Sustainability-related disclosures
Redstone BLUE Fund I Ky. Article 8 SFDR website disclosure.
Mandatory disclosures under Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector (SFDR)
Last edited: October 2026 · Redstone Nordics Oy
A Redstone Nordics Oy · B Redstone BLUE Fund I Ky
ARedstone Nordics Oy
ITransparency of sustainability risk policies (Article 3 SFDR)
Redstone Nordics Oy (the “Fund Manager”) is a long-term investor that recognises its responsibility towards its investors, its portfolio companies and the wider ecosystem in which they operate. For the purposes of this disclosure, a sustainability risk is an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment (Article 2(22) SFDR).
The Fund Manager integrates sustainability risks into its investment decisions at three points. Before an investment, each opportunity is screened against the applicable exclusion list, and sustainability risks are assessed in the due diligence and risk assessment process, including a review of potential negative environmental externalities and of the target’s governance, labour, human rights and anti-corruption practices. The results are documented in the investment memorandum and considered by the investment committee. After an investment, the Fund Manager manages sustainability risks through active board participation or board observer roles where available, and through regular monitoring of each portfolio company.
IINo consideration of principal adverse impacts of investment decisions on sustainability factors (Article 4 SFDR)
The Fund Manager does not currently consider the principal adverse impacts of its investment decisions on sustainability factors within the meaning of Article 4(1)(b) SFDR. The Fund Manager has fewer than 500 employees and is therefore not subject to the mandatory statement under Article 4(3) and (4) SFDR.
The Fund Manager invests in early-stage, unlisted companies. For such companies, reliable data on the principal adverse impact indicators set out in Annex I of Commission Delegated Regulation (EU) 2022/1288 (the “SFDR RTS”) is in most cases not available, and producing it would place a disproportionate burden on young companies with small teams. Instead, the Fund Manager applies a qualitative assessment of potential harm to environmental objectives and of minimum governance and social safeguards, as described in Part B. The Fund Manager will review this position annually and intends to reconsider it as its portfolio companies mature and the availability of data improves.
IIITransparency of remuneration policies in relation to the integration of sustainability risks (Article 5 SFDR)
The Fund Manager is a registered alternative investment fund manager within the meaning of the Finnish Act on Alternative Investment Fund Managers (162/2014). The remuneration policy requirements of that Act apply to authorised alternative investment fund managers and not to registered ones. Accordingly, the Fund Manager does not maintain a remuneration policy within the meaning of that Act, and the integration of sustainability risks is not considered in the determination of remuneration.
BRedstone BLUE Fund I Ky
Disclosure of sustainability-related information about financial products promoting environmental or social characteristics (Article 10 SFDR and the SFDR RTS) · Legal entity identifier (Finnish Business ID): 3546642-5
1Summary
Redstone BLUE Fund I Ky (the “Fund”), managed by the Fund Manager, promotes environmental characteristics within the meaning of Article 8 SFDR. It does not have sustainable investment as its objective and does not commit to making sustainable investments within the meaning of Article 2(17) SFDR.
The Fund invests in early-stage, unlisted companies in the blue economy, in the Baltic Sea region, Europe and rest of the world with a focus on sectors such as water management, marine ecosystem protection, the energy transition in shipping, marine observation & data, blue renewable energy, and sustainable port and logistics operations. The environmental characteristics promoted are the decarbonisation of shipping, the sustainable use of marine resources, clean water technologies and ecosystem preservation.
The binding elements of the investment strategy are thematic alignment with the blue economy, ESG screening including the exclusion of investments that cause significant harm to environmental or social objectives, monitoring of portfolio companies’ ESG reporting, and post-investment engagement. At least 80% of the Fund’s investments are aligned with the environmental characteristics it promotes. The remaining portion of up to 20% consists of cash, cash equivalents and ancillary instruments held for liquidity purposes. The Fund does not commit to any minimum proportion of sustainable or EU Taxonomy-aligned investments.
Each potential investment is assessed with the Fund’s impact assessment rubric, which scores six criteria on a four-step scale. After investment, portfolio companies are encouraged to report on two to four key performance indicators from the Ocean Impact Navigator when the company stage, operations and headcount make such reporting meaningful. After taking the KPIs into use, they are updated annually. Companies are re-scored annually and reviewed semi-annually for potential harm, governance and emerging risks. Data comes mainly from the portfolio companies themselves and, given their early stage, may in part rest on estimates. The Fund Manager engages with portfolio companies through board roles and hands-on support. No reference benchmark has been designated.
2No sustainable investment objective
This financial product promotes environmental characteristics, but does not have as its objective sustainable investment.
