolio companies are as follows:

1. Negative Screening (Exclusion List)
As part of the Funds deal sourcing strategy, the Fund Manager begin by conducting an initial review to determine whether a potential investment aligns with the Fund’s investment criteria and whether it conflicts with the Funds exclusion list, cf. Appendix 1 (“Prohibited Sectors & Activities”). Companies within the Prohibited Sectors and Activities are not considered further.

2. ESG risk and opportunities screening

During the pre-investment phase, the Fund Manager also evaluates potential investments through both an industry-wide and case-specific lens to identify ESG risks and opportunities. For the industry-level assessment, the Fund Manager use recognized frameworks such as the SASB (IFRS Foundation) Materiality Map, the VentureESG materiality tool, and the SDGs. For the case-specific evaluation, the Fund Manager gathers information from pitch decks, presentations, discussions with industry experts, and meetings with potential customers, stakeholders affected and the management/founder team to assess the unique ESG risks and opportunities.

Good governance practices are assessed during the due diligence phase based on a set of governance questions, including board oversight, employee relationships, personality traits, anti-bribery & corruption, financial & process control, tax control and IT safety & security.

To support the Funds ESG risk and opportunities screening, the Fund Manager has developed its own tools – the ESG Napkin and ESG Sprint – which take a materiality assessment approach. The ESG Napkin provides a quick, high-level overview of key ESG factors relevant to each investment at different stages, while the ESG Sprint is a more in-depth, process-driven workshop that engages the portfolio company’s founder(s) in identifying and addressing material ESG risks and opportunities. The Fund Manager uses these tools in combination with the latest industry frameworks, applying them on a case-by-case basis, as ESG risks and opportunities vary significantly depending on the stage of the portfolio company and the industry in which it operates.

3. Impact screening
In line with the Funds commitment to achieving the environmental and/or social characteristics promoted by the Fund, the Fund Manager actively seek investments that meet the environmental and/or social characteristics promoted by the Fund and thereby qualify as impact startups in alignment with the Funds investment strategy.

An impact startup, as defined by the Fund, demonstrates a strong intention to generate positive and measurable social and/or environmental impact alongside financial growth. These companies should address at least one of the SDGs and be committed to creating value that benefits society and the environment. The Fund Manager place significant importance on the interlock between impact and the portfolio company’s business model – ensuring that impact scales in proportion to the portfolio company’s growth.

To assess this, the Fund applies an “Impact Framework” to the due diligence process. Where the ESG Sprint is process driven and focuses on the “how” – the internal principles, processes, and practices that guide the portfolio company’s operations, the Impact Framework is outcome driven and focuses on the “what” – the actual positive social or environmental outcomes of the portfolio company’s operations or behavior. These two components are complementary, as the Fund Manager believes strong ESG practices are essential for achieving meaningful impact.

4. Alignment with the environmental and/or social characteristics of the Fund
Additionally, to be considered as an impact startup, the portfolio company must demonstrate alignment with the Fund’s specific environmental or social characteristics and show a strong ‘impact interlock’—meaning that impact scales proportionally as the portfolio company grows. This is assessed through the Funds six impact criteria, which guide the Fund Managers’ evaluation process:

1. Intentionality & Problem: Does the founder have a clear intention to solve a specific environmental or social issue? Is the environmental and/or social problem in alignment with the Funds strategy?
2. Evidence & Data: Is their approach to solving the identified issue supported by scientific understanding? Is there clear evidence, data, and research demonstrating that their approach is making a positive contribution
3. Interlock: Is the impact closely integrated with the portfolio company’s business model, ensuring that as the portfolio company grows, its impact scales proportionally?
4. Moving the Needle: Does the approach make a measurable difference in both depth (e.g., the percentage of emissions reduced per product sold) and breadth (e.g., the number of people reached)?
5. Additionality: Would the desired impact occur without this portfolio company’s intervention? What other approaches are addressing the same issue? Is the approach new or innovative? Are the financial returns and environmental/social outcomes intrinsically linked?
6. Measurability: Can the social and/or environmental outcomes be effectively measured and managed to ensure progress toward the desired impact?

These criteria enable the Fund Manager to determine whether a company is truly capable of creating meaningful and measurable impact and thus qualifies as an investment that helps promoting at least one of the environmental and/or social characteristics of the Fund, defined as E/S promoting cases.

In order to measure the attainment of the environmental and/or social characteristics promoted by the Fund, a questionnaire is completed by the potential portfolio companies, typically in close collaboration with the Fund Manager in the course of the due diligence process prior to any investment. The findings from the assessment and questionnaire are consolidated into an investment recommendation document. This document is then presented to the investment committee, which considers it alongside other due diligence outcomes in their investment decision.

