Version: November 2023
With this Privacy Policy we inform you about the processing of your personal data (“data”) when using our website.
We are controller of the data processed as described in this Privacy Notice:
AC Management GmbH
Rosenthaler Strasse 72a
10119 Berlin
Germany
Berlin
Email: contact@aminocollective.com
Data Protection Officer: Manuel Grossmann
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Insofar as we process your personal data, you have the following rights:
You have the right to obtain confirmation as to whether personal data concerning you are being processed by us, and, where that is the case, what data we are processing about you (Art. 15 GDPR). You can make this request again within a reasonable period. In addition, you have the right to receive a copy of your data that is the subject of our processing.
You can also request the rectification of inaccurate data in accordance with Art. 16 GDPR. In addition, you have the right to request the completion of incomplete data concerning you, taking into account the purposes of the processing.
Under the conditions of Art. 17 GDPR, you can request the erasure of your data.
You have the right to request the restriction of processing from us if the conditions of Art. 18 GDPR are met. This is the case, for example, if the processing of your data is no longer needed for our purposes, but you need it to assert, exercise or defend legal claims. If the processing of your data is restricted, this data - apart from storage - may only be processed by us with your consent or in the special cases mentioned in Art. 18 (2) GDPR.
Under the conditions of Art. 20 GDPR, you can demand that we hand over your data in a structured, commonly used and machine-readable format. In this case, you can also request that we transfer this data to another controller.
If we process your data on the basis of your consent, you have the right to withdraw your consent at any time with effect for the future (Art. 7 para. 3 GDPR).
You have the right to object to data processing for direct marketing purposes at any time. In addition, you may object at any time to data processing based on a legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR, Art. 21 GDPR, if there are reasons relating to your particular situation.
To exercise your rights as a data subject, please contact our data protection officer by e-mail or letter (contact details below).
Postal address:
AC Management GmbH
Rosenthaler Strasse 72a
10119 Berlin
Germany
Berlin
Email: contact@aminocollective.com
You have the right to lodge a complaint with a supervisory authority, in particular in the member state of your place of residence, your place of work or the place of the alleged infringement (Art. 77 GDPR).
In this section we inform you about the processing of your data when you visit our website.
When you access our website, the following data is transferred to our web server and stored in a log file:
The data processing is necessary to display the contents of the websites in the best possible way on your device. In addition, we process this data for the defense, investigation and clarification of attacks on our infrastructure and for the prevention and detection of criminal offences.
The data processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR due to our legitimate interest in being able to display the websites to you in the best possible way, to be able to track attacks on our IT and for the prevention and detection of criminal offences.
Our web hosting service provider processes the aforementioned data strictly in accordance with instructions on our behalf on the basis of a contract for data processing pursuant to Art. 28 GDPR.
Our web hosting service provider is:
Webflow, Inc.
398 11th Street, 2nd Floor
San Francisco, CA 94103
The log files are only processed for the duration of your visit to the website and are directly deleted afterwards.
When you visit our website, we set so-called cookies. Cookies are small text files that are stored on your device. Cookies usually contain a unique string of characters, called a cookie ID, with which can be used to identify your browser when you visit our websites again.
Cookies save you from having to enter data repeatedly, facilitate the delivery of specific content and help us to identify particularly popular areas of our website. They thus enable us to continually improve the structure and content of our website.
We only use so called functional- cookies on our website. These are cookies that are necessary to enable the operation of the websites or to ensure IT security, the legal basis for the use of the cookie is § 25 para. 2 No. 2 of the German Telecommunications-Telemedia-Data-Protection-Act (TTDSG). The legal basis for further data processing is Art. 6 para. 1 lit. f GDPR.
You have full control over the use of cookies and can delete cookies in your browser, disable the storage of cookies altogether, selectively accept certain cookies and, if necessary, set your browser to notify you if a cookie is to be set. Please use the help functions of your browser to find out how to change these settings. This may limit the functionality of our websites.
You can contact us via our websites in various ways. If you would like to contact us, we need the following data from you:
We process your data for the purpose of being able to answer your enquiry in the best possible way. We process your data on the basis of Art. 6 para. lit. f GDPR. Our legitimate interest lies in answering your enquiry sent to us.
The data will only be processed by the contact persons responsible internally for the contact requests.
