This ESG Policy (the “Policy”), dated December 2023, reflects our current approach to considering and addressing Environmental, Social and Governance (“ESG”) factors, which has been further developed and refined since we became a PRI signatory in 2019 and adopted our initial ESG Policy in 2017. This Policy retains the same fundamental principles and our commitment to integrate ESG considerations into our investment management business and portfolio company ownership practices. In developing this Policy, we have considered a range of guidance, including the Principles for Responsible Investment, the American Investment Counsel Guidelines for Responsible Investment and the Sustainable Development Goals.
EagleTree has always strived to maintain a strong culture of good governance to ensure that it operates in a socially responsible manner. In furtherance of this ethos and in accordance with our responsibilities to our clients and other stakeholders, EagleTree is committed to identifying and considering ESG issues, risks and opportunities associated with potential portfolio company investments and engaging with portfolio companies on these matters as necessary during our ownership.
In addition, we remain committed to compliance with national, state and local labor laws in jurisdictions in which we invest and to provide a safe and healthy workplace consistent with national and local laws. EagleTree continues to maintain policies and procedures that prohibit bribery and other illegal payments to public officials consistent with U.S. federal and state laws. We have implemented a robust cyber-security framework in order to protect our systems, networks, programs, devices and Firm and investor data from cyber-attacks.
This Policy is intended to provide a broad framework for EagleTree’s overall approach to ESG. EagleTree recognizes that its approach to different ESG factors may vary among portfolio companies of different sizes, that fall within different industry sectors and that operate in different geographies. Therefore, EagleTree may incorporate and alter different elements of this Policy for different portfolio companies across the stages of the investment management process, including during pre-acquisition, throughout ownership, and when positioning a portfolio company for an exit.
EagleTree’s ESG initiatives are overseen by its ESG Committee, which includes EagleTree’s two Co-Managing Partners and other members of senior management. The ESG Committee meets at least quarterly. An ESG Sub-Committee has also been formed to function as an ESG working group that carries out the day-to-day aspects of EagleTree’s ESG efforts and initiatives and is available as a resource for investment team members. The ESG Sub-Committee generally meets on a weekly basis and its responsibilities include: (i) engaging with EagleTree’s deal teams on pre-acquisition ESG due diligence matters; (ii) engaging with EagleTree’s third-party ESG specialists to conduct annual portfolio company-level ESG reviews; (iii) responding to investor and other stakeholder ESG requests; (iv) conducting annual employee training; and (v) reviewing and updating this Policy and EagleTree’s ESG program, as necessary, from time to time. The ESG Committee also aims to ensure that all EagleTree employees are aware of EagleTree’s culture of social responsibility and any amendments to this Policy.
As applicable, EagleTree’s Investment Committees in partnership with the ESG Sub-Committee oversees and considers ESG issues, if any, that are material to a potential portfolio company investment. With assistance from the ESG Sub-Committee and outside ESG specialists, as appropriate, EagleTree’s deal teams manage and monitor material ESG issues that have been identified during portfolio company ownership.
EagleTree continues to promote diverse perspectives. In this regard, EagleTree has adopted a Diversity & Inclusion Statement and, in 2021, became a signatory to ILPA’s Diversity in Action Initiative.
EagleTree seeks to improve diversity and inclusion within the Firm, across its portfolio company investments and in the private equity industry, where possible.
EagleTree has a history of charitable giving and an active Philanthropic Committee that strives to support a number of charities from both a financial and volunteer perspective and carries out the Firm’s initiatives in this regard. Our Philanthropic Committee, identifies several nonprofit charities each year with whom employees volunteer and EagleTree supports. EagleTree continues to encourage all of its employees to actively engage in nonprofit volunteer activities and giving in our communities.
EagleTree aims to provide timely information to its clients and other stakeholders on the matters addressed herein and to work with them to foster transparency with regard to its ESG initiative. EagleTree intends to engage with clients and stakeholders, from time to time, in dialogue regarding how we can manage ESG issues in a way that is consistent with their initiatives.
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