POLICIES & CULTURE

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Privacy Policy

Introduction

This Privacy Policy outlines Kavedone Kapital (“we“, “our” or “the Company“) practices with respect to information collected from users who access our website at www.kavedonkapital.com (“Site“), or otherwise share personal information with us (collectively: “Users“).

 

Grounds for data collection

Processing of your personal information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information“) is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.

 

What information we collect?

We collect two types of data and information from Users.

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  • Registration information: When you register to our Site you will be asked to provide us certain details such as: full name; e-mail or physical address, and other information.

 

How do we receive information about you?

We receive your Personal Information from various sources:

  • When you voluntarily provide us your personal details in order to register on our Site;
  • When you use or access our Site in connection with your use of our services;
  • From third party providers, services and public registers (for example, traffic analytics vendors).

 

What information we collect?

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may use the information for the following:

  • Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
  • To communicate with you and to keep you informed of our latest updates and services;
  • To serve you advertisements when you use our Site (see more under “Advertisements”);
  • To market our websites and products (see more under “Marketing”);
  • Conducting statistical and analytical purposes, intended to improve the Site.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party providers, who may be located in different jurisdictions across the world, for any of the following purposes:

  • Hosting and operating our Site;
  • Providing you with our services, including providing a personalized display of our Site;
  • Storing and processing such information on our behalf;
  • Serving you with advertisements and assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  • Providing you with marketing offers and promotional materials related to our Site and services;
  • Performing research, technical diagnostics or analytics;

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

 

User Rights

You may request to:

  1. Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
  2. Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
  3. Request rectification of your personal information that is in our control.
  4. Request erasure of your personal information.
  5. Object to the processing of personal information by us.
  6. Request to restrict processing of your personal information by us.
  7. Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer (“DPO”) using the details provided below:

info@kavedonkapital.com

 

Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

 

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

The Site uses the following types of cookies:

a. ‘session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;

b. ‘persistent cookies ‘ which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;

c. ‘third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

 

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

 

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information. We employ industry standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information, and we require any third party to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

 

Transfer of data outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

 

Advertisements

We may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).

You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

 

Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

 

Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy.

 

Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at info@kavedonkapital.com.

 

Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the “Last modified” section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

 

How to contact us

If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at info@kavedonkapital.com.

 

Kavedon Kapital

Last Modified 21.02.2021

Environmental, Social & Governance Policy

At Kavedon Kapital (“Kavedon”), we strive to create value for investors and portfolio companies while remaining aware of our responsibility towards both society and the environment. We’re proud of the fact that we consider responsible investing an integral part of our business model and we recognise the ever-increasing importance of environmental, social and governance aspects for our business and the world we in.

While this ESG policy sets out our commitment to responsible investing, we believe strongly in collaboration – and we will pursue a network-based approach to advance and improve our ESG position on an ongoing basis. We continually seek to work with our portfolio companies to create sustainable value.

Against this background, this policy should be read and understood as an evolving, inclusive, and overarching document. In it, we will be setting forth our general ESG commitment, which may be shaped further through dynamic and collaborative processes.

As the policy evolves, we will endeavour to respect the principle of proportionality, i.e., taking due account of the size, nature and scale of our activities, types of funds and stages of our portfolio companies. We will also engage our portfolio companies on a case-by-case basis, as appropriate to the company’s individual situation as well as our own legal, regulatory and tax requirements.

Scope

We commit to following this ESG policy within our own organisation, the funds we manage and partners we cooperate with. At Kavedon, as part of our circular economic design we have already implemented concrete steps towards more sustainable and impactful business operations. We are committed to maintaining all our efforts to minimize Kavedon’s and all its partners impact on the environment in other areas going forward.

Since we generally operate in early-stage investment, the influence we have on portfolio companies through shareholdings of our funds, including influence on sustainability matters. We will make every effort to encourage our portfolio companies to agree with our ESG policy and to commit to pursuing our ESG values. Also, we will strive to work with partners and market participants who implement such values themselves, or who can at least identify with them.