The Fund does not commit to making sustainable investments within the meaning of Article 2(17) SFDR. Its due diligence nevertheless includes a qualitative assessment of whether a target company could cause material harm to the environmental characteristics the Fund promotes, and of the company’s minimum governance and social safeguards (see section 10). This assessment is an internal screening tool and does not constitute a “do no significant harm” assessment within the meaning of SFDR.
3Environmental or social characteristics of the financial product
The Fund promotes environmental characteristics by investing in early-stage companies whose products and services address the sustainability challenges of the blue economy, primarily in the Baltic Sea region. The Fund focuses on innovations in areas such as:
- Water management — water and marine resource management and clean water technologies.
- Marine ecosystem protection — solutions that protect and preserve marine ecosystems, including technologies that monitor their condition.
- Energy transition in shipping — solutions that decarbonise shipping.
- Blue renewable energy — renewable energy generated at sea or from water, and related climate-resilient infrastructure.
- Sustainable port and logistics operations — solutions that reduce the environmental footprint of ports and maritime logistics.
- Marine observation and data — solutions that help monitor and observe marine environments and maritime infrastructure.
At least 80% of the investments made by the Fund are aligned with the environmental characteristics it promotes: the decarbonisation of shipping, the sustainable use of marine resources, clean water technologies and ecosystem preservation. To make these characteristics concrete, the Fund assesses every investment against four selected UN Sustainable Development Goals: SDG 6 (Clean water and sanitation), SDG 8 (Decent work and economic growth), SDG 13 (Climate action) and SDG 14 (Life below water). It also assesses the contribution to reducing pressure on five planetary boundaries: climate change, biogeochemical flows, biosphere integrity, ocean acidification and freshwater change.
4Investment strategy
The Fund builds, holds and manages a portfolio of equity and equity-related minority investments in early-stage, unlisted companies aligned with the blue economy themes set out in section 3, primarily in the Baltic Sea region. The Fund applies a thematic investment approach and integrates environmental and social considerations into sourcing, pre-screening, due diligence, the investment decision and portfolio management. The Fund prioritises companies whose environmental benefit is inherent to the business model, so that the positive effect grows as the company grows.
Binding elements
- Thematic alignment — all portfolio companies must operate within the blue economy sectors or closely aligned industries and demonstrate potential for environmental impact or alignment with climate and marine sustainability themes.
- ESG screening — investments that cause significant harm to environmental or social objectives, including companies involved in environmentally harmful practices, are excluded. The screening is carried out with the impact assessment rubric described in section 10.
- Monitoring — portfolio companies are encouraged to report on relevant ESG key performance indicators, particularly those related to environmental impacts when the company stage, operations and headcount make such reporting meaningful.
- Engagement — the Fund engages with companies post-investment to improve ESG performance and reporting where appropriate.
Exclusions
Investments in excluded sectors are avoided. The Fund does not invest in companies involved in:
- fossil fuels;
- tobacco;
- weapons, including controversial weapons;
- environmentally harmful practices or other activities that cause significant harm to environmental or social objectives; or
- severe violations of international norms, including human rights standards and the labour rights set out in the ILO fundamental conventions and the International Bill of Human Rights.
There is no committed minimum rate by which the investment universe is reduced before the investment strategy is applied.
Policy to assess good governance practices
The Fund assesses the good governance practices of potential portfolio companies in due diligence, covering compliance with applicable laws and regulations, governance structures such as board oversight and shareholder rights, business ethics and anti-corruption, and labour rights and working conditions. Governance maturity is also scored as part of the minimum safeguards criterion of the impact assessment rubric. Ongoing governance monitoring is conducted through active engagement and representation on company boards when appropriate.
5Proportion of investments
At least 80% of the Fund’s investments are aligned with the environmental characteristics it promotes (#1 Aligned with E/S characteristics). These investments are selected on the basis of the binding elements described in section 4. The Fund does not commit to making sustainable investments; the minimum proportion of sustainable investments is therefore 0%. The Fund does not commit to investments aligned with the EU Taxonomy (Regulation (EU) 2020/852); the minimum proportion of Taxonomy-aligned investments, including in fossil gas and nuclear energy, is 0%.
Up to 20% of the Fund’s assets may be held in cash, cash equivalents and other ancillary instruments for liquidity purposes or pending investment or distribution (#2 Other). These holdings do not promote environmental characteristics; minimum safeguards apply through the general exclusion criteria. The Fund does not use derivatives to attain the environmental characteristics it promotes.
6Monitoring of environmental or social characteristics
The attainment of the environmental characteristics and the sustainability indicators is monitored throughout the holding period:
- Annual impact review — each portfolio company is re-scored with the impact assessment rubric, so that red flags are detected early and year-on-year progress is visible.
