Sustainability-Related Disclosures

Disclosures pursuant to Regulation (EU) 2019/2088 ("SFDR")

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Introduction

The following information is published by Puzzle Ventures Management GmbH (LEI: 391200DT8N8Q8XR6L724; "Puzzle Ventures") in light of the consideration of sustainability-related aspects in accordance with Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector ("SFDR").

Puzzle Ventures is a registered alternative investment fund manager within the meaning of Section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, "KAGB").

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Article 3 SFDR - Sustainability Risk Policy

Puzzle Ventures recognizes that sustainability risks, meaning environmental, social or governance events or conditions that, if they occur, could cause an actual or a potential material negative impact on the value of an investment, may affect the value of its investments. Puzzle Ventures considers and assesses sustainability risks as part of its due diligence process prior to any investment. The results of such assessment are taken into account when the investment decision is being taken. However, Puzzle Ventures remains free in its decision to refrain from investing or to invest despite identified sustainability risks, in which case it may apply measures to reduce or mitigate such risks. At all times, Puzzle Ventures will apply the principle of proportionality, taking due account of the strategic relevance of an investment as well as its transactional context.

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Article 4 SFDR - No Consideration of Principal Adverse Impacts

Puzzle Ventures does not consider the adverse impacts of its investment decisions on sustainability factors as outlined in Article 4 (1) SFDR and does not use the sustainability indicators listed in Annex I of the Regulatory Technical Standards (Delegated Regulation (EU) 2022/1288, "RTS") to identify and assess potential adverse impacts. Sustainability factors are environmental, social and employee concerns, respect for human rights and the fight against corruption and bribery.

Puzzle Ventures pursues an active venture capital strategy and invests in early-stage software and technology companies. Given the early-stage focus, the data required for analyzing principal adverse impacts is not available from portfolio companies in sufficient quality or quantity. The standardized PAI indicator catalog is not tailored to the specific characteristics of venture capital investments, and the burden associated with collecting and reporting this data would be disproportionate for early-stage portfolio companies. Furthermore, as a minority investor, Puzzle Ventures is generally not in a position to require portfolio companies to collect and report the data as prescribed by the SFDR and the accompanying RTS.

Puzzle Ventures is open to reconsidering the consideration of principal adverse impacts in the future as data availability improves and market practice evolves.

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Article 5 SFDR - Remuneration Disclosure

As a registered alternative investment fund manager within the meaning of Section 2 (4) of the KAGB, Puzzle Ventures does not have, and does not need to have, a remuneration guideline or policy in accordance with the requirements of the KAGB. Sustainability risks are not specifically considered with respect to the determination of remuneration.

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Financial Product Disclosure

Puzzle Ventures Fund I GmbH & Co. KG (the “Fund”), LEI: 39120036RKP445R40B98

The fund does not promote environmental or social characteristics within the meaning ofArticle 8 SFDR and does not have sustainable investment as its objective within the meaning of Article 9 SFDR.

Investment Strategy

The Fund seeks long-term capital appreciation through equity and quasi-equity investments in early-stage technology companies. The Fund invests primarily in pre-seed and seed stage private companies active in B2B software and fintech, located or active within the European Economic Area, Switzerland, the United Kingdom and the United States.

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Investment Restrictions

The Fund may not invest, guarantee or otherwise provide financial orother support, directly or indirectly, to companies or other entities whose business activity consists of, or which substantially focus on:

- an illegal economic activity, including without limitation human cloning for reproduction purposes;
- the production of and trade into bacco and distilled alcoholic beverages;
- the production of and trade in weapons and ammunition of any kind;
- casinos and equivalent enterprises;
- research, development ortechnical applications relating to electronic data programs or solutions which aim specifically at supporting any of the above activities, internet gambling and online casinos, or pornography, or which are intended to enable illegal access to electronic data networks or illegal downloading of electronic data.

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Substainability Risks

Sustainability risks are considered as part of the investment decision-making process as described in the sustainability risk policy above.The occurrence of a sustainability risk could have a material negative impact on the net asset value of the Fund and on the returns of the financial product.However, given that the Fund invests in early-stage software and technology companies with predominantly digital business models in highly regulated jurisdictions, the likelihood of severe sustainability risk events with material financial impact is considered to be relatively low.

The Fund does not make sustainable investments within the meaning ofArticle 2 (17) SFDR, and no portion of its investments is aligned with the EUTaxonomy (Regulation (EU) 2020/852).

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