To promote and maintain good governance practices within the Fund’s portfolio companies during the holding period, the Fund has implemented a process focused on ESG management, responsible leadership practices, and operational impact. The Funds approach includes but is not limited to: ESG Sprint workshop during portfolio onboarding, Theory of Change Framework i.e. impact thesis development, ongoing ESG guidance, carbon footprint tracking estimations for CO2 emissions measurement, annual ESG questionnaire and support for impact measurements to monitor ESG and impact progress, access to LCA specialists, leadership development, and legal advisory. This “support system” aims to ensure that the Fund’s portfolio companies not only maintain good governance practices but also continuously enhance their impact and ESG performance throughout the investment period. If the Fund becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution. Further, the Fund will use any position as board member to influence the portfolio company to ensure good governance practices are in place throughout the holding period.

To summarize, the binding elements used to select the investments to attain each of the environmental and social characteristics promoted by the Fund are:

• The portfolio company is at pre-seed stage, tech enabled and is not operating within any of the Prohibited Sectors and activities i.e. passes the negative screening
• The portfolio company passes the Fund Manager’s ‘ESG risk and opportunity’ screening
• The portfolio company passes the Fund Manager’s ‘Impact’ screening test i.e. be assessed to have “real impact’ potential
• The portfolio company is in alignment with the environmental and/or social characteristics promoted by the Fund

e. Proportion of investments

The Fund will invest fully in line with its investment strategy and investment restrictions, i.e.,
investments used to meet the environmental and/or social characteristics promoted by the Fund, in accordance with the binding elements of the investment strategy and use best efforts to reach at least 50% of the Funds venture investments (based on number of investments and monitored upon the expiry of the investment period). Venture investments, according to the Fund, are investments where the aggregated invested amount is above DKK 5 million.

The purpose of the remaining proportion of investments is to invest in early stage tech enabled companies that pass the negative screening test, operate in accordance with good governance practices, as determined by the Funds ESG risk and opportunities screening process but is not at the time of the investment or during the holding period eligible to meet the other binding elements.

f. Monitoring of environmental or social characteristics

To be able to monitor the environmental and/or social characteristics promoted by the Fund throughout the lifecycle of the Fund, the Fund requires access to the portfolio companies and relevant data. The Fund includes a statement in the legal documentation with each portfolio company that outlines the Fund’s information expectations relating to environmental and/or social characteristics i.e., the relevant data and information necessary to monitor these. Further, the Fund will be able to monitor portfolio companies where the Fund has significant influence on the portfolio companies’ governance and holds a board seat.

The Fund distributes stage-sensitive assessment questionnaires to portfolio companies on an annual basis that are adapted as appropriate to the stage of the portfolio company. Each portfolio company will on an annual basis report on minimum: Responsible Operations (to ensure ongoing adherence to ESG responsibility standards), Ethical Practices (to ensure continued compliance with the negative screening criteria), and their individual impact KPIs identified to ensure it meets the investment criteria and to be able to measure the attainment of the environmental and/or social characteristics promoted.

Internal control mechanisms include regular portfolio reviews to ensure ongoing alignment with the Fund’s environmental and social characteristics. All E/S promoting cases will undergo an annual ESG sprint. This process is designed to track the portfolio companies’ progress on key impact KPIs and support their ongoing development in environmental, social, and governance areas. The Fund has an internal ESG & Impact expert to evaluate and monitor the sustainability performance of the portfolio companies. For external control mechanism, the Fund utilize third-party ESG data providers, when necessary, to obtain an independent assessment of portfolio companies’ alignment with the environmental and social characteristics promoted by the Fund.

g. Methodologies
As described in section d. ‘Investment Strategy’, the Fund follows a tailored four-step decision-making process to ensure the attainment of the environmental and/or social characteristics promoted by the Fund, while ensuring that all portfolio companies adhere to responsible business practices and good governance standards.

To be eligible for investment, potential portfolio companies must pass two key screenings: 1) negative screening and 2) ESG risk and opportunities screening. To qualify as an impact startup, i.e. E/S promoting case, that helps promote at least one of the environmental and/or social characteristics of the Fund, the potential portfolio company must also pass 3) the impact screening test, and 4) the potential portfolio company must demonstrate alignment with the Fund’s specific environmental and/or social characteristics. This is assessed through the Funds six impact criteria, as described in section d. ‘Investment Strategy’, which guides the Fund Managers’ evaluation process. Based on the results of such an assessment, the Fund identifies whether the environmental and/or social characteristics promoted by the Fund are met.

