How Sentica Manages Responsibility

Legislation, international norms, and industry standards

Sentica’s responsible investment approach is founded on up-to-date national legislation, EU regulation, and internationally recognised norms. The key reference frameworks for our investment activities include the United Nations Principles for Responsible Investment (UN PRI) as well as the guidelines issued by Invest Europe and the Finnish Venture Capital Association. These frameworks are intended to ensure that material ESG topics are identified in a consistent manner and that our resources are directed toward the most impactful areas of responsibility.

In addressing ESG topics, we rely on the core principles of the UN Global Compact relating to human rights, labour standards, the environment, and anti-corruption. We monitor that our portfolio companies comply at a minimum with all applicable legal requirements and actively encourage the development of more advanced corporate responsibility practices.

Sentica is registered as an alternative investment fund manager under the Finnish AIFM legislation (162/2014) and complies with the guidelines of the Finnish Financial Supervisory Authority (Finanssivalvonta) as well as the obligations arising from the fund agreements of the funds it manages. Sentica is also a full member of the Finnish Venture Capital Association and follows its rules and recommendations. In investor reporting, we adhere to the Invest Europe Investment Reporting Guidelines. In the valuation of portfolio companies, we apply the International Private Equity and Venture Capital Valuation Guidelines (IPEV).

Responsible investment principles and guidance

Sentica has a separate Responsible Investment Policy that describes how responsibility considerations are taken into account in our investment activities, ownership practices, and reporting. The policy is complemented by internal guidelines that ensure practical implementation across all stages of the investment process.

Sustainability factors are assessed on an industry- and company-specific basis. The assessment emphasises materiality: we focus on those topics that have the greatest financial relevance, the clearest risk implications, or the most significant potential for value creation.

Organisational responsibilities

Sentica’s responsibility framework is based on a clear allocation of roles:

• Overall responsibility for ESG matters at the organisational level rests with Sentica partner Johan Wentzel.
• Investment-specific responsibility for ESG matters lies with the partner leading each individual investment.
• Reporting and documentation are supported by Sentica’s operational team.
• Where necessary, external experts are engaged to support risk assessments and the design of development measures.

The objective is to ensure that responsibility is not treated as a separate or isolated topic, but as an integral part of Sentica’s investment strategy and ownership model.

Responsibility in the investment process and during the holding period

Responsibility is embedded throughout Sentica’s entire investment lifecycle. In practice, this includes the following elements at different stages of the investment process:

Preparation of new investments

• Responsibility topics are assessed at every stage of the process, from the initial screening to the final investment decision.
• A company-specific analysis of the most material ESG risks and opportunities is prepared to support the investment decision.
• During the due diligence phase, external experts may be used where appropriate, for example to assess environmental liabilities, occupational safety, or data protection matters.
• Key findings are documented and incorporated into the investment memorandum.

Acquisition and value creation

• Key sustainability factors that present value-creation potential or significant risks are incorporated into the portfolio company’s initial development plan.
• During the holding period, we systematically promote the development of responsible business practices as part of strategic and operational steering.
• In line with Sentica’s Good Governance model, the board of each portfolio company is required to review the status of responsibility matters at least annually and to ensure that concrete development programmes are in place for key topics.

Management of responsibility during the holding period

• The partner responsible for owner oversight, Johan Wentzel, ensures that the progress of responsibility-related work is monitored and documented at fund level.
• The objective is to support portfolio companies in building long-term practices that are directly linked to risk management, high-quality governance, and sustainable financial value creation.

Consideration of adverse impacts (SFDR)

Sentica recognises that investments may also have adverse impacts on sustainability factors. We assess such impacts as part of the investment decision-making process and monitor them throughout the entire holding period.

Our assessment covers, among other things:

• Environmental impacts (including emissions, use of natural resources, and waste management)
• Employee and stakeholder well-being
• Quality of governance
• Prevention of corruption and bribery
• Respect for human rights

Our analysis is based on the EU Sustainable Finance Disclosure Regulation (SFDR, Regulation (EU) 2019/2088).

Reporting and monitoring

Sentica reports to investors in its funds on a regular and transparent basis. Reporting is conducted in accordance with:

• Invest Europe reporting guidelines
• Fund-specific contractual arrangements
• The Principles for Responsible Investment (PRI)
• IPEV valuation guidelines

The status and development of responsibility matters in portfolio companies are reported as part of investor reporting. In addition, Sentica produces an annual overview of the progress of responsible investing and key themes at the portfolio level.

 

Attachments: Sentica Responsible Investment Policy 2026