ESG Values

Kavedon’s aim is to promote sustainable practices throughout our organisation, our funds, and our portfolio companies. To this end, we’re proud to commit to the following values, which will serve as guidelines as we move towards wholly responsible investing and business practices.

Environmental

How can we become a positive presence in the natural world we live in?

• Minimize environmental impact and encourage environmental consciousness
• Promote the responsible use of resources (e.g., water, energy, natural resources; increase use of remote conferencing to minimize travel; implementation of energy efficient plans, train-first policy)
• Limit consumption of environmentally scarce and non-renewable resources
• Limit production of waste and improve recycling, for example, through active sorting and recycling of office waste

Social

How can we respect the rights, dignity, and well-being of everyone and contribute to a society in which there is equality for all?

• Promote respect of internationally recognized human rights
• Support elimination of child and forced labour
• Promote diversity and equal opportunities
• Zero tolerance against discrimination
• Address customer interests (e.g., health, safety, privacy)
• Respect employees’ and contractors’ rights to decent working conditions (e.g., minimum wages, working hours, health, and safety and right to collective bargaining)
• Depending on the respective fund’s legal documents, no investments in companies whose business activities consist of certain business practices and sectors, such as illegal economic activities, tobacco, distilled alcohol, weapons and ammunition, casinos, or equivalent enterprises, as well as electronic data programs or solutions that (i) refer to the above activities, internet gambling and online casinos or pornography; or (ii) enable illegal entry into data networks or to download data
• Encourage innovation, promote economic growth, and enhance global competitiveness of investee companies
• Encourage portfolio companies to consider their material social issues and respect basic labour rights when conducting their business activities
• Offer regular anti-bias trainings to increase partners’ awareness and sensitivity

Governance

How can we operate with integrity and transparency, and remain accountable for our business practices?

• Maintain a strict anti-corruption, anti-money laundering and GDPR policy
• Promote high standards of business ethics
• Provide timely information to limited partners on ESG matters and work to foster transparency regarding their activities
• Create awareness of future regulations in the markets we operate in

Implementing our values

Our ESG values are an integral part of each phase of the investment and value creation process, which is why we incorporate them into both the pre-investment and post-investment phases.

In the pre-investment phase, we consider our ESG values as we conduct our due diligence processes. We collect relevant information from potential portfolio companies using a detailed questionnaire and in doing so, we identify and evaluate potential ESG-related value creation opportunities and issues before making an investment decision.

To further assess ESG-related value creation opportunities and issues, and to monitor adherence to our ESG policy, this questionnaire is also issued to portfolio companies during the post-investment phase on an annual basis. This enables us to identify any ESG-related value creation opportunities and issues early and encourage and support actions for improvement. We also apply best efforts when negotiating an investment into a portfolio company, to reach a side letter agreement requiring the portfolio company to notify us on an ad hoc basis if any ESG-related issues become apparent. Furthermore, we organize an onboarding session for each portfolio company during which we discuss with and explain to the management how they could incorporate ESG consideration into their operations.

Specifically addressing social values, we have set up an Equal Opportunity and Inclusion policy, which covers relevant issues both internally and externally with its two pillars: career and investment. Each pillar has two goals, which can be summarized as equal opportunity on the one hand, and health and inclusion on the other. Our aim here is to ensure talented people of all backgrounds have equitable access to career and capital opportunities, and for Kavedon to achieve its vision of becoming a role model for equal opportunity and inclusion in venture capital.

Risk Management

We consider ESG factors within our risk management processes prior to and post investment. As required by the Sustainable Finance Disclosure Regulation (EU) 2019/2088, we have described and disclosed our processes relating to sustainability risks, as well as adverse impacts on sustainability factors, here.

Roles and Responsibilities

Our diverse team consists of experienced professionals who are committed to and collectively responsible for our adherence to this ESG policy in all relevant investment decisions and monitoring procedures. Where additional expertise is needed, the team will employ external resources.