During the holding period, the Fund monitors and consults with its portfolio companies on a regular basis in order to assess whether said characteristics are continuously met.
In addition to the annual stage-sensitive assessment questionnaires, follow-up questions and/or calls or meetings are tailored to the specific environmental and/or social characteristics that the portfolio company is deemed able to help promote.

Based on the decision-making process and assessment, specific KPIs for the portfolio companies will be identified. The Fund Manager will take into consideration the industry, maturity, and the characteristics the portfolio company helps promote as well as the indicators used to measure the attainment of the specific characteristic(s). The Fund Manager do not pre-define KPIs and indicators and ask the portfolio companies to opt in. This means aggregation is more difficult, however the Funds focus is on helping each company define and scale their impact contribution. The KPIs will develop over time. Examples of indicators and KPIs that could be used to measure the attainment of the environmental and/or social characteristics:

During the holding period, the Fund Manager will measure each portfolio company’s progress in achieving the KPIs and will in cooperation with the portfolio company continuously set new KPIs.

If it is difficult to find a meaningful indicator for the portfolio company’s impact, the chances are most likely that the portfolio company is not living up to the Funds six impact criteria and is not truly focused on promoting the environmental/or social characteristics of the Fund. In some cases, the impact is still too distant and uncertain for the founders in the early days but can develop as the portfolio company matures. These companies will be assessed to be ‘a responsible business case’ as described in section f. Monitoring of environmental or social characteristics, and thereby be a part of the proportion of investments in the Fund that pass the negative screening test, operate in accordance with good governance practices, as determined by the Funds ESG risk and opportunities screening process, but is not at the time of the investment or during the holding period eligible to meet the other binding elements.

h. Data sources and processing
In order to attain each of the environmental and/or social characteristics promoted by the Fund, a questionnaire is completed by the potential portfolio companies in the course of the due diligence process prior to any investment as well as on an annual basis during the holding period. Hence, data is obtained only from the potential portfolio companies or supplemented by information publicly available.

The data quality is ensured through internal review and – in some cases – follow up interviews with the portfolio companies. Moreover, a comprehensive internal and/or external review or verification of the information obtained will be carried out if misrepresentations are suspected.

As the Fund invests in early-stage companies a proportion of the data is expected to be estimated, hence the stage-sensitive assessment questionnaires. It is expected that the proportion of reported data will increase as the portfolio company matures.

The Fund is continuously re-evaluating the data process to make it most applicable to the nature of early-stage companies.

i. Limitations to methodologies and data
Due to the nature of the Fund’s investment scope, focusing on early-stage companies leveraging innovative technologies, the methodologies and data sources described have certain limitations, including the reliability of estimations and the lack of historical data for portfolio companies.

There is limited established practice and methodology for measuring impact and the attainment of the environmental and/or social characteristics promoted by the Fund. To address this, the Fund has implemented its own developed ESG & impact process to measure and evaluate the impact of its portfolio companies.

The methodologies outlined in section (g) ‘Methodologies’ and data sources discussed in section (h) ‘Data sources and processing’ provide only a snapshot, as any projections into the future inherently carry uncertainty.

Despite these limitations, the Fund believes the measurements are directionally accurate, ensuring that portfolio companies are on track to achieve the environmental and/or social outcomes promoted by the Fund. To further mitigate these limitations, the Fund will regularly review and refine the methodologies and data used to assess progress, ensuring the most up-to-date approach is applied. This is achieved by gathering feedback from subject matter experts and collaborating closely with impact experts.

j. Due diligence
The due diligence carried out includes various steps to determine whether a portfolio company is eligible for the investment strategy of the Fund.

During the investment process, the Fund’s due diligence considers ESG and impact factors in pre-set questionnaires appropriate for the growth stage of the portfolio company. The ESG-factors evolve around five core business areas that include: workplace culture and employment practices, responsible product design, data privacy and protection, environmental impact, supply chain. These considerations form the basis of the Fund’s ongoing monitoring process and engagement agenda with each portfolio company. The impact factors include an assessment of founder intentionality and motivation, criteria to meet the Fund’s definition of impact investments, and alignment with the UN Sustainable Development Goals. ESG and impact factors from the respective questionnaires are included in a due diligence report that is shared among investors before an investment decision. Further, the Fund will identify and look at Sustainability Risks.

