LIFA Ventures Responsible Investment & Sustainability Policy

Effective Date: 19 November 2025  Version 1

Policy Owner: LIFA Ventures ehf. 

Review Cadence: Annual (next review due: November 2026)

1. Introduction

LIFA Ventures ehf. is a specialist venture capital management company focused on early-stage Nordic MedTech, medical devices, diagnostics, and clinically impactful health technologies. We believe that responsible investment is integral to building durable, high-impact companies and generating strong returns for our investors.

This policy sets out how LIFA Ventures ehf. integrates environmental, social, and governance (ESG) considerations into its investment decisions and portfolio management across all funds under management. It applies to all investments, staff, General Partners, Venture Partners, and advisors engaged by the management company.

LIFA Ventures ehf. is registered with the Icelandic Financial Supervisory Authority (FSA). Funds managed by LIFA Ventures ehf. are classified under SFDR Article 6, integrating sustainability risks into investment decisions. The management company periodically reviews whether an upgrade to Article 8 is appropriate.

2. Principles

LIFA Ventures ehf. is guided by the following responsible investment principles:

• Patient impact first. We invest in technologies that address genuine unmet clinical needs with measurable patient benefit.
• Health equity & access. We prioritise devices and diagnostics that expand access and improve outcomes for underserved populations, including e.g. FemTech and out-of-hospital care.
• Safety & regulatory rigour. We invest only where credible regulatory pathways exist and founders demonstrate commitment to quality, safety, and evidence-based development.
• Data responsibility. We expect portfolio companies to protect patient and health data with appropriate safeguards.
• Ethical conduct. We expect integrity, legal compliance, and ethical supply chain and labour practices.
• Transparency. We report honestly and regularly to our investors on ESG matters.
  

3. Frameworks & Standards

International frameworks

SFDR: Article 6 - sustainability risk integration

UN PRI: Aligned; signatory targeted within 12 months of first fund final close

UN SDGs: Aligned with SDG 3 (Health & Well-being), SDG 5 (Gender Equality), SDG 9 (Innovation & Infrastructure), SDG 10 (Reduced Inequalities)

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Governance guidelines

LIFA Ventures ehf. follows the Corporate Governance Guidelines published by the Icelandic 

Chamber of Commerce, Nasdaq Iceland, and the Confederation of Icelandic Enterprise.

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MedTech-specific standards

As a specialist MedTech investor, we assess portfolio companies against the following standards, as applicable to their stage and product:

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ISO 13485: Quality Management Systems for medical devices

ISO 14971: Risk management for medical devices

ISO 14155: Good clinical practice for clinical investigations
ISO 27001:Information security management
EU MDR / IVDR & FDA 21 CFR: Including similar regulations for medical devices and diagnostics

GDPR / HIPAA: Data privacy and protection

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4. Exclusions

LIFA Ventures ehf. will not knowingly invest in companies whose primary business involves:

• Weapons or munitions
• Tobacco or Alcohol
• Gambling
• Illegal activity
• Human trafficking or forced labour
• Systemic corruption or bribery
• Persistent human-rights breaches

Companies with unresolved material regulatory enforcement actions where remediation is not credibly underway are also excluded.

5. ESG in Our Investment Process

Pre-investment
ESG considerations are embedded in our screening and due diligence through a dedicated ESG/Impact Checklist applied by the Investment Committee to every investment decision. The checklist covers six areas that reflect the specific risks and opportunities in MedTech:

• Patient impact & health equity: unmet clinical need, outcome targets, access for underserved populations, FemTech, site-of-service economics
• Safety & quality: ISO 13485 QMS roadmap, ISO 14971 risk management, design controls, supplier quality
• Regulatory & clinical evidence: defined pathway (510(k)/De Novo/MDR/IVDR), evidence strategy, ISO 14155 compliance for clinical investigations
• Data privacy & cybersecurity: GDPR/HIPAA path, ISO 27001 roadmap
• Supply chain & environment: ethical sourcing, environmental controls, end-of-life considerations
• Governance: board composition, founder alignment, IP assignment, financial controls

A material ESG failure can result in rejection of an investment regardless of other merits.

Investment structuring

Where ESG risks are identified, sustainability-related milestones may be incorporated as conditions in investment documentation.

Post-investment

We take an active ownership approach, holding board seats or observer positions in all portfolio companies. ESG-relevant matters are monitored through regular board meetings, operational engagement, and quarterly Impact KPI collection. We engage constructively where portfolio companies fall short of expectations.

Follow-on

ESG-related milestones are hard gates for follow-on capital. Companies that do not meet clinical, regulatory, quality, or data privacy milestones will not receive additional investment.

6. Health Equity & Access

Health equity is a core pillar of our investment thesis, not merely an ESG overlay:

• Out-of-hospital care: technologies for field use, point-of-care, and community settings
• Underserved populations: devices expanding access in rural, low-resource, and underrepresented patient groups
• Inclusive design & performance: we prioritise devices and diagnostics designed and validated to perform equitably across diverse patient populations, regardless of skin tone, ethnicity, body type, age, or geography
• Payer-validated economics: ensuring clinical benefit translates to real-world adoption through credible reimbursement pathways
• FemTech: medical devices and diagnostics addressing women’s health, a historically underfunded category

7. Governance & Oversight

The General Partners of LIFA Ventures ehf. are collectively responsible for the implementation and annual review of this policy.

The Investment Committee applies the ESG/Impact Checklist to all investment decisions. Both General Partners must approve every investment, and the ESG/Impact assessment forms part of the required decision materials. Venture Partners contribute domain expertise and flag ESG risks through advisory reviews.

Conflicts of interest are logged, recusals applied, and exceptions reported. Related-party transactions and conflict management are governed by the relevant fund’s Limited Partnership Agreement.

The LPAC (if established for a given fund) provides oversight on material ESG matters and receives an annual ESG/Impact summary.

8. Reporting

LIFA Ventures ehf. reports on ESG matters to fund investors through the following channels:

• Quarterly: Impact KPIs per portfolio company included in LP reporting, covering regulatory, clinical, quality, data privacy, and access/equity metrics where applicable
• Annual: ESG/Impact summary with portfolio-level performance, SDG alignment, incident review, and policy update outcomes
• Material incidents: Investors and LPAC notified of significant events (e.g., recalls, data breaches, serious adverse events) with remediation plans, in accordance with the relevant fund’s LPA

LIFA Ventures ehf. plans to become a PRI signatory within 12 months of its first fund’s final close, adding an additional layer of public ESG disclosure.

9. Internal Practices

We aim to apply the same standards we expect of our portfolio companies to ourselves:

• We value diversity of thought and background within our team

• We protect the privacy of all personal and sensitive data in accordance with applicable laws
• We support open collaboration, knowledge sharing, and mentoring within the Nordic MedTech ecosystem
  
  

10. Review

This policy is reviewed annually and approved by the General Partners of LIFA Ventures ehf. Material changes are communicated to the LPAC (if established) and disclosed to investors in the next quarterly report.

Detailed ESG implementation procedures, including the IC ESG/Impact Checklist and Impact KPI framework, are maintained as internal operational documents and are available to investors on request.

19 November 2025, LIFA Ventures ehf.

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