Mandatory disclosures under Regulation of the European Parliament and of the Council on Sustainability-Related Disclosures in the financial services sector (EU) 2019/2088 (“SFDR”)‍

Summary

The Blue Revolution Fund L.P. (the “Fund” or “the BRF”) invests in sustainable aquaculture and alternative seafood ventures, aiming to generate competitive returns while protecting ocean ecosystems. The Fund focuses on early-stage companies (Seed and Series A) and applies rigorous upfront ESG screening and ongoing monitoring, conducted in partnership with its Conservation Manager, The Nature Conservancy (TNC).

The Fund is classified as an Article 8 financial product under the Sustainable Finance Disclosure Regulation (SFDR). It promotes environmental and social characteristics but does not have sustainable investment as its objective under Article 2(17) of SFDR. At least 80% of the Fund’s capital is allocated to investments that promote environmental and/or social characteristics. The Fund integrates ESG considerations throughout its investment process. Investments undergo rigorous upfront screening and ESG due diligence to ensure alignment with the Fund’s environmental and social objectives. Key metrics tracked include habitat-producing farm area, CO2 avoidance, nitrogen removal, sustainable seafood production, and job creation.

Portfolio companies are monitored annually through tailored Impact Action Plans, with additional site visits conducted as needed. While the Fund relies on self-reported data from portfolio companies, validation efforts include monitoring calls, site visits, and cross-checking against industry standards.

The Fund adheres to internationally recognized standards, such as the IFC Performance Standards, the UN Biodiversity Convention, and OECD Guidelines for Multinational Enterprises. An exclusion list, aligned with European Development Finance Institutions (EDFI), ensures compliance with best practices.

The Fund does not make sustainable investments within the meaning of Article 2(17) of SFDR or investments aligned with the EU Taxonomy. No reference benchmark is designated to measure the environmental or social characteristics promoted by the Fund.‍

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No sustainable investment objective

The Fund promotes environmental or social characteristics but does not have sustainable investment as its objective under Article 2(17) of SFDR.

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Environmental or social characteristics of the financial product

The Fund integrates environmental, social, and governance (ESG) considerations throughout its investment process. It collaborates closely with TNC, from investment decision-making to ongoing portfolio management, ensuring compliance with ESG criteria and achieving measurable conservation impacts.

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The Fund’s primary environmental and social metrics include:

• Habitat-producing farm area (ha)
• Nitrogen removed (kg)
• CO2 equivalents avoided (tonnes)
• Ocean area affected by aquaculture with improved environmental performance (ha)
• Portions of sustainable seafood produced (#)
• Direct/indirect jobs created (#)

To ensure strict adherence to the ESG mission of the Fund, all proposed investments require an up-front screening. The Investment Committee will only consider proposed investments that have successfully passed the ESG Due Diligence process. The Investment Committee will not make investments into companies that have not passed the ESG Due Diligence process.

In addition, the Fund is fully committed to complying with nationally and internationally recognised standards, procedures, regulations, and guidelines, including:

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Relevant Market Best Practices

• National legislation and regulations
• International Finance Corporation’s (IFC) Policy on Social and Environmental Sustainability and its Performance Standards
• The three objectives of the United Nation’s Convention on Biodiversity
• The United Nations Code of Conduct for Responsible Fisheries
• The United Nations Technical Guidelines on Aquaculture Certification

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SFDR Minimum Safeguards

• OECD’s Guidelines for Multinational Enterprises
• UN Guiding Principles on Business and Human Rights
• International Labour Organisation (ILO)’s Declaration on Fundamental Principles and Rights at Work
• International Bill of Human Rights

The Fund’s exclusion list is harmonized with The European Development Finance Institutions’ (EDFI) exclusion list of undesirable businesses.

