1. Purpose.
This Responsible Investment Policy (the “Policy”), dated March 2025, reflects our current approach to considering and addressing Responsible Investment (“RI”) factors, which has been further developed and refined since we became a PRI signatory in 2019 and adopted our initial responsible investment policy in 2017. This Policy reflects the same fundamental principles and commitment to integrate RI considerations into our investment management business and portfolio company ownership practices as we have always integrated. In developing this Policy, we have considered a range of guidance, including the Principles for Responsible Investment and the American Investment Counsel Guidelines for Responsible Investment.
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 RI 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 also implemented and continue to update, as necessary, a robust cyber-security framework in order to protect our systems, networks, programs, devices and Firm and investor data from cyber-attacks.
3. Scope.
This Policy is intended to provide a broad framework for EagleTree’s overall approach to RI. EagleTree recognizes that its approach to different RI 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 our investment management process, including during pre-acquisition, throughout ownership, and when positioning a portfolio company for an exit.
4. Roles and Responsibilities.
EagleTree’s RI initiatives are overseen by its RI Committee, which includes EagleTree’s two Co-Managing Partners and other members of senior management. The RI Committee meets at least quarterly. An RI Sub-Committee has also been formed to function as a working group that carries out the day-to-day aspects of EagleTree’s responsible investment efforts and initiatives and is available as a resource for investment team members. The RI Sub-Committee generally meets on a weekly basis and its responsibilities include: (i) engaging with EagleTree’s deal teams on preacquisition RI due diligence matters; (ii) engaging with EagleTree’s third-party RI specialists to conduct annual portfolio company-level RI reviews; (iii) responding to investor and other stakeholder RI requests; (iv) conducting annual employee training; and (v) reviewing and updating this Policy and EagleTree’s overall approach to responsible investment, as necessary, from time to time. The RI Committee also aims to ensure that all EagleTree employees are aware of EagleTree’s culture and any amendments to this Policy.
As applicable, EagleTree’s Investment Committees in partnership with the RI Sub-Committee oversees and considers RI issues, if any, that are material to a potential portfolio company investment. With assistance from the RI Sub-Committee and outside RI specialists, as appropriate, EagleTree’s deal teams manage and monitor material RI issues that have been identified during portfolio company ownership.
5. RI Process Integration
- Pre-Acquisition Process: During pre-acquisition, EagleTree aims to:
- Incorporate detailed RI considerations into our pre-investment decision-making process in order to better assess RI risks and opportunities and to provide us with an initial overview of a potential portfolio company’s profile.
- Tailor specific RI 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 RI 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. This list is not exhaustive and is qualified by our legal documentation and any applicable side letters governing our investments.
- Ownership Process: During ownership, EagleTree aims to:
- Work with portfolio companies to advance EagleTree’s RI principles with the goal of improving long-term performance and minimizing adverse impacts in these areas.
- Track RI-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 aims to do the following, as applicable:
- Summarize the portfolio company’s standing on RI matters, as necessary.
- Highlight in-process RI initiatives as necessary.
6. Firm Culture
EagleTree continues to promote an inclusive and cohesive working and investing environment. The Firm focuses on recruiting talented and skilled candidates and promoting and retaining them through professional development, training and networking opportunities. EagleTree has formalized its commitment to a strong Firm culture in its Firm Culture statement and, in 2021, became a signatory to ILPA’s DIA Initiative.
7. Community 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 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.
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 RI initiative. EagleTree intends to engage with clients and stakeholders, from time to time, in dialogue regarding how we can manage RI issues in a way that is consistent with their initiatives.
