Sustainability Statement

About us:

Atempo Growth is a private debt growth investor focused on high-growth technology companies across Europe. We understand the importance of sustainability risks and the potential impact these can have on our fund, our firm, and our portfolio.

Investment process & ESG

As part of our investment process, Atempo considers ESG strategies of potential portfolio companies. Any material ESG issues are presented to the investment committee during the approval process and contribute to investment decisions.

As a lender we cannot significantly influence the ESG related policies of our portfolio companies. So while ESG reviews form part of our overall investment process, investment decisions will always be made on an assessment of the overall risk/return (not solely on ESG factors alone).

We want to ensure there is always space for ongoing discussion surrounding sustainability – to share ideas with the view to help influence and support change across our portfolio. To facilitate this, we currently invite all our portfolio companies to take part in the ESG_VC assessment framework as part of our investment due diligence process. ESG_VC is led by a steering group of funds and industry bodies and their framework helps early-stage companies better understand and improve their ESG performance, while providing anonymised data to the BVCA for industry monitoring.

Sustainability risks

Atempo considers “sustainability risks” to be events related to ESG that, if occurred, could cause a materially adverse impact to the value of the investment or directly to Atempo Growth. These impacts apply to our entire investment process, from sourcing to portfolio management and exit. We seek to address these matters in our investment committee papers using an ESG & Integrity framework on a deal-by-deal basis.

Furthermore, here are a few things we do to ensure minimal impact:

Restricted Sectors

Atempo will not invest or otherwise provide financial or other support, directly or indirectly, to companies or other entities whose business activity consists of an illegal economic activity.

Furthermore, the fund shall not invest in companies or other entities whose business activities substantially focus on the financing of the production of or trade in:

  • Tobacco;
  • cannabis;
  • distilled alcoholic beverages and related products;
  • weapons and ammunition of any kind;
  • Casinos and equivalent enterprises (including gambling and betting companies);
  • The research, development, or technical applications relating to electronic data programs or solutions which aim specifically at:
    • Supporting any activity referred to under items (a) to (c) above;
    • Internet gambling and online casinos; or
    • Pornography

Or which

  • Are intended to enable persons/groups to illegally enter into electronic data networks or download electronic data

The fund shall not invest in companies or other entities involved in, or related to, any activities involving harmful or exploitative forms of forced or child labour.

ESG & Integrity

In addition to restricted sectors, we take steps to avoid investing in businesses involved in other harmful practices. During our investment process, we do not recommend investment in any business where a substantial proportion of that business incorporates:

  • Any projects or activities located in areas classified as Ramsar Sites, World Heritage Sites or by the International Union for Conservation of Nature (IUCN) as categories I, II, III or IV
  • Oil & Gas:
    • any projects, or expansion of existing facilities, north of the Arctic Circle
    • any projects involved in the exploration, development, construction or expansion of unconventional oil & gas (e.g. tar sands/fracking / coal bed methane);
  • Power generation: coal fired power generation/nuclear power plants / liquid natural gas facilities;
  • Mining & Metals: extraction, processing, marketing, mining activities or projects related to:
    • Asbestos;
    • Rough diamonds and precious minerals and metals;
    • Coal mining;
    • Uranium;
    • Mining activities without a specific treatment to avoid tailings disposal in riverine or shallow sea environments;
  • Soft commodities:
    • Extractions and sale of native tropical wood species.
    • Processors of palm oil;
    • Activities that create the expansion of the agricultural/plantations frontier to the detriment of natural forest;
    • Activities with an impact on tropical forests.

We will institute and maintain internal control procedures designed to:

  • confirm the integrity of individuals and entities associated with potential Portfolio Companies and the individuals and key institutions associated with them (including directors, managers, shareholders, suppliers/customers able to exercise significant influence and;
  • prevent the Company or any Portfolio Company from being involved in any money laundering or tax evasion scheme, fraud or other criminal or terrorist

Principle Adverse Impact Statement, SFDR and UN PRI

The European Union Sustainable Finance Disclosure Regulation 2019/2088 (”SFDR”) Atempo is required to make entity-level disclosures on how the firm assesses Principle Adverse Impacts (PAI) and establishes fund level-disclosures on a “comply” or “explain” basis. PAI data is often not readily available, and difficult to collect, particularly given the nature of the companies we invest in. Atempo focuses on high-growth, tech-enabled businesses across Europe, from Series A to pre-IPO. Typically, these companies will be scale-ups, and therefore lacking the framework needed for stringent reporting on PAI.

After careful consideration surrounding these difficulties for growth-stage companies we have made a deliberate choice to not yet report publicly on the principal adverse impacts of our investment decisions, in accordance with the Disclosure Regulation. We are confident that the companies we partner with have a positive impact on society, demonstrated through factors such as job creation and improved efficiencies across a multitude of sectors, from logistics to SaaS and beyond.

Atempo has incorporated a range of ESG-related considerations throughout our business operations and investment processes, and has an ongoing commitment to improvement in this area.

Integrating ESG at a firm level

Diversity and inclusion

At Atempo Growth we embrace and value diversity in all its forms, whether gender, age, ethnicity, or cultural background. Equal opportunity is integral to our recruitment process and internal promotion processes and outcomes, as we aim to develop a team of diverse talent.

We strive to maintain a positive workplace, free from discrimination and harassment. We champion pay equity and mutual respect, promoting an environment of fairness and equality.


While there are no KPIs directly linked to remuneration, we take into consideration ESG factors when assessing the performance of our investment team. This is just one of many factors we consider during performance and remuneration reviews. Our co-founders, along with the financial director, conduct annual salary reviews to ensure that all employees are compensated fairly for comparable work across the team. Any variances in salary are due to legitimate role-related factors.

Remuneration levels of employees are justified according to the performance of the individual concerned, as reviewed on a regular basis. Whilst the policy does not fully integrate sustainability risks, the performance evaluation of an employee may include consideration for ESG contribution.

Next steps

Atempo Growth is dedicated to evolving and improving our performance in ESG and sustainability matters. Our ESG Policies are regularly reviewed and updated by our ESG Committee, and we seek to keep our employees informed and engaged on these topics as we grow in terms of our portfolio and our team.