The Fund evaluates good governance during the due diligence phase using a set of key governance criteria, including board oversight, employee relations, anti-bribery and anti-corruption measures, financial and process controls, tax compliance, and IT security. Based on the results, the Fund determines whether the portfolio company meets the required standards for good governance and establishes targets to further enhance governance practices during the Funds holding period.

As ESG and impact related risks differ across industries, markets, and countries, the Fund evaluates them on a case-by-case basis, focusing on the issues most relevant to each potential portfolio company and its specific operating environment. This is achieved through the Funds ESG Sprint, a developed workshop that serves as a materiality assessment with the founders, and the Funds Impact Framework which uses a theory of change approach to assess the portfolio company’s potential impact and its contribution to the environmental and/or social characteristics promoted by the Fund.

Based on the results of the assessments, the Fund will either take additional actions – such as conducting further ESG and/or impact risk reviews internally or by external experts – or finalize the ESG & impact assessment, including recommendations for improvements as part of the due diligence.

Given the Fund’s focus on early-stage investments, it is expected that most potential portfolio companies will have little to no historical burden related to social or governance issues, as the companies are typically newly founded and, in some cases, do not employ any employees beyond the founding team. However, the Fund acknowledges that these companies rarely have established governance processes. This enables the Fund to support the portfolio companies in establishing strong governance policies and processes from the outset.

The Fund expects that (potential) portfolio companies in regulated industries – such as finance, healthcare, or other heavily regulated sectors – will require significant attention during the analysis process. Striking the right balance between disrupting an industry with pushing the regulatory boundaries without crossing legal lines is crucial. Portfolio companies must always comply with relevant regulations and ensure their governance practices meet acceptable standards prior to the investment decision.

k. Engagement policies
The Fund engages with portfolio companies to encourage adoption and effective implementation of the environmental and social characteristics promoted by the Fund. This includes ESG and impact in-person and online sessions and workshops.

Where the Fund has substantial influence over the portfolio company’s structure and governance, the Fund will leverage this influence at the board level to ensure that ESG priorities, and impact priorities where relevant, are incorporated into the agenda of board meetings. Further, influence will be exercised to ensure that Sustainability Risks are mitigated and relevant KPIs are developed.

Beyond board-level discussions, the Fund maintains ongoing engagement with portfolio companies to provide guidance and support on ESG and impact matters as well as ensuring that risks and ESG-related incidents are managed properly. This may involve sharing best practices, connecting them with relevant resources, industry experts, and collaborating to identify and address areas for improvement. The Fund has developed its own ESG Napkin and ESG Sprint to ensure this integration for early-stage technology companies.

However, there are situations where the Fund does not gain influence over the portfolio company. In these cases, the Fund will utilize the support available to all portfolio companies on ESG and impact matters to collaborate on addressing and mitigating any ESG-related incident, should they arise.

Upon closing a new investment, a discussion on the ESG and impact-related issues takes place between the Fund and the portfolio company. This includes reviewing the findings from the Fund Managers ESG risk and opportunities screening, as well as the impact screening during the due diligence process. The Fund will also establish expectations for financial and ESG reporting.

Each portfolio company is responsible for developing its own ESG Policy (or equivalent) tailored to its operation, with the Fund offering support throughout the process. This helps ensure that ESG considerations are embedded in the portfolio company’s strategic direction and that progress is being made as they mature. Further, this ensures that management procedures for handling any potential sustainability-related controversies are considered.

Overall, the Funds engagement policies are designed to integrate ESG considerations into the core operations of the Fund’s portfolio companies and to offer continuous support in enhancing their ESG performance.

I. Designated reference benchmark
No index has been designated as a reference benchmark for the Fund, as the Fund invests in early-stage businesses, where no relevant benchmark has been identified.

Appendix 1

Negative Screening (Exclusion List)

The Fund will not make any investment in portfolio companies that, to the Funds knowledge, engages in the following:

i. Activities being illegal in the jurisdiction where such activities take place;
ii. activities or persons (physical or legal) that are subject to or is managed or otherwise
affiliated with persons that are subject to restrictive measures (sanctions) imposed by the
United Nations, OFAC, the European Union or Denmark from time to time;
iii. the manufacture, sale or distribution of tobacco, E-cigarettes and/or nicotine products and
any other products categorized as tobacco by the relevant authorities;
iv. the cloning of human beings for reproductive purposes;
v. the manufacture, sale and/or storage of UN defined unconventional weapons;
vi. activities which can be considered as pornography, or which can be associated with prostitution;
vii. fishing activities and/or fishing gear such as bottom trawling, beam trawling, spinning
rods and dredges etc., which levels out the sea floor, disrupts the biodiversity and risks
by catching other species; and/or
viii. activities within fossil raw materials including fossil fueled power plants as well as activities which have drilling, investigations, extractions, refining and sale of crude oil, natural gas
and thermal coal or storage of fossil fuels and the underlying infrastructure (pipelines etc.)
as its purpose.
ix. exploration and/or extraction of fossil fuels (coal, oil or gas) (not including any company
or other entity providing services to such companies or other entities)
x. utility company where the CO2 intensity of the energy production exceeds p00g CO2/kWh
or it bases more than 50% of its energy production on thermal coal (not including any
company or other entity providing services to such companies or other entities)

This document contains key information about the PSV Tech’s investment product. The document does not serve any marketing purposes. The information is required by legislation to help anyone understand the type of investment product and compare it to other products.

Download the document here

In this policy we want to tell you who we are, what data we process about you, why we collect it, what we use it for and how we protect it, care for it and retain it.
Why? Because your privacy is important to us.

Who are we and how can you contact us?
PSV is the data controller for the personal data we process about you in accordance with this policy. You can read more about what that means on the EU’s GDPR portal.

Here is our company information:
PSV
Diplomvej 381,
2800 Kongens Lyngby
(+45) 7734 0755
CVR: 10050154

To make this policy more user-friendly, we use “we”, “us”, “our” etc. to mean our company, PSV.

When we refer to “you”, we mean you as a user of our website, e.g. when you request a demo, ask for a compliance check, ask to be contacted, sign up for our newsletters, sign up for our services, register yourself as a business user in our product, etc.
When we talk about our “website” we mean www.psv.xyz and psvacademy.dk
On our website, in our emails, and on our social-media profiles, we have links to websites that aren’t ours. This policy doesn’t cover how those websites/companies process your data. We encourage you to read the privacy notices on the other websites you visit.

What data do we collect about you?
The data we collect about you fits into these different categories: 1) personal data, 2) business data and 3) log data.

1) Personal information:
When you sign up to our newsletters, events, seminars, courses etc. or download content from our website, we collect the following data about you:

• Your name
• Your e-mail
• The company you work for
• Your work title
• Telephone number
• Country
• Postal Code
• Profile / Nature of your work e.g.student,founder,investor etc.
• LinkedIn profile

We also collect information related to your request or sign-up, e.g. when you accepted our terms & conditions, when you viewed and e.g. read our privacy policy, when you asked to receive email marketing and what event you participated in

2) Business data:
When you sign up for our service or register yourself as a business user in our product, we collect the following information about you:

• Your first and last name
• E-mail
• What company you work for
• The company domain
• Company incorporation date
• Phone number
• Work title
• Business address
• Country in which your business operates
• Your pitch-deck

3) Log data:
When you visit our website, our servers may automatically log the standard data provided by your web browser. It includes your

• computer’s Internet Protocol (IP) address,
• browser type and version
• operating system
• which mobile brand and device you use
• your user agent
• the pages you visit
• the time and date of your visit
• the time spent on each page
• the referral page
• search terms
• and other details

We take situational pictures of the attendees at our events for our own use. We do not sell or rent your data to marketers or third parties.

What do we use your data for? (Also known as “purposes”)
The collection of personal data and the processing of this will at all times take place in accordance with the ordinance and applicable legislation, including the Data Protection Act (GDPR).
We use your data for these purposes:

• Manage events & webinars, conferences etc.
• To conduct feedback surveys,
• To review and assess your pitch and company and potentially invest in your company,
• Identify you as a participant in our events, seminars and academy sessions and log and save the events you participated in,
• Improve or modifying our website, our services, including our widgets, services and products to you,
• Respond to your questions and provide you with customer service and support, including sending services related messages to you,
• Send you newsletters, provide you with offers and send you different types of marketing material,
• Comply with legal obligations and requirements, requests from public and governmental authorities, relevant industry standards and our internal policies and protect our operations and our rights,
• Engage in various internal business purposes, i.e data analysis, audits, developing new products and services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities,

We may also use your data in other ways but we will inform you about these purposes when we collect your data.
We do not sell or rent your data to marketers or third parties.

What legal basis is used to process your data?
We process your data based on the following legal grounds:

• To perform our contract with you (see Article 6.1.b of the GDPR (the General Data Protection Regulation (EU) 2016/679)).
• To comply with our legal obligations (see Article 6.1.c of the GDPR), including the Danish Marketing Practices Act, etc.
• To pursue legitimate business interests of our own related to operating our website and providing our services to you, or to pursue the legitimate interests of third parties as long as your interests and fundamental rights do not override those interests (see Article 6.1.f of the GDPR).
• For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR).
• To process your data on the basis of your consent (see Article 6.1.a of the GDPR)

Some of these grounds for processing your data overlap, so there may be several reasons that justify us processing your data.
When you have expressly given your consent to us to process your data (see Article 6.1.a of the GDPR), e.g. when subscribing to our newsletters, you are free to withdraw your consent at any time. If you withdraw your consent, we might still have the right to process your information if it is required or justified by the legal grounds above.
If you would like more information about our legal basis for processing your data, please contact us (see our details elsewhere in this policy).

What about third parties? (Also known as “sub-processors”)
We never disclose, sell or exchange your personal information to third parties.
However, we use specific companies to help us deliver our services to you, such as sending out newsletters and running our website. These third-party companies are sub-processors, which means that they are not entitled to use the data for their own purposes. We have contracts with them, which means they cannot do anything with your personal information unless we have instructed them to do it. They must not share your data with any organisation apart from us or use your data for anything else than instructed by us. They will hold your data securely and keep it for the period we tell them to.
Here is a list of some of the sub-processors we use:

IT-systemType of personal dataHostingOffice 365 (mail, file storage)Names, emails, phone numbersEU (Ireland/Netherlands)HubSpot (CRM)Names, emails, phone numbers, business informationEU (Ireland)Google AnalyticsIP addresses, browser fingerprint informationUSATeamtailorNames, emails, phone numbersEU (Ireland)

IF THE SUB-PROCESSORS ARE LOCATED OUTSIDE EU/EEA:
Some of these sub-processors are located outside of EU / EEA, e.g. in the US. You consent to us using data processors in unsecure third countries provided that there is a legal framework governing the transfer of your personal data and ensuring adequate protection of it, for example if the data processor is part of the EU-US Privacy Shield framework.

How we protect your data and for how long do we keep it?
We use reasonable organizational, technical and administrative measures to protect your data within our company. The internet is not a 100% secure environment and that means we cannot guarantee the security of the data you transmit to us. Emails sent via the internet might not be encrypted, so we advise you not to include any confidential information in your emails to us.
The length of time we keep your data depends on the type of data we are processing and why we are processing it.

Newsletters, email marketing, etc.
We keep your data for as long as you are subscribed to our newsletters, email marketing, etc. If you ask us to unsubscribe you, we will keep your data for 24 months after your request so we can show that we have honored your request, and to make sure that you aren’t receiving our email marketing and newsletters.
If we have collected publicly-accessible information about you for the purpose of being able to carry out marketing activities, we will keep that data for as long as the relevant activity continues, and for two years.

Events, seminars, courses, etc.
We will keep your personal data as long as necessary for the purposes of the course, event or seminar in question, and for evaluating them.
Signing up for our service and registration as a business user in our systems
We will keep your data about your sign-up and registration as long as you have an account with us and up to 2 years after that, so that we can fulfill our legal obligations.
If you are employed by one of our customers, we will keep your data as long as we have a business relationship with that customer.

Business data
We will keep your data for as long as necessary for the purpose or purposes for which they are being processed. As a general rule, data will be kept for as long as you use our product or have an account with us plus 2 years following the conclusion of your account / customer relationship with us. Special circumstances or legal requirements may mean that these periods may be shorter or longer, e.g. for us to comply with legal requirements for the erasure or keeping of data.

Your rights and how to unsubscribe from email marketing material
You have rights we want to make you aware of. Your rights will depend on our reason for processing your data.

1. Your right of access
   You always have the right to ask us for copies of your personal data.
2. Your right to correction
   You can always ask us to correct information you think is inaccurate and you can also ask us to complete information you think is incomplete.
3. Your right to erase
   You can also ask us to erase your personal information, except in the following situations:
   – You have an unresolved case with customer service
   – You have an open order that has not yet been completed
   – You have a financial balance with PSV, regardless of payment method
4. Your rights to restriction of processing and to object to processing
   You have the right to ask us to restrict the processing of your information in certain circumstances and the same goes for your right to object to processing.
5. Your right to data portability
   This only applies to information you have given us. You have the right to ask us to transfer the information you gave us to another organisation, or to give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

The easiest way to exercise your rights is to email us at info@psv.xyz

We have one month to respond to you.