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‍Investment strategy

The purpose of the Fund is to invest in early stage ventures across sectors such as :

• Innovative sustainable aquaculture technologies
• Scalable and sustainable aquaculture farms employing novel technologies
• Alternative seafood products leveraging defensible technologies
• Regenerative (i.e., seaweed and shellfish) with scalable systems

The portfolio is diversified by market, geography, risk profile, and company lifecycle. While focusing on the European Economic Area, investments are also made in Asia-Pacific and the United States. The Fund uses equity and convertible equity as its primary instruments.

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‍Proportion of investments

The Fund allocates a minimum of 80% of its capital to ventures that promote environmental and/or social characteristics in accordance with SFDR Article 8.

The remaining portion may be held in cash or cash equivalents, or used for operational purposes, such as managing liquidity, pending deployment into qualifying investments, or other fund operations. 

The Fund invests in ventures that promote environmental and/or social characteristics but do not have sustainable investment as its objective at this time. The Fund does not make and does not intend to make sustainable investments within the meaning of Article 2(17) of SFDR or environmentally sustainable investments within the meaning of Article 3 of the EU Taxonomy Regulation; hence, no portion of its investments will be aligned with the EU Taxonomy.

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‍Monitoring of environmental or social characteristics

Portfolio companies must report progress against KPIs outlined in their Impact Action Plan annually. This ensures continuous improvement beyond the baseline ESG standards.

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‍Methodologies

Quantitative assessments are applied to measure environmental and social characteristics. Monitoring visits, scheduled annually to every 36 months, validate ESG reporting and track progress. Additional visits may be conducted at the discretion of the Conservation Manager.

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‍Data sources and processing

Environmental and social data are sourced from portfolio companies and reviewed by the Conservation Manager. While self-reported data is prevalent, efforts are made to identify misrepresentation through regular monitoring and site visits.

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‍Limitations to methodologies and data

The Fund relies on data collected from portfolio companies through questionnaires and reporting as part of the due diligence and monitoring processes. While these data provide critical insights into the environmental and social characteristics promoted by the Fund, the nature of self-reported data necessitates a high level of estimation for certain metrics.

The information provided by portfolio companies is internally or externally verified only if and to the extent that misrepresentations are suspected. Consequently, there is a possibility that false information may remain undetected in certain cases.

To mitigate these limitations, the Conservation Manager conducts regular monitoring calls and site visits, aiming to validate data and uphold high standards of accuracy and reliability. Data are cross-checked for consistency and completeness against industry standards where possible, ensuring robust and credible reporting processes.

Despite these measures, the inherent reliance on self-reported data introduces unavoidable challenges. The Fund remains committed to maintaining rigorous data quality standards and continuously improving its methodologies to enhance the reliability of reported information.

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‍Due Diligence

An initial assessment of how an investment relates to the environmental and/or social characteristics promoted by the Fund is carried out as part of the due diligence process by the Conservation Manager. The ESG review process includes initial ESG screening, where all proposed investments must go through upfront screening, and ESG due diligence. The detailed ESG Due Diligence Review is a risk assessment process which quantitatively and qualitatively assesses potential negative environmental impacts posed to the proposed investments across 10 key ESG categories: 

• Company governance
• Management measures
• Impacts to wild stocks including: sources of fry, escapes and genetic interactions, macrofauna interactions, feed use
• Habitat impacts
• Water pollution impacts
• Disease and chemical use
• Freshwater and land use
• Energy use
• Community and social impacts‍

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Engagement Policies

Engagement forms part of the environmental or social investment strategy of the Fund. The Fund will engage with its portfolio companies should principal adverse impacts become apparent. Further, should the Fund determine any potential issues relating to its environmental and/or social characteristics in its portfolio companies, the Fund will engage with the respective portfolio companies to resolve, reduce or mitigate any adverse effects. Yet, it remains at the sole discretion of the Fund to determine which efforts are appropriate and proportionate in light of the size and strategic importance of the respective investment in the portfolio company, as well as the bargaining positions and the transactional context.

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‍Designated reference benchmark

No index has been designated as a reference benchmark to meet the environmental or social characteristics promoted by the Fund.

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