Sustainability Policy

Introduction

This policy sets out Atomico’s approach to sustainability which incorporates both our responsible investment practices and our management of Environmental, Social and Governance (“ESG”) factors within our business operations and investment activities. Below we have set out the principles that the firm follows and the processes we have implemented in order to deliver on our sustainability objectives. All Atomico staff are required to adhere to this policy.

Our approach to Sustainability

Sustainability is at the core of Atomico’s investment philosophy, mission and values - integrated under the banner of “Conscious Scaling”. Our objective is for Atomico and the companies we partner with to be genuinely focused on doing well for all stakeholders: employees, customers, suppliers, shareholders, the environment and the wider world at large. We firmly believe that responsible business practices help generate superior long-term performance. 


Sustainability within our operations

  • Environmental impact: Atomico has implemented a climate strategy based on the principles of measure, reduce, remove and report, to ensure we are accountable for our impact on the environment. We measure our scope 1,2 & 3 GHG emissions (including 3.15 financed emissions) annually through a third party verifier. We have targets and initiatives in place to reduce our emissions such as 100% adoption of renewable energy, green procurement, waste management and sustainable business travel. We have implemented an internal carbon fee based on our annual emissions which we donate each year to verified climate projects focused on durable carbon removal, nature restoration and protection, and decarbonization. And finally, we report our annual GHG emissions and progress against our reduction targets annually through our Conscious Scaling sustainability report. 

  • Responsible supply chain: Atomico is committed to the responsible use of resources and encourages its employees and budget holders through its Sustainable Supplier Policy to help ensure the procurement, purchase and use of products and services is aligned with our environmental and social values.

  • Promoting diversity, equity and inclusion: Atomico is an equal opportunities employer and we respect the diversity of our people. Our aim is to attract, motivate, develop and retain a diverse and talented group of people while also providing a working environment that promotes inclusion. See our Diversity, Equity and Inclusion policy for more information on the initiatives we have in place.

  • Maintaining strong ESG governance: Our Management Committee has overall responsibility for our sustainable business practices and responsible governance. Atomico provides employees with specific training and resources to help them fulfil the firm’s sustainability targets, commitments and objectives. 

  • Integrating ESG within our remuneration framework: Remuneration for Atomico’s staff is based on an annual appraisal process which considers a variety of factors but includes the extent to which staff members promote the firm’s guiding principles and adhere to the firm’s policies (including this Sustainability policy). A significant portion of overall remuneration for senior staff members is also linked to the long-term performance of the Atomico funds. We consider this approach, which aligns the interest of staff members with those of our limited partners, to be appropriate to promote a culture of reducing long-term ESG risks within our portfolio and creating long term value and financial performance for our funds and other stakeholders.

  • Engaging with our limited partners: Atomico is transparent with our limited partners in the Atomico funds regarding ESG matters. Atomico proactively includes ESG information in our quarterly reports and provides updates on ESG issues and programmes at our annual Investor Summit and at our advisory board meetings. Atomico reports on the progress of its ESG initiatives through its annual Conscious Scaling report which is publicly available on our website. Atomico also collaborates with its limited partners on ESG through specific side letters where appropriate.

  • Engaging with ecosystem stakeholders: Atomico actively engages with stakeholders in the ecosystem on championing Sustainability within the tech industry. These activities include:

Sustainability within our investment activities

  • Exclusion list: Atomico has an exclusion list which in addition to excluding a number of industries & sectors such as weapons, fossil fuels, real estate, alcohol, tobacco and pornography, also ensures we do not invest in companies that;

    • Have contributed to a systematic denial of basic human rights

    • Show a pattern of engaging in child labour or forced labour

    • Demonstrate a pattern of non-compliance with environmental regulations

  • ESG term sheet clauses: Our ESG term sheet clauses for rounds we lead cover:

    • Ensuring a DEI policy and ESG policy within 3 months post-close

    • Implementing a DEI strategy within 6 months post-close

    • Measuring emissions within 12 months post-close

    • Appointing a member of the management team responsible for ESG

  • Atomico has made a commitment to not provide follow-on funding to any company which proves non-compliant with these clauses.

