10x Founders GmbH

Brienner Str. 21
D-80333 München

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Managing Directors: Rupert Schäfer and Jan Reichelt
Contact: info@10xfounders.com

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Register Entry: Amtsgericht München - HRB 259670
VAT identification number in accordance with § 27a of the German Value Added Tax Act (Umsatzsteuergesetz): DE340823788

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Competent Supervisory Authority:

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin) with offices inGraurheindorfer Straße 108, 53117 Bonn as well as Marie-Curie-Str. 24-28, 60439 Frankfurt am Main

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Internet: https://www.bafin.de

‍Email: poststelle@bafin.de

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‍‍Please note that this website does not address consumers or retail investors.

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Key information Document / Basisblatt in accordance with EU regulation no 1286/2014

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Processing of data

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Due to our statutory obligation under § 5 para. 3 of the German Telemedia act (Telemediengesetz) 10x Founders’ website contains information which makes it possible to contact our company quickly in electronic form and to directly communicate with us. If you decide to contact us, for example via e-mail, the personal data you transmitted is automatically stored in order to process your request. The legal basis for such processing and storage is art. 6 para. 1, lit. c) of the EU General Data Protection Regulation. Under the EU General Data Protection Regulation, you are entitled to request which communication we process and have stored, or to request to delete any communication you sent us, or to restrict processing and storing of such communication.

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Disclaimer

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1. Accountability for content
   the contents of our pages have been created with the utmost care. however, we cannot guarantee the contents’ accuracy, completeness or topicality. according to statutory provisions, we are furthermore responsible for our own.
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2. Accountability for links
   Responsibility for the content of external links (to web pages of third parties) lies solely with the operators of the linked pages. No violations were evident to us at the time of linking. Should any legal infringement become known to us, we will remove the respective link immediately.
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3. Copyright
   Our web pages and their contents are subject to German copyright law. Unless expressly permitted by law (§ 44a et seq. of the copyright law), every form of utilizing, reproducing or processing works subject to copyright protection on our web pages requires the prior consent of the respective owner of the rights. Individual reproductions of a work are allowed only for private use, so must not serve either directly or indirectly for earnings. Unauthorized utilization of copyrighted works is punishable (§ 106 of the copyright law).

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SFDR Disclosures

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Disclosures pursuant to the Sustainable Finance Disclosure Regulation (EU) 2019/2088 (“SFDR”)

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• Date of publication: January 2021.
• Date of update: May 2024; amendment of existing published information to ensure compliance with updated regulatory requirements.
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1. Sustainability Risks
   10x Founders GmbH (“10x”, LEI: 3912002ZVYOTIRQX7717) 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. 10x 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 through an informal process as appropriate in light of the circumstances of the individual case. The results of such assessment are considered on a non-binding basis when the investment decision is taken. However, 10x remains free in its decision to refrain from investing or to invest despite sustainability risks, in which case 10x can also apply measures to reduce or mitigate any sustainability risks. At all times, 10x will apply the principle of proportionality taking due account of the strategic relevance of an investment as well as its transactional context.
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2. No consideration of adverse impacts of investment decisions on sustainability factors
   10x does not consider any adverse impacts of its investment decisions on sustainability factors and, hence, does not use the sustainability 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 Regulation (EU) 2020/852 (“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. 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. Hence, at 10x we believe that the information provided to us by our portfolio companies in relation to the investments is not yet sufficient (in particular with a view to the RTS) to meet those reporting requirements. However, 10x will monitor developments with regard to available information and evolving market practice, if any, and reasonably consider disclosing the information required by the Art. 4 SFDR (including the RTS) once sufficient information flow can be ensured and a reasonable market practice has been established.
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3. Renumeration disclosures
   As a registered alternative investment fund manager within the meaning of section 2 (4) of the German Investment Code (Kapitalanlagegesetzbuch, “KAGB”) and a manager of a qualifying venture capital fund as defined in Art. 3 (b) of Regulation (EU) No. 345/2013 (“EuVECA-Regulation”), 10x does not have and does not need to have a remuneration guideline or policy in accordance with the requirements of the KAGB or the EuVECA Regulation. Sustainability risks are not considered with respect to the determination of the remuneration.
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4. Sustainability-related disclosures

1. 10x Founders Fund GmbH & Co. KG

Financial product: 10x Founders Fund GmbH & Co. KG (the “Fund” / der “Fonds”)

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LEI: 391200R7PP52PP6UF316

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Summary

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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 the investments by incorporation of investment exclusions (negative screening). For this purpose, information is initially and regularly obtained from the portfolio companies by means of qualitative queries. The actions and decisions described in the following section are each made by 10x for and on behalf of the Fund.