- Key performance indicators — at onboarding, portfolio companies are encouraged to select two to four key performance indicators from the Ocean Impact Navigator, which are updated annually and aggregated at portfolio level where comparable, for example for climate, pollution and waste to water, and restored ocean area.
- Semi-annual check-ins — qualitative review of potential harm, governance and emerging environmental risks.
- Exclusions — compliance with the exclusions is confirmed before each investment and reviewed in the annual impact review.
Monitoring is carried out by the Fund’s investment team. Results are reported to investors in the Fund’s annual periodic disclosure under Article 11 SFDR.
7Methodologies
The table sets out how each of the sustainability indicators set out in the Fund’s pre-contractual disclosure is measured.
The indicators are supported by the impact assessment rubric (section 10), under which each company is scored 0 to 3 on six criteria at investment and in each annual review. Ocean Impact Navigator KPIs are used wherever feasible, that is where they are compatible with the metrics used by the portfolio company and reflect the material ocean impacts of its business model. The KPIs are taken into use when company stage, operations and headcount make such KPIs meaningful to measure. The Ocean Impact Navigator was developed by 1000 Ocean Startups with the support of SYSTEMIQ as an impact framework specifically for ocean innovation.
8Data sources and processing
The main data sources are information provided by portfolio companies in due diligence and in their regular reporting, management meetings and board work, and, where relevant, public sources and scientific literature. Data is collected by the investment team together with the annual reporting of each portfolio company, checked for plausibility against previous periods and the company’s business development, and stored in the Fund Manager’s portfolio monitoring records. Given the early stage of the portfolio companies, a significant share of impact data may be based on estimates or modelled values; the share of estimated data is disclosed in the periodic report where it can be determined. Apart from due diligence, monitoring and regular dialogue with portfolio companies, the Fund Manager does not conduct further research unless the reported data gives rise to reasonable doubts.
9Limitations to methodologies and data
The Fund relies mainly on data reported by its portfolio companies. Because these are early-stage companies, some metrics will be based on estimates or assumptions, and reported data is not externally verified. Key performance indicators are closely linked to each company’s business model and may need to be redefined after a pivot, which limits comparability over time. The Ocean Impact Navigator is itself still developing, so aggregation across the portfolio is possible only within certain impact areas.
These limitations do not affect the attainment of the environmental characteristics promoted, because the binding elements of thematic alignment and ESG screening are assessed by the Fund Manager at the time of investment and do not depend on data reported later. The Fund Manager mitigates the remaining limitations by supporting portfolio companies in refining their KPIs and data collection, and by drawing on scientific expertise where needed.
10Due diligence
The assessment of how a potential investment relates to the environmental characteristics promoted is part of the due diligence before each investment. After pre-screening, the Fund scores the target on six criteria using a four-step rubric (0 red flag, 1 yellow flag, 2 moderate, 3 strong):
- Coupling of business and impact growth — whether the environmental benefit scales with each sale or unit deployed and is core to the business model.
- SDG alignment — fit with and contribution to SDGs 6, 8, 13 and 14, including concrete SDG targets and a strong causal link.
- Planetary boundaries alignment — whether the solution reduces pressure on one or more of the five selected planetary boundaries without rebound effects or burden shifting.
- Potential harm to the environmental characteristics — negative externalities, early awareness of risks and mitigation.
- Minimum safeguards — human rights, labour, anti-corruption and basic compliance, and the team’s governance maturity.
- Measurability — whether credible and simple KPIs, a baseline and data collection are feasible.
The results are summarised in a dedicated section of the investment memorandum and considered by the investment committee. Any red flag is addressed in the investment memorandum together with the proposed mitigation. Further reviews may be carried out where the Fund Manager considers this appropriate in a specific case.
11Engagement policies
The Fund Manager engages actively with its portfolio companies, typically through board seats or board observer roles, and supports founders in improving environmental performance and reporting. This includes help in refining KPIs and data collection, simple governance upgrades such as the adoption of basic policies, and access to relevant experts and partners, including the Fund’s scientific advisor and impact workshops within the blue economy ecosystem. Where a controversy or a deterioration in governance or environmental practices is identified, the Fund Manager first raises the matter with management and the board and agrees remedial steps, and may then use the shareholder rights available to it as a minority investor. The Fund Manager also works with portfolio companies to strengthen the link between revenue and impact and to build credible impact evidence over time.
12Designated reference benchmark
No index has been designated as a reference benchmark to determine whether the Fund is aligned with the environmental characteristics it promotes.
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