The retention period depends on the content of your contact request. The data will be deleted as soon as it is no longer required to achieve the purpose for which it was collected and any statutory retention obligations have expired.
To protect your personal data against manipulation, loss, destruction or access by unauthorized persons, ongoing technical and organizational security measures are taken. In particular, we use TLS encryption when transmitting data via our website. You can recognize this by the fact that the lock symbol is closed in the status bar of your browser and the address line begins with https://.
AC Management GmbH (“Amino”, LEI: 39120001CTVJ30O89P96) 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. Amino considers sustainability risks as part of its due diligence process prior to any investment. This also includes an assessment of sustainability risks. Such assessment is being conducted by referring to the VentureESG universe of issues. The results of such assessment are laid down in our investment memos (where applicable) and taken into account when the investment decision is being taken. However, Amino remains free in its decision to refrain from investing or to invest despite sustainability risks in which case Amino can also apply measures to reduce or mitigate any sustainability risks. At all times, Amino will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.
Amino does not consider any adverse impacts of its investment decisions on sustainability factors and, hence, does not use the 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. Given that the SFDR, the Taxonomy and the accompanying RTS are relatively new legislative acts, there is very little or no practical experience or practice with regard to the application of their respective provisions. Therefore, substantial legal uncertainties would remain when applying those provisions. Moreover, the Fund will only hold minority interests in its portfolio companies. Such minority interests are, however, generally not sufficient to encourage the Fund’s portfolio companies to collect and provide the relevant data. If and to the extent that the legal uncertainties will be resolved and a practicable market and administrative practice will evolve in this regard, Amino will re-evaluate considering principal adverse impacts of its investment decisions in due course.
As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”), Amino does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB.
Financial product: AC Management GmbH (the “Fund” / der “Fonds”) LEI: 39120001CTVJ30O89P96
The Fund considers certain environmental and/or social characteristics as part of its investment decisions and monitoring processes but does not seek to make sustainable investments as defined in the SFDR. The consideration of environmental and/or social characteristics is carried out both before and after an investment. For this purpose, information is initially and regularly obtained from the portfolio companies by means of qualitative queries. The Fund incorporates exclusion (negative screening) aspects during the decision-making process. Thereby the Fund considers several ESG themes to be the key to responsible investing. The actions and decisions described in the following section are each made by Amino for and on behalf of the Fund.
The Fund promotes environmental or social characteristics but does not have sustainable investments as its objective.
The Fund promotes environmental and/or social characteristics by implementing certain investment exclusions (see section ‘Investment strategy’) during the decision-making process.
The purpose of the Fund is to build, hold and manage (including to divest) a portfolio of equity and equity- related investments in portfolio companies. The Fund will conduct early-stage investments in emerging digital technologies in the healthcare and pharmaceutical sector, non-digital technologies in life sciences and adjacent sectors. Startup companies, primarily early stage, will be a specified target segment, but also dynamic and innovative companies from the “old economy” may be suitable targets. The Fund intends to make its initial investments in the early stage, i.e. pre-seed. seed, Series A and Series B rounds.
The Fund’s investment strategy is implemented in the investment process on a continuous basis: Every investment opportunity will be tested against the Fund’s investment strategy, in particular its investment exclusions, as part of the due diligence prior to any investment made by the Fund. After an investment, i.e., during the holding period, the Fund will monitor its portfolio companies on a regular basis and provide support if and where considered relevant.
The Fund is bound by the investment restrictions and limitations set out in the Fund’s limited partnership agreement and shall procure that such requirements, restrictions and limitations are complied with at all times. In particular, the Fund will screen each investment opportunity against its investment exclusions and no investments will be made in the area of such exclusions.
