ESG Strategy & Responsible Investment Policy

Last updated Dec 22, 2022


In this context, “Icebreaker” means any of the following entities:  

  • Icebreaker Fund Management Oy (which acts as the Alternative Investment Fund Manager (AIFM))
  • Icebreaker Fund I GP (which acts as the general partner for Icebreaker Fund I Ky)
  • Icebreaker Fund II GP Oy (which acts as the general partner for Icebreaker Fund II Ky)
  • Icebreaker Opportunity Fund I GP Oy (which acts as the general partner for Icebreaker Opportunity Fund I Ky)
  • Icebreaker Fund I Ky (a fund managed by the AIFM)
  • Icebreaker Fund II Ky (a fund managed by the AIFM)
  • Icebreaker Opportunity Fund I Ky (a fund managed by the AIFM)

Icebreaker’s goal is to build long term value for its limited partners and make a positive impact on society. One part of the value creation is to act as a responsible investor and take environmental, social and governance (ESG) issues into account. Besides managing the risks related to ESG issues Icebreaker aims to benefit from the upside opportunities that well-managed ESG and corporate responsibility policies can generate.

Icebreaker acknowledges that some of the limited partners are committed to the Principles for Responsible Investment (PRI) instituted by the United Nations ( and their objective is to comply with and promote considerations related to ESG in investment analyses and decisions and in ownership policy.

This document describes Icebreaker’s ESG Strategy and Responsible Investment Policy which is created to be relevant to its funds’ investment strategy, characteristics of the investee companies and limited partners’ UNPRI commitments.

Investment analysis and decision-making processes

Analysis of the ESG issues are a standard part of Icebreaker’s investment process and due diligence. No investments are made if a potential investee company fails to meet the requirements of the Responsible Investment Policy and there is no credible plan on how to address the issues in a reasonable timeline. Icebreaker expects to find issues that are impossible to amend (e.g. company operating in an unacceptable industry) but also issues that can be corrected easier (e.g. improving the responsible employer policy).

When analyzing and considering potential investments, an ESG-related checklist on opportunities and risks is used (see Appendix 1). In the investment memorandum for an initial or follow-on investment, ESG considerations are covered as a part of the risk and development analysis. Because ESG related opportunities and risks vary in different industries, markets and countries Icebreaker analyses them on a case-by-case basis and focuses on the issues that are relevant to the potential investee company and its operating environment.

Icebreaker will not invest in companies operating in weapons, pornography, alcohol, tobacco or gambling industries, companies conducting illegal activities or companies which Icebreaker determines to operate unethically. In addition, Icebreaker does not invest in founders or co-invest with investors which Icebreaker determines to have serious reputational issues, such as a criminal record. However, most ESG considerations are more nuanced than the previously listed and therefore require careful evaluation.

Considering the nature of Icebreaker’s software-driven investee companies and their intangible products Icebreaker is not expecting to face many environmental risks that are usually more relevant to companies that produce and ship tangible products. Instead, Icebreaker expects to find opportunities with software based solutions reducing the load on the environment by making processes more efficient (e.g., digital payments reducing the number of receipts printed). 

Because of Icebreaker’s investment stages (i.e. angel, pre-seed and seed) Icebreaker expects that the potential investee companies usually have little or no historical burden regarding social or governance issues as the companies are founded recently and rarely employ any employees besides the founder team. However, Icebreaker acknowledges that the investee companies rarely have established governance processes either. This enables Icebreaker to support the investee companies by establishing good policies and processes from the beginning and ensure the sufficient level of social responsibility (e.g. compliance with labor legislation) and governance. Furthermore, innovation and agility are seen as the great benefits of diversity and talented personnel in addition to their health and wellbeing are one of the key assets of any early-stage software-driven company. Therefore, Icebreaker expects to find opportunities when encouraging the investee companies to diversity and becoming a responsible and good employer. Sound governance processes from the very beginning also help the investee companies to succeed in their follow-on investment rounds and exits.

Icebreaker expects that startups operating in regulated industries (e.g., in finance, healthcare or regulated profession such as the taxi market) are the ones that require significant attention during the analysis process. There is a fine balance between disrupting an industry with pushing the regulatory envelope and breaking the rules of regulation in a negative manner. The investee companies must always operate in compliance with the regulations and legislation, and also have the governance issues on an acceptable level before the investment decision.

Portfolio management processes


After an Investment, a discussion regarding the ESG related issues is a part of Icebreaker’s setup process with the investee company. Each investee company will work on its own corporate responsibility policy, which best fits the operations of the company, while Icebreaker provides support for that process.


ESG related issues are a standard part of the investee companies’ board work. ESG related issues are covered in the board meetings at least once a year. However, Icebreaker believes that the best impact is made through a consultative approach where the goal is to make the founders understand and believe in the positive effects of a well-managed company where ESG issues are a normal part of the processes and company culture. In addition, Icebreaker organizes ESG-focused coaching with the help of external advisors. Icebreaker also facilitates sharing of ESG related knowledge and best practices amongst the investee companies.

Icebreaker’s internal development

The ESG policies and processes are one part of Icebreaker’s internal development goals. ESG related issues are covered at the board meetings at least once a year. In addition, the ESG issues are also on the agenda of the funds’ Advisory Board meetings at least once a year.

Responsible Person

Icebreaker has a designated person in the AIFM for ESG considerations and responsible investing. The person’s role is to monitor the application of the processes, ensure they are kept up-to-date and drive awareness inside Icebreaker as well as in the investee companies.

No consideration of sustainability adverse impacts

Icebreaker is continuously developing its sustainability policies and considers ESG matters in investment strategy. However, Icebreaker does not consider the principal adverse impacts of investment decisions on sustainability factors under Article 4(1)(a) of Regulation (EU) 2019/2088. For the moment, considerable uncertainty remains regarding the new legislation. Icebreaker will follow the development of the legislation and re-evaluate its approach when the regulatory technical standards outlining the content and definition of such impacts have been finalised. 

Appendix 1 - ESG Checklist

This is an example checklist that Icebreaker uses as part of the investment process.


Does the company operate unethically or in weapons, pornography, alcohol, tobacco or gambling industries? Does the company conduct illegal activities?

Founders and other shareholders

Are there any reasons to suspect that the founders or other shareholders would have serious reputational risks, such as a criminal record?

Are there any reasons to suspect that the founders or other shareholders would use the company for questionable or illegal purposes, such as money laundering?


Does the company have any opportunities regarding environmental issues?
Environmental opportunity nro 1:
Environmental opportunity nro 2:
Environmental opportunity nro 3:

Does the company have any risks regarding environmental issues?
Environmental risk nro 1:
Environmental risk nro 2:
Environmental risk nro 3:


Does the company have any opportunities regarding social issues?
Social opportunity nro 1:
Social opportunity nro 2:
Social opportunity nro 3:

Does the company have any risks regarding social issues?
Social risk nro 1: 
Social risk nro 2: 
Social risk nro 3:


Does the company have any opportunities or strengths regarding governance issues?Governance opportunity or strength nro 1: 
Governance opportunity or strength nro 2: 
Governance opportunity or strength nro 3:

Does the company have any risks or weaknesses regarding governance issues?
Governance risk or weakness nro 1: 
Governance risk or weakness nro 2: 
Governance risk or weakness nro 3: