1. Purpose.
This ESG Policy (the “Policy”) amends, restates and supersedes EagleTree’s ESG Policy that was first formally adopted in 2017. This Policy reflects our current approach to considering and addressing Environmental, Social and Governance (“ESG”) factors and which has been further developed and refined since we became a PRI signatory in 2019. This Policy does, however, retain 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 believes that it is better positioned to address many of the issues facing our portfolio companies in a rapidly changing world when we proactively incorporate ESG considerations into our investment approach.
2. Commitment.
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 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, and in an effort to protect our systems, networks, programs, devices and data from cyber-attacks, has implemented a robust cyber-security framework.
3. Scope.
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.
4. Roles and Responsibilities.
EagleTree’s ESG initiatives will be overseen by its ESG Committee, which includes EagleTree’s two Co-Managing Partners and other members of senior management. The ESG Committee will meet at least quarterly. An ESG Sub-Committee has also been formed to function as an ESG working group that will carry out the day-to-day aspects of EagleTree’s ESG efforts and initiatives and be available as a resource for investment team members. The ESG Sub-Committee generally will meet on at least a weekly basis and its responsibilities will 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 will oversee and consider ESG issues, if any, that are material to a potential company investment. With assistance from the ESG Sub-Committee and outside ESG specialists, as appropriate, EagleTree’s deal teams will manage and monitor material ESG issues that have been identified during portfolio company ownership.
5. ESG Investment Process Integration
- Pre-Acquisition Process: During pre-acquisition, EagleTree will aim to:
- Incorporate detailed ESG considerations into our pre-investment decision-making process in order to better assess ESG risks and opportunities and to provide us with an initial overview of a potential portfolio company’s ESG profile.
- Tailor specific ESG inquiries and approaches based on various investment factors including the core industry sector of a particular investment.
- Engage with outside advisors, as necessary, to analyze and address ESG issues, risks and opportunities that arise.
- Consider whether a potential portfolio company’s business aligns with EagleTree’s core values.
- Identify any business line that would cause us to refuse to invest, including: (i) the manufacture or sale of handguns, assault weapons and/or ammunition; (ii) the distribution or sale of pornography; (iii) the direct and primary production or packaging of tobacco or alcoholic beverages; (iii) the production, sale, trade or distribution of illegal drugs; or (iv) a business that would pose a high reputational risk to EagleTree, its clients and/or other stakeholders.
- Ownership Process: During ownership, EagleTree will aim to:
- Work with portfolio companies to advance EagleTree’s ESG principles with the goal of improving long-term performance and minimizing adverse impacts in these areas.
- Track ESG-related metrics across our portfolio companies and engage and collaborate with portfolio companies to consider recommendations from these findings.
- Work with portfolio companies to integrate sustainability considerations into their business plans, as applicable.
- Work with portfolio companies to address ever-changing cyber-security considerations.
- Respect the human rights of those affected by our investment activities and seek to confirm that our portfolio company investments do not support companies that utilize child or forced labor or maintain discriminatory policies.
- Exit Process: In positioning a portfolio company for an exit, EagleTree will aim to do the following, as applicable:
- Highlight the portfolio company’s progress on ESG matters.
- Summarize the positive impact that our integration of ESG initiatives had on the portfolio company’s business and/or culture.
6. Diversity and Inclusion.
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.
7. Social Impact
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. EagleTree continues to encourage all of its employees to actively engage in nonprofit volunteer activities and giving in our communities. Our initiatives in this regard are carried out by our Philanthropic Committee, which identifies several nonprofit charities each year with whom employees volunteer and EagleTree supports.
8. Transparency.
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.
