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Legal Notice

SFDR Disclosures

01 — Legal Notice

Legal Notice

Legal name

Expon Capital

Legal form

Société à responsabilité limitiée (sàrl)

Registered address

203 Route d'Arlon, 1150 Belair, Luxembourg

Regulator

Commission de Surveillance du Secteur Financier (CSSF)

RCS Luxembourg

B 198440

Expon Capital is registered with and regulated by the Commission de Surveillance du Secteur Financier (CSSF) in Luxembourg. Its funds are structured as SICARs (Société d'Investissement en Capital à Risque) under Luxembourg law.

Access to this website and investment in Expon Capital funds is reserved for Well-Informed Investors as defined under Luxembourg law, i.e. institutional investors, professional investors, and investors who confirm their awareness of the risks involved and invest a minimum of €100.000.

The information on this website does not constitute an offer or solicitation to buy or sell securities in any jurisdiction. Past performance is not indicative of future results. All investments involve risk, including the possible loss of capital.

02 — SFDR

Sustainability-Related Disclosures

Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector ("SFDR")

No consideration of adverse impacts — Art. 3

We acknowledge that ESG-related events or conditions could potentially have a negative impact on the value of our investments. At Expon Capital, we do not formally integrate an assessment of sustainability risks in our decision-making process in accordance with article 3 of the SFDR.

That being said, Expon Capital is focused on investing responsibly through its funds in (i) companies that solve the world's greatest challenges and unmet needs in a profitable, scalable and measurable way and (ii) companies that contribute to the development of the Luxembourg startup ecosystem. We do carefully select potential portfolio entities for investments, as well as the sectors that they are active in. In addition, through the long-term investments that our funds take in portfolio entities, we may influence such portfolio entities' activities and policies and thereby diminishing sustainability risks for our investments.

As set out in the documentation governing our funds, no investments will be made in entities active in certain 'restricted sectors' (which, among others, are sectors that may entail sustainability risks). Prior to making any investment, we conduct a thorough due diligence research on target entities. The outcome of the due diligence findings is taken into consideration when an investment decision is taken by us.

Transparency of adverse sustainability — Art. 4

The SFDR requires Expon Capital to make a "comply or explain" decision whether to consider the principal adverse impacts ("PAIs") of its investment decisions on sustainability factors, in accordance with a specific regime outlined in the SFDR.

Expon Capital has carefully evaluated the requirements of the PAI regime in Article 4 of the SFDR. Expon Capital is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market. However, Expon Capital is concerned about the lack of readily available data to comply with many of the reporting requirements of the PAI regime, as companies in their early stages of development may not be able to provide the required data.

Taking these considerations into account, at this stage Expon Capital has opted not to comply with that regime, both generally and in relation to the Funds. Expon Capital will keep its decision not to comply with the PAI regime under regular review.

Remuneration policies — Art. 5

Expon Capital's remuneration policy is consistent with the integration of sustainability risks. The compensation structure does not include variable components incentivizing investment managers to take excessive risks, including sustainability risks. The remuneration is composed primarily of a fixed management fee based on capital commitments, subject to a cap, which is not linked to ESG-related performance indicators.

Co-investments by Expon Capital's team in portfolio companies align interests with investors and are based solely on financial performance, not ESG criteria. A robust risk management process ensures that sustainability risks are adequately considered in investment decisions without promoting excessive risk-taking.

03 — Privacy Policy

Privacy Policy

Expon Capital S.A. ("we", "us", "our") is committed to protecting your personal data in accordance with Regulation (EU) 2016/679 (GDPR) and applicable Luxembourg data protection law.

Data we collect

How we use your data

Your rights

Under GDPR, you have the right to access, rectify, erase, or restrict the processing of your personal data. To exercise these rights, contact us at contact@exponcapital.com.

Data retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. Newsletter subscriber data is retained until you unsubscribe.