We are committed to proactively fostering an ESG-forward culture, and stimulating positive, sustainable impact alongside delivering attractive risk-adjusted returns to our investors.

• Environmental Focus Area—Carbon & Climate
• Social Focus Area—People & Community
• Governance Focus Area—Accountability & Transparency

Fostering Entrepreneurship and Female Leadership

Diversity of background and experience is a critical component of business performance. These characteristics are an ever-present component of founder- and family-owned and operated businesses and are why our Firm values these business relationships. We are also passionate about empowering the next generation of female leaders, and strive to promote female entrepreneurship.

In support of these themes, we have launched various initiatives aimed at advancing equity and inclusion efforts across the private equity and entrepreneurial communities.

• Fostering an inclusion-based culture founded in the Firm’s commitment to embracing diversity
• 64 promotions since inception
• 50% diverse leadership
• 66% diverse employees

Our ESG Committee leads our Firm through our sustainability journey. Comprised of leaders from different departments across the organization, the Committee reports to the broader Principal and Partner group, driving the development and implementation of key firmwide ESG initiatives.

Trilantic Capital Management L.P. (“Trilantic North America” or the “Firm”) is committed to the evaluation of Environmental, Social and Governance (“ESG”) risks and considerations within our own business, and as an essential component of creating and maintaining value for our investors, portfolio companies and community.

Guidelines

In an effort to promote and support ESG best practices, Trilantic North America has developed the following ESG guidelines within our investment process:

• During pre-acquisition diligence, specific environmental topics, selected from a more comprehensive set of potential environmental topics developed from SASB standards (such as energy management & resource efficiency, waste management, compliance with environmental regulations and environmental impact), are identified for diligence based on the potential portfolio company’s industry sector and operating locations.
• Risks identified in pre-acquisition diligence will inform the deal team’s ongoing monitoring priorities.
• Generally, within the first year of Trilantic North America’s investment in a portfolio, and thereafter on an annual basis, the Firm collects Scope 1, Scope 2 and certain Scope 3 emissions data from companies, where available, and seeks to encourage portfolio companies to progressively obtain higher quality data for carbon footprint measurements.
• Trilantic North America also considers the climate-related risks to which its companies are exposed, aiming to conduct a physical climate risk assessment on portfolio companies every three to five years.

Social Guidelines

Sector-specific and region-specific operating considerations of a portfolio company related to human rights and labor practices are generally assessed during pre-acquisition diligence processes, as well as such portfolio company’s impact on communities, and such considerations will inform ongoing diligence considerations. However, there are certain standards that we aim to uphold in all portfolio company investments; for example, we aim to screen out investments known to be associated with child or forced labor or other exploitative or discriminatory practices.

• Consistent with Trilantic North America’s investment style, which is predicated on identifying companies and trends poised for growth and helping to fund that growth, we expect our portfolio companies to be significant employers and job creators, and for such portfolio companies to be equal opportunity employers, prioritize employee health and safety, and promote diversity in their boards of directors, senior management and overall workforce.
• In pre-acquisition diligence and ongoing diligence, we seek to review a portfolio company’s policies on employee recruitment, development and retention and employee diversity, equity and inclusion. During our monitoring period, we track diversity data annually and seek to provide our portfolio companies with resources to encourage board diversification upon a board vacancy.
• We are also committed to data security and data privacy, assessing a