The Fund shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including portfolio companies, or other entities whose business activity consists of:
a) Performing research and innovation activities considered as illegal according to the applicable legislation in the country of the portfolio company;
b) An illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Partnership or the relevant Portfolio Company, including without limitation, human cloning for reproduction purposes);
c) The production of, and trade in, tobacco and distilled alcoholic beverages and related products;
d) The financing and production of, and trade in, weapons and am-munition of any kind, save that investments in portfolio companies, or other entities whose business activity consists the financing and production of, and trade in, weapons and ammunition in accordance with legal and/ or regulatory standards of the European Union (as applicable);
e) Casinos and equivalent enterprises;
f) The research, development or technical applications relating to electronic data programs or solutions, which aim specifically at: (i) supporting any activity considered as prohibited sectors; (ii) internet gambling and online casinos; or (iii) pornography; or are intended to enable to illegally (A) enter into electronic data networks; or (B) download electronic data;
g) Oil and gas or metals and mining exploration, extraction or operations;
h) Retail banking;
i) Pornography;
j) The research, development or technical applications relating to electronic data programs or solutions, which are intended to enable to illegally (i) enter into electronic data networks; or (ii) download electronic data.
Good governance practices are assessed through an informal process as appropriate in light of the circumstances of each individual case (as included in the universe of ESG issues) during every due diligence process prior to any investment made by the Fund. Such practices include, in particular, sound management structures, employee relations, remuneration of staff and tax compliance within the portfolio companies. Moreover, the Fund will conduct regular monitoring of the good governance practices in its portfolio companies during the holding period (during board participation, where applicable; informally otherwise). If the Fund becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution.
The Fund will invest fully in line with its investment strategy and investment restrictions, i.e., will only make investments which are aligned with its environmental or social characteristics (i.e., its investment exclusions). The Fund does not make and does not intend to make sustainable investments within the meaning of Art. 2 (17) SFDR or environmentally sustainable investments within the meaning of Art. 2 Taxonomy; hence, no portion of its investments will be aligned with the Taxonomy.
The Fund has an increased awareness on the impact of environmental or social characteristics on risk management and thus on the value potential of investments. In order to monitor the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions), the Fund consults with the portfolio companies in regular intervals and will carry out further checks in order to identify potential issues with such characteristics. Therefore, the Fund monitors compliance with its environmental or social characteristics (i.e., its investment exclusions) on an ongoing basis. External monitoring mechanisms are not in place.
Currently the Fund applies qualitative assessments with regard to its environmental or social characteristics (i.e., its investment exclusions). The Fund conducts its initial assessment in the course of its due diligence. The Fund’s due diligence is carried out via an informal process.
Based on the results of such assessment the Fund identifies whether the environmental or social characteristics promoted by the Fund are met.
In order to measure how the environmental or social characteristics are met during the holding period, the Fund consults with the portfolio companies in regular intervals and will carry out further checks in order to identify potential issues with such characteristics.
In order to attain each of the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions), the Fund obtains the relevant data from its (potential) portfolio companies through an informal process. Hence, data is obtained only from the (potential) portfolio companies. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected.
The results of the data obtained are considered in the investment decision and, during the term of the Fund, in the monitoring process.
The information collected from the (potential) portfolio companies through the informal process carried out by the Fund is internally or externally verified only if and to the extent misrepresentations are suspected. Thus, it cannot be ruled out completely that false information may remain undetected in certain cases. As the Fund’s investments are made for several years, the Fund considers it a priority to establish and maintain a trustful working relationship with its portfolio companies in order to ensure compliance with the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions).
An initial assessment of how an investment relates to the environmental or social characteristics promoted by the Fund (i.e., its investment exclusions) is carried out as part of the due diligence process and, where required based on the inherent ESG risk of the portfolio company, through an enhanced analysis. As a rule, purely qualitative statements of an environmental or social nature or relating to corporate governance are requested from the portfolio companies and then taken into account in the investment decision-making process. An internal or external review or verification of the information obtained will only be carried out if misrepresentations are suspected.
Engagement is not part of the environmental or social investment strategy of the Fund. However, the Fund encourages its portfolio companies to conduct regular ESG trainings and to improve their ESG efforts.
Designated reference benchmark
No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by the Fund.
Date of publication: November 2023
Rosenthaler Strasse 72a
10119 Berlin
Germany
Berlin
Email (including for enquiries): contact@aminocollective.com
Web: www.aminocollective.com
Registered Office: Berlin
Registration Court: Amtsgericht Charlottenburg (Charlottenburg District Court)
Company Registration Number: HRB 222767
VAT Registration Number: DE 355159088
Amino Collective is legally represented by its Managing Director Manuel Grossmann.
Amino Collective is neither obliged nor willing to take part in any dispute settlement proceedings before a consumer arbitration board.