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Zusammenfassung

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Der Fonds berücksichtigt bestimmte ökologische und/oder soziale Merkmale im Rahmen seiner Investitionsentscheidungen und Monitoring-Prozesse, strebt aber keine nachhaltigen Investitionen im Sinne der SFDR an. Die Berücksichtigung von Umwelt- und/oder Sozialmerkmalen erfolgt sowohl vor als auch nach den Investitionen durch die Einbeziehung von Investitionsausschlüssen (negatives Screening). Zu diesem Zweck werden Informationen von den Portfoliounternehmen durch qualitative Abfragen eingeholt. Die in diesem Abschnitt beschriebenen Handlungen und Entscheidungen erfolgen jeweils durch 10x für den Fonds.

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No sustainable investment objective

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The Fund promotes environmental or social characteristics, but does not have as its objective sustainable investment.

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Environmental or social characteristics of the financial product

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This financial product promotes environmental and/or social characteristics by implementing certain investment exclusions.

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Investment strategy

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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 investments in Portfolio Companies in the digital tech sector with innovation capacity and growth potential, including, but not limited to, software, AI, data, robotics, platforms, marketplaces, consumer and hardware with software components. As such, investments are expected to be spread across a wide range of economic activities. The Fund intends to make its initial investments in the early stage, i.e., pre-seed, seed and series A rounds. The Fund’s ESG approach comprises part of its investment strategy, which is consistently applied for every portfolio company investment.

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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.

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The Fund shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies, including portfolio companies, or other entities:

1. Performing research and innovation activities considered as illegal in Germany;
2. Any economic activity considered as illegal in Germany;
3. The production of, and trade in, tobacco, distilled alcoholic beverages and related products;
4. The financing and production of, and trade in, weapons and ammunition of any kind;
5. Casinos and equivalent enterprises (with, for the avoidance of doubt, the exception of gaming and e-sports);
6. 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) pornography; or (iii) are intended to enable to illegally (A) enter into electronic data networks; or (B) download electronic data.

Good governance practices are assessed through an informal process as appropriate in light of the circumstances of each individual case. Such practices include, in particular, sound management structures, employee relations, remuneration of staff and tax compliance within the portfolio companies. The Fund will conduct regular monitoring of the good governance practices in its portfolio companies during the holding period on an ad-hoc basis. If the Fund becomes aware of severe governance issues, it will investigate them and work with all parties involved to find an appropriate solution.

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Proportion of investments

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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 no. 17 SFDR or environmentally sustainable investments within the meaning of Art. 3 Taxonomy; hence, no portion of its investments will be aligned with the Taxonomy.

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Monitoring of environmental or social characteristics

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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 on an ad-hoc basis and will carry out further checks if there are indications of potential issues with such characteristics. External monitoring mechanisms are not provided.

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Methodologies for environmental or social characteristics

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Currently the Fund applies qualitative assessments with regard to environmental or social characteristics (i.e., its investment exclusions). The Fund conducts an initial assessment of the promoted environmental or social characteristics via an informal process in the course of the due diligence. Based on the results of such assessment the Fund identifies pre-investment whether the environmental or social characteristics promoted by the Fund are met. During the holding period, the so conducted assessment forms the basis to monitor on an ad-hoc basis if the characteristics are continuously being met.

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Data sources and processing

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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 in the course of the due diligence conducted prior to each investment. Moreover, during the holding period, the Fund relies on publicly available date to check the compliance with the investment exclusions. An internal or external review or verification of the information obtained will be carried out if misrepresentations are suspected.

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Limitations to methodologies and data

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The information collected from the (potential) portfolio companies through the informal process carried out by the Fund is 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 investment is 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). Further limitations, in particular with regard to the accuracy of the data and reliability of the data sources used, are not apparent at this time.

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Due diligence

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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. 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.

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Engagement policies

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Engagement is not part of the environmental or social investment strategy of the Fund.

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Designated reference benchmark

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

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2. 10x Founders Fund II GmbH & Co. KG
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The disclosures relating to 10x Founders Fund GmbH & Co. KG apply accordingly to 10x Founders Fund II GmbH & Co. KG (LEI: 391200XBS485Y1219E87).

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