ESG policy

We believe that environmental, social and governance (ESG) issues can have a significant impact on private equity investments, in terms of making investments, creating value in each portfolio company and finally in raising funds.
These issues are integral to our business, both our own operations and those of our portfolio companies. We think that firms with an environmentally sustainable and socially responsible way of operating significantly de-risk their business model and, therefore, achieve greater cost efficiencies and profitability, leading to higher valuations.
Our ESG policy reflects all those laws, codes and regulations to which we are bound by law, including all anti-bribery and corruption policy requirements in the countries where we or any of our portfolio companies operate.

Our ESG policy statement

SEAFORT ADVISORS will, to the best of our ability:

• Comply with relevant regulations and appropriate best practices governing the protection of human rights, occupational and public health and safety, the environment, and the labor and business practices of the jurisdictions in which we conduct business.
• Adhere to the highest standards of conduct intended to avoid even the appearance of negligent, unfair or corrupt business practices or practices involving conflicts of interest.
• Regard implementation of our ESG statement as an integral part of how we do business.
• Provide for the assignment of and accountability for ESG responsibilities to senior managers at companies we control.
• Instruct all SEAFORT ADVISORS partners and employees in the identification and management of ESG risks and opportunities and provide them with appropriate support (including external resources when needed).
• Identify ESG risks and opportunities as part of the evaluation of whether to invest in companies, seeking both to respect human rights (including by avoiding investment where there is the use of child or forced labor or discriminatory policies) and manage ESG risks and opportunities following acquisition, including those arising through supply chains.
• Establish appropriate ESG policies and practices for portfolio companies we own comparable to the standards adopted by us, including in relation to human rights, sanctions, anti-corruption, health and safety, the environment and climate change, labor practices and, where appropriate, consider similar issues in relation to the portfolio company’s supply chain.
• Monitor and oversee the implementation and operation of such policies and practices in portfolio companies, recognizing that establishing an appropriate compliance culture is an essential part of effective implementation, require the establishment of systems to measure ESG performance and encourage the disclosure of ESG matters for public review and engagement with relevant stakeholders.
• Initiate reporting and corporate governance best practices in our portfolio companies to ensure that we are able to assess and to ensure compliance with the policies and procedures referred to above.
• Recognize that our ESG activities are of an ongoing nature and encourage continual improvement in ESG performance both in our operations and at our portfolio companies.
• Distribute this policy to all our employees and appropriate employees of portfolio companies we own.
• We will review the policy’s effectiveness and implementation on a regular basis, and report relevant findings, progress and recommendations to our team members.

Hamburg April 2018