You can always lodge a complaint with a relevant data-protection authority, for example the Danish Data Protection Agency (www.datatilsynet.dk).
If you have subscribed to our newsletters or asked to receive marketing material from us, you can always unsubscribe. We include a link in all of these emails that you can use to easily unsubscribe.
You can also always ask questions or unsubscribe by sending us a request by email to info@psv.xyz

Changes to this policy
Sometimes we need to make changes to this policy to reflect our current practices. We will take reasonable steps to let you know about changes via our website. If you are a registered user, we will notify you by email if significant changes are being made to the policy. We will use the contact details you gave us, when you signed up. You are responsible for keeping those details up to date.
If you continue to use our website or services after notification of changes to this policy, we will treat that as your acceptance of those changes.

This policy is effective from January 30, 2026.

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In this cookie policy you can read about

• how we use cookies,
• the types of cookies we use,
• for how long they work and for what purposes they are used,
• how to change your cookie settings and opt-out, and
• who are we and how can you contact us.

When we use words like “us”, “we”, “our” we mean PSV. You can find our company details below. We are the data controller of the data collected through the use of cookies on our website.
Our website is www.psv.xyz, www.psvacademy.dk, incl. our sub-domains, we own and operate.
When we refer to “you” we mean you as a user or visitor of our website.
This policy is part of our privacy policy. Our use of cookies may include processing of your personal data and we therefore recommend that you read our privacy policy, which can be found here http://psv.xyz/codex-policies

Consent
By accepting our use of cookies, apart from necessary cookies, you consent to our use of cookies as described under “Types of cookies and how we use them” below. You may at any time change or withdraw your cookie consent – See the section “How you can change your cookie settings, incl. opting out” below.

What do I need to know about cookies?
There are different types of cookies and they are used for different purposes.
Below you can read about what a cookie is, the difference between first and third party cookies and session cookies vs. persistent cookies and what types of cookies we use on our website and why.

What is a cookie?
A cookie is a small piece of data that a website stores on your device when you visit it and which is then read when you later revisit the site. The word “cookies” in this policy and the consent also refers to other forms of automatic collection of data, e.g. Flash-cookies (Local Shared Objects), Web Storage (HTML5), Javascripts or cookies placed by other software.
A cookie may contain information about the website itself, a unique identifier that allows the site to recognise your web browser when you return to the website, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.
The word “cookies” or “cookie data” also covers information about IP and MAC addresses and other information about your device collected by said technologies.
Cookies are used to enable certain features (e.g. logging in), to track site usage (e.g. analytics), to store your user settings (e.g. timezone, notification preferences), and to personalise your content (e.g. advertising, language).

Session cookies vs. persistent cookies
Session cookies only last as long as your online session. This means that they will disappear from your computer or device when you close your browser. They are therefore also sometimes referred to as temporary cookies. Typically, session cookies are used to remember what a user put in their basket when they are browsing a website.
Persistent cookies are different. These cookies are sometimes called permanent cookies. They will stay on your computer or device after you close your browser. These types of cookies will expire according to the time specified in the cookie. You can see the specific duration of each persistent cookie below.

What’s the difference between first and third party cookies?
First party cookies are cookies that are set by the website that you are visiting and it’s only this website that can access and read these cookies.
Third party cookies are set by someone other than the owner of the website you’re visiting. As an example, some pages have content from other sites like YouTube. YouTube may set their own cookies on your browser when you play the video from YouTube. Cookies set by other sites and companies (i.e. third parties) can be used to track you on other websites that use the same third-party service.
We may engage third parties to assist with maintenance, operation, creation or functionality of our website, e.g. analytics providers and content partners. We grant these third parties’ access to selected information to perform specific tasks on our behalf.
We are, as a main rule, joint controller with providers of third-party cookies for the collection of personal data via such cookies and the disclosure to the provider. The provider of third-party cookies is data controller for the processing taking place after receiving the personal data from us. You can read more about the extent of our joint controllership with providers of third-party cookies in our privacy policy.
We recommend reading the provider’s privacy policy which can be found through links in the tables below, where you can also see which cookies on our website are first party cookies and third-party cookies.

Types of cookies and how we use them
Necessary cookies
Necessary cookies are required for the basic functionality of our website to work. We use necessary cookies to make it possible for you to only have to enter your username and password once during a visit to our website.
We also use necessary cookies to help with ensuring that you are given the option to accept or reject cookies, block non-necessary cookies from working until you give consent, and remember your cookie settings and choices. The cookies also help keep track of, if, and when, you gave consent to analytical cookies, T&Cs and email marketing.
Necessary cookies are also used for payment processing.
It’s not necessary to accept nor possible to reject the use of necessary cookies as they are core for the functionality of our website.

