Aster Capital Partners is a management company accredited by the Autorité des Marchés Financiers (AMF) under the number GP 02 024

Aster Capital Partners SAS (Société par Actions Simplifiée)

Share Capital: €828,784

Siret: 41428656700071

RCS: 414286567

VAT Number: FR71414286567

Intellectual property

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Processing of personal data

Aster processes and collects personal data such as name, company, email address or phone number from you for the exclusive purpose of entering in contact with the team. You have a right of inquiry, access, rectification, deletion of data, restriction of processing, withdrawal of consent, portability, as well as a right to object to the processing of their data. You also have the right to send Aster Capital Partners a general or specific instruction concerning the storage, deletion and communication of your data after your death.

You can exercise these rights either by sending an e-mail to or a written letter addressed to 26 avenue de l’Opéra 75001 Paris, including a copy of an identity document.

Finally, you have the right to lodge a complaint with the Commission Nationale de l’Informatique et des Libertés (CNIL).

Complaint handling

Aster has established and maintains operational an effective and transparent procedure for reasonable and prompt handling of complaints received from investors. The complaints can be filed free of charge with the Management Company, by all the investors.

The claims and complaints of the investors are accepted either by means of a written letter or an electronic mail to the attention of the Finance team. The updated contact data of the Management Company and the team is provided on Aster website. Aster will acknowledge receipt of the complaint within a maximum period of ten days, and will examine it, including any relevant actions, without undue delay, and in any case not later than within sixty days of taking over the complaint.

In case of an ongoing dispute, the investors may contact the Autorité des Marchés Financiers mediator for any complaint.

Conflict of interest

Aster has established a cartography to identify the potential conflicts of interests that may arise and indicate the measures taken to prevent these conflicts. The conflict of interests’ situation that may arise are escalated to the RCCI.

The complete conflict of interest procedure is available on request.

Sustainability-Related Disclosure

Aster Capital Partners SAS (“Aster Capital”) publishes the following information in accordance with the Regulation (EU)2019/2088 on sustainability-related disclosures in the financial services sector (“SFDR”).

Sustainability risks definition and identification

In light of the SFDR regulation, Aster diligently focuses on identifying ESG (Environmental, Social, and Governance) and sustainability risks, as outlined in Article 3 of the SFDR.

A sustainability risk refers to any event or occurrence – be it environmental, social, or governance-related – that has the potential to adversely impact the long-term financial performance of an investment. These risks encompass a wide range of factors, from climate change effects and ethical business practices to changing regulations and social trends, all of which can influence the sustainability and profitability of investment portfolios. Aster takes sustainability risks into account in its decision-making process for all the investment funds managed.

A number of sustainability risks have been identified as potentially relevant to Aster’s investment sectors:

• Environment: climate change, physical risk, energy management, waste management, water management

• Social: diversity and inclusion, health and safety, social rights

• Governance: cybersecurity, customer privacy, business ethics, supply chain management

The consideration of these risks occurs throughout the entire investment process.

1. Sustainability risks during the pre-investment phase
1.1. Exclusion policy
Aster has defined a list of all the sector of activity excluded from the management company’s investment scope.

Investment team members are using this list of investment restrictions to identify whether the contemplated business would constitute a material breach against Aster’s prohibited or restricted investments, as defined in each fund by-laws. These include businesses in which Aster is not likely to invest (such as activities relating to weapons production and tobacco), or certain geographies (such as companies operating in high-risk and non-cooperative jurisdictions under the Financial Action Task Force).

The Management Company shall not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities:

a. whose business activity consists of an illegal economic activity (i.e., any production, trade or other activity, which is illegal under the laws or regulations applicable to the Funds or the relevant company or entity, including without limitation, human cloning for reproduction purposes); or

b. which substantially focus on:

i. the production of and trade in tobacco and distilled alcoholic beverages and related products;

ii. the financing of the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies;

iii. casinos and equivalent enterprises;

iv. exploitation or drilling of fossil fuel

v. the research, development or technical applications relating to electronic data programs or solutions, which

vi. aim specifically at:

· supporting any activity referred to under items (i) to (v) above;

· internet gambling and online casinos; or

· pornography, or

vii. are intended to enable to illegally:

· enter into electronic data networks; or

· download electronic data.

c. that have their principal place of business operations in high-risk and non-cooperative jurisdictions as listed and updated by the Financial Action Task Force (“FATF”).

In addition, when providing support to the financing of the research, development or technical applications relating to (i) human cloning for research or therapeutic purposes or (ii) genetically modified organisms (GMOs), the Fund shall ensure the appropriate control of legal, regulatory and ethical issues linked to such human cloning for research or therapeutic purposes and/or GMOs.

1.2. ESG Due Diligence
The investment team members use a due diligence grid to identify sustainability risks, i.e., red flags as well as the weaknesses of each investment opportunity studied with regard to sustainability risks. The ESG maturity of companies is assessed by applying a scoring system for all new investments made from June 2023.

This grid is also used by Aster to identify sustainability related opportunities related to an investment’s business model (geographic, diversification of services/products, market segment, etc.).

In this due diligence phase carried out by Aster’s investment team, sustainability risks are studied in relation to each company’s sector of activity and geographical location.

At the end of the investment process, ESG due diligence may be carried out by a third party, if necessary, on certain specific subjects.

If a sustainability risk is deemed significant and the company has not taken steps to mitigate the risk, Aster can choose either not to pursue the investment or to continue with the investment process under certain conditions, including an action to mitigate the risks. Aster is committed to proposing the implementation of a sustainability clause in the shareholder agreement and designing a 100-day plan to ensure that measures are put in place to mitigate the identified risks. As a minority investor, Aster will propose the implementation of these measures, but does not have the leverage to ensure that they are carried out systematically.


2. Sustainability risks during the holding phase
During the holding phase sustainability risks are monitored through:

•         A periodic reporting : Aster’s team uses an annual reporting grid to collect comprehensive periodic data based on the 3 ESG pillars for Article 9 funds.

•         An annual discussion during the board : As a minority investor, Aster supports the practice of discussing these risks at least once a year at the board, to ensure that they are monitored and to decide on actions to be taken to mitigate these risks when they are identified.

3. Sustainability risks during at exit
For Article 8 or Article 9 funds, Aster may share portfolio company’s ESG information at exit and at the request of the other parties.


Principal Adverse Impacts

Pursuant to Article 4 of the SFDR, Aster Capital is required to disclose whether the Principal Adverse Impacts (PAI) of investments decisions are considered on sustainability factors. The PAI are defined as the impacts of investment decisions that result in negative effects on sustainability factors.

Aster Capital considers the PAI of its investment decisions on ESG matters. The PAI are assessed during the due diligence phase, before investment decisions are made. Since the venture focus of the funds managed by Aster Capital, the contemplated targets are by nature innovative and orientated towards promoting better and more sustainable solutions. The analysis of a company performed by the investment team integrates the PAI, and gathers its available information, keeping in mind that Aster Capital invests in early-stage unlisted companies.


Integration of sustainability risks to the remuneration policy

Aster Capital has set up a remuneration policy which is designed to promote sound and effective risk management and not to encourage risk-taking that is inconsistent with the risk profiles of the funds managed. The remuneration of the team members is based on the allocation of a fixed remuneration and a bonus that is based on a mix of collective and individual performance, including for example the number of deals sourced, the quality of investors relations, and depends on the results of Aster Capital.

The remuneration policy integrates the compliance with the sustainability risk analysis as an indirect objective for the members of the investment team. This is notably monitored through the evaluation of the quality of the data collected from the portfolio companies, and of the analysis on how this data translates into mitigated sustainability risks for the sound development of these companies.