  • Diversity in our portfolio: Atomico aims to find and invest in the best and most ambitious founders from a diverse set of demographics, backgrounds, and experiences to maximise fund performance. Atomico’s evaluation process is impartial and structurally designed to ensure we evaluate opportunities from a diverse perspective and identify biases and blind spots. For more information on our initiatives, see our Diversity, Equity and Inclusion policy.

  • Human rights and digital ethics: Atomico is aware that, at scale, the products from the companies we partner with could have a profound impact on society, both positive and negative. Atomico strives to identify, assess and monitor these issues within the companies we partner with - which are often unforeseen and unintended during the formative early years - and supports founders in their efforts to safeguard and mitigate against them. Atomico also incorporates human rights risks into its due diligence evaluations where appropriate. 

  • Pre-investment screening: As part of our screening process, Atomico’s investment teams assess a company’s ESG-related risks and related factors and present their findings to our Investment Committee at preliminary investment review.

  • Pre-investment due diligence: Once a potential investment reaches confirmatory due diligence, our Sustainability team run a robust ESG due diligence process with the portfolio company where by we ask the founder to complete a detailed ESG questionnaire designed to identify potential ESG issues, risks and opportunities material to the company, and the existing business processes the company has in place to address them. The Sustainability team then follows up with an in person (where possible) conversation with the founder to discuss the company's understanding of the risks & issues identified and their long term approach to ESG. The output of the questionnaire & conversation with the founder is presented to the firm's Investment Committee at final investment review. Where appropriate or deemed necessary, Atomico will also instruct external experts to perform additional ESG due diligence on potential portfolio companies. If the Investment Committee concludes that the ESG risks related to a potential investment are too great and/or cannot be appropriately mitigated in a reasonable timeframe, no investment is made. 

  • Post-close Conscious Scaling: Conscious scaling refers to the programme of initiatives and tools we have developed to help the companies we partner with integrate ESG best practise into their business operations. Our Conscious Scaling roadmap helps companies understand what initiatives they should have in place when it comes to ESG according to their size and stage, and helps them identify what initiatives they should look to introduce next. Atomico provides portfolio companies with access to materials and policy templates, plus a network of sustainability experts & specialist consultancies.

  • Monitoring and engagement: Atomico annually surveys its entire active portfolio on ESG KPI’s and metrics so we can track and monitor their ESG performance and engagement. This helps us to identify companies that may need our help and support. The partners and investment teams at Atomico take an active interest in how our portfolio companies manage ESG issues and in their capacity as board members actively encourage, support and stretch our portfolio companies to strive for the very best ESG standards.

  • Portfolio ESG engagement targets: Atomico has set targets for ESG engagement within our portfolio related to measuring emissions, adoption of near term decarbonisation targets, adoption of DEI and ESG policy and assigning responsible ESG board members. We publish our progress towards these targets annually in our Conscious Scaling sustainability report. 

  • ESG support at exit: As an early stage investor, Atomico is limited in its ability to dictate the route and timing of a portfolio company's potential exit. However we seek to collaborate with potential interested parties in sharing information on ESG (where appropriate) and support our portfolio companies with their ESG initiatives in readiness for the transition.

  • Adoption of ESG standards and frameworks: Atomico is a PRI signatory and commits to their guidelines in relation to responsible investment practices. 

  • European Union Sustainable Finance Disclosure Regulation 2019/2088 (“SFDR”): Atomico’s latest funds, Atomico Venture VI ScSp & Atomico Growth VI ScSp are aligned with Article 8 under SFDR - promoting environmental and social characteristics

Principal Adverse Impact Statement 

Atomico is not required to and does not take into account the principal adverse impacts (PAI’s) of its investment decisions on sustainability factors as set out under the European Union Sustainable Finance Disclosure Regulation 2019/2088 (“SFDR”) 


Atomico has chosen to adopt a best effort approach to assessing the main negative impacts of its investments, selecting the most relevant indicators proposed by the Disclosure Regulation alongside other sustainability indicators it feels relevant and appropriate to the size and stage of its underlying investments. 

Approval

This policy is updated at least once per annum and has been approved by the firm’s Management Committee.