Here are the necessary cookies we use, what we use them for, the specific cookies providers and each cookie’s duration:

ProviderPurposeCookiesOpenli by Legal Monster ApSThe cookies from Legal Monster help with ensuring that you are given the option to accept or reject cookies, block non-necessary cookies from working until you give consent and remember your cookie settings and choices. The cookies also help with keeping track of if and when you gave consent to analytical cookies, our privacy policy, T&Cs and email marketing.

• legalmonster-consent-cache
  Session cookie
• legalmonster-cookie-consent
  Expires after 180 days
• legalmonster-pages-viewed
  Session cookie
• legalmonster-user
  Expires after 180 days

Openli by Legal Monster ApsLegal Monster is providing widgets for collecting compliant consent regarding privacy policies, cookies and signups

• isPrimaryDomain
  Session cookie
• isPrimaryDomain
  Session cookie
• isPrimaryDomain
  Session cookie
• isPrimaryDomain
  Session cookie
• legalmonster-consent-cache
  Session cookie
• legalmonster-cookie-consent
  Expires after 180 days
• legalmonster-pages-viewed
  Session cookie
• legalmonster-user
  Expires after 180 days

Analytical cookies
Analytical cookies gather statistics. We use this information to make our website even better. The information collected via the analytical cookies track how you use our website during your visit. It helps us understand visitor usage patterns, identify, and diagnose problems or errors you may encounter, and make better strategic decisions in improving the website experience.
We will only set analytical cookies on your device if you give us your consent.

Here are the analytical cookies we use, what we use them for, the specific cookie providers and each cookie’s duration:

ProviderPurposeCookiesHubspotThese cookies from Hubspot are used to keep track of sessions, determine if the visitor has restarted their browser, keep track of a visitor’s identity and generally track visitors

• __hssc
  Expires after 0 days
• __hssrc
  Session cookie
• __hstc
  Expires after 390 days
• hubspotutk
  Expires after 390 days

Google AnalyticsThese cookies help with measuring website usage. They distinguish unique users, remember the number and time of previous visits and throttle request rate. They also determine the start and end of a session and remember the value of visitor-level custom variables. The cookies also store the traffic source or campaign that explains how you reached the website. It therefore helps with understanding which pages users visit, for how long they stay on the site, which website they came from etc.

• _ga
  Expires after 730 days
• _ga
  Expires after 730 days
• _gat_gtag_UA_115182529_1
  Expires after 0 days
• _gat_gtag_UA_115182529_2
  Expires after 0 days
• _gid
  Expires after 1 days

Targeting/advertising cookies
Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns, and the quality of content presented to you. These cookies may be set by the website you’re visiting (first party) or by third-party services. Targeting/advertising cookies set by a third-party service may be used to track you on other websites that use the same third-party service.
We only set marketing/targeting cookies on your device, if you give us your consent.

Here are the advertising/targeting cookies we use, what we use them for, the specific cookie providers and each cookie’s duration:

ProviderPurposeCookiesFacebook Inc.Facebook is a social media network that allows users to share posts and photos with friends

• Session cookie
• _fbp
  Expires after 90 days
• fr
  Expires after 90 days

Pixels
Cookies are not the only way to recognise or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our website [or opened an email that we have sent them]. This allows us, for example, [to monitor the traffic patterns of users from one page within our website to another, to understand whether you have come to our website from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of email marketing campaigns].

How you can change your cookie settings, incl. opting out
As part of our cookie solution, we always ask for your consent to cookies, except for necessary cookies, before placing cookies on your device.
We also always give you the option to change your consent. If you at one point gave consent to non-necessary cookies on our website, you can always change which cookies you will give consent to. Just look for the shield on our website. If you press the shield, your cookie settings will appear, allowing you to always change your settings and reject cookies.
It’s also possible to instruct your browser to refuse cookies from our website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie. If you use multiple browsers and wish to block cookies or change or withdraw your consent, remember to do this in all browsers.
If you browse websites from multiple devices, you may also need to update your settings on each individual device.
Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content on the site.

How often will we update this Cookie Notice?
We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies. The date at the bottom of this Cookie Policy indicates when it was last updated.

Who are we and how can you contact us?
Here is our company information:

PSV A/S
Diplomvej 381
2800 Kgs. Lyngby
Denmark

Company registration number: 10050154

You can always write to us at: info@psv.xyz or call us at (+45) 77340755

This policy is effective from October 27, 2020