Contact

For all contact regarding responsible investment and ESG-related issues please connect to info@kavedonkapital.com. This document was last updated on March 1, 2022.

SFDR Sustainability Risks

Kavedon Kapital (“Kavedon”) considers sustainability risks as part of its investment decision-making process. Sustainability risks are environmental, social or governance events or conditions, the occurrence of which could have an actual or potential material adverse effect on the value of the investment. Kavedon considers sustainability risks as part of the due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted using a questionnaire. The results of such assessment are taken into account when the investment decision is being taken. Kavedon remains free in its decision to refrain from investing or to invest despite sustainability risks in which case Kavedon can also apply measures to reduce or mitigate any sustainability risks. At all times, Kavedon will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.

 

Principal adverse sustainability impacts statement‍

 

1. Summary

Kavedon considers principal adverse impacts of its investment decisions on sustainability factors before and after investments. Sustainability factors mean environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery. No sustainability indicators are currently used. Kavedon collects information regarding principal adverse impacts from portfolio companies using a questionnaire prior to the investment as well as on an ongoing basis. This principal adverse impact statement dates as of 10 March 2021.

2. Description of principal adverse sustainability impacts

Kavedon has not identified any adverse sustainability impacts related to its investments to date.

3. Description of policies to identify and prioritise principal adverse sustainability impacts

Prior to any investment, Kavedon will conduct due diligence. Part of this due diligence includes checking whether the investment could have a negative impact on sustainability factors. This check is performed using a checklist questionnaire. The necessary information is obtained from the respective portfolio company. After an investment, i.e., during the holding period, a check is carried out at regular intervals to determine whether there have been or could be any adverse effects on sustainability factors. This review is carried out annually based on a checklist. In addition, the portfolio companies are expected to notify Kavedon in writing on an ad hoc basis if any adverse effects on sustainability factors become apparent. If adverse effects on sustainability factors are identified before or after an investment, they are taken into account in light of the circumstances of the individual case, in particular considering other impacts of the investment, its size, strategic importance and transactional context.

4. Engagement policies

Kavedon decides at its sole discretion whether or not to make an investment in light of principal adverse impacts on sustainability factors, and Kavedon may apply risk mitigation measures where appropriate. Kavedon organizes an onboarding session for each portfolio company it invests in. During such onboarding session Kavedon discusses with and explains to the management of those portfolio companies how they can incorporate and implement consideration of adverse impacts into their daily operations.

5. References to international standards

Kavedon is not a member of any international bodies, organizations or required by any national or international convention or standard to comply with any further requirements.

 

Renumeration and ESG statement

Kavedon operates a reward policy which is designed, among other things, to encourage responsible business conduct, ensure fair treatment of clients and avoid conflicts of interest. Further, and as noted in our ESG Policy, the firm ensures that relevant employees are suitably incentivised and remunerated to ensure that ESG requirements are implemented and adhered to.

Our reward policy requires that appropriate qualitative criteria (reflecting compliance with internal policies, applicable regulations, the fair treatment of Investors and Investees) are taken into account when setting remuneration for relevant staff, rather than relying solely on quantitative criteria. It covers all forms of remuneration offered to staff and states that an appropriate balance of between fixed and variable remuneration must be maintained at all times.

Zero Tolerance Policy

Background

Kavedon Kapital (“Kavedon”) is committed to maintain an inclusive and safe workplace that promotes respect, integrity, equal opportunity, and openness. To this end, Kavedon has adopted a zero-tolerance approach against any kind of discrimination and harassment. The purpose of this policy is to describe behaviour and activity falling under the zero-tolerance concept. It also includes how to report violations of this policy and remedial actions.

 

Scope

This policy applies to all individuals involved, engaged or associated with Kavedon, including Kavedon employees, fund portfolio company founders and employees, partners and vendors and other stakeholders. We expect everyone to adhere to this policy in all settings associated with Kavedon such as offices, video and telephone conferences, media and online communication, events and social outings. The behaviours falling under the zero-tolerance concept include discrimination, harassment, sexual harassment and other unwanted behaviour which are described in more detail below. The conducts and acts mentioned are not exhaustive. There may be other behaviour, which by either nature or context will fall within the scope of this policy.

 

Discrimination

Discrimination is when an individual is treated unfavourably or when an individual’s dignity is violated. There are several grounds of discrimination including sex, transgender identity or expression, ethnicity, religion or other belief, disability, age or other basis protected by law (‘protected characteristics’).

Direct discrimination occurs when someone is treated less favourable because of having one or more of the protected characteristics, compared to someone who does not have the same protected characteristic. Indirect discrimination occurs when a conduct or act appears neutral but in fact disadvantages certain individuals and can’t be objectively justified. Discrimination also occurs if an individual with a disability is disadvantaged due to not getting the same access as someone without the same disability.

Discriminatory behaviour may include limiting opportunities to work for non-objective reasons, deliberate exclusion attendance in a way that may constitute indirect discrimination and instructing someone else to discriminate against another individual.

 

Harassment

Harassment is an unwanted conduct or act which an individual is subjected to, that relates to a protected characteristic, and violates the victim’s dignity or creates an intimidating, hostile, degrading or offensive environment.

Harassment may include statements or remarks that are derogatory or demeaning about an individual, degrading images or material portraying stereotypes of an individual or marginalized group, racist or ethnic slurs, obscene or abusive language or outing individuals against their will, e.g. sexual orientation and religion.

 

Sexual harassment

Sexual harassment is harassment of a sexual nature or related to gender. Sexual harassment can take many forms and does not need to be motivated by sexual desire. Some acts may be considered as sexual harassments by nature, while some acts may be considered as sexual harassment based on the context.

Sexual harassment may include misogynist comments or behaviour, deliberate or persistent misgendering, sexual jokes, advances, propositions and touching, gestures, written and verbal abuse of sexual nature or sexually degrading ways to describe an individual.

A conduct or act by an individual in significant power over the recipient, such as a senior staff member or a person who influences funding decisions towards a person seeking funding, are specifically included under this section.

 

Other unacceptable conducts and acts

The above-mentioned conducts and acts are not exhaustive. Other behaviour that the recipient may perceive as unwanted may also be considered as falling under the zero-tolerance concept such as: – non-sexual physical touch, restraint, assault or threats, retaliation or the threat of retaliation against someone; – minimising, excusing and defending unacceptable behaviour; and – criticizing the recipient of unwanted behaviour for having an inappropriate emotional state of mind in response to an unacceptable behaviour.

 

Reporting

Kavedon strongly encourages its stakeholders to adopt a zero-tolerance approach to the conduct described herein and to implement processes to report and take appropriate measures against such behaviour.

Kavedon also encourages reporting of violations against this policy. We specifically expect people in senior positions or positions of power to report violations they may encounter as they are less vulnerable to retaliation or pressure.

Reporting can be made by email to Kavedon Kapital at hr@kavedonkapital.com.

We take all complaints seriously and will investigate promptly. Every effort will be made to ensure the victim’s privacy is maintained whilst protecting the rights of the accused. The information obtained in the investigation will be communicated on a “need to know” basis. For some complaints, third party assistance may be required.

 

Remedial Action

Kavedon has zero-tolerance for violations of this policy and if it is determined that a violation of this policy has occurred, effective remedial action will be taken. Such actions may include the following:

  • appropriate support to portfolio companies or other stakeholders to handle the violation;
  • informal or formal warning;
  • removal of responsibilities;
  • suspension;
  • termination of employment or contract;
  • reporting to authorities; and
  • follow-up monitoring to ensure that the inappropriate conduct or act has ceased.

For more information concerning Kavedon’s zero-tolerance policy, please contact hr@kavedonkapital.com. This policy is reviewed on an annual basis.