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Seed Stage Operator Fund

Build by founders,
for a better world.

We back exceptional Italian founders building the future — with a rigorous commitment to Environmental, Social and Governance principles across every investment decision.

Art. 8

SFDR Classification — Lumen II

100%

Portfolio companies ESG screened

SDGs

UN 2030 Agenda aligned

Our ESG Framework

Responsible investing,
at every stage.

Lumen II integrates sustainability risks and opportunities into its full investment lifecycle — from deal sourcing to exit — with measurable objectives and transparent reporting.


Environmental

We prioritise companies driving environmental reclamation and sustainable resource use, measuring carbon footprint and waste reduction as core KPIs.

  • Carbon footprint (GHG scope 1–3)
  • Environmental certifications
  • R&D investment in green standards
  • Hazardous waste and emissions

Social

We back founders creating skilled employment, talent retention and inclusive growth — supporting Italian SMEs and innovative startups with long-term social value.

  • Long-term skilled job creation
  • Gender diversity ratio
  • Workplace safety policies
  • Community engagement

Governance

Good governance is non-negotiable. Our Investment Committee reviews ESG due diligence reports alongside every investment memorandum, before any decision.

  • Board gender diversity
  • Independent directors
  • ESG-linked incentive plans
  • Anti-corruption policies

Investment Process

How we integrate ESG

From first screening to portfolio monitoring, sustainability is embedded into how we evaluate, select and manage every company.

1 Exclusion screening

We exclude tobacco, weapons, GMOs, pornography, gold trading and any company with demonstrated human rights violations from our entire investment universe.

Regulatory Framework

SFDR Article 8 — Lumen II

Lumen II promotes environmental and social characteristics in accordance with EU Regulation 2019/2088. Managed by Ulixes SGR SpA, the fund integrates sustainability risk across a robust risk management framework covering environmental, social and governance dimensions at both fund and asset level.

Classification: Article 8 — SFDR Regulation 2019/2088 EU
Benchmark alignment: UN Global Compact · OECD Guidelines
Principal Adverse Indicators: PAI 4, 10, 11, 14, 15, 16 considered
Annual ESG reporting: Art. 11 SFDR — sustainability-related disclosure
SDG alignment: UN 2030 Sustainable Development Goals

Exclusion Policy

Sectors we do not invest in

Our exclusion policy screens out companies involved in activities that contradict our responsibility standards or pose material ESG risk.

Tobacco
Pornographic content
Human rights infringements
Casinos, gambling and betting
Gold buying & precious metals trading
Controversial weapons
Human cloning
Thermal coal
Systemic corruption
Opaque corporate structures
Genetically modified organisms
UNGC & OECD violations
Alcohol
Aggressive tax avoidance
Nuclear fuels

The Fund also applies the European Do No Significant Harm (DNSH) principles and the Core Cross-Cutting Principles (PNRR) related to Gender Equality, Youth Empowerment and Reduction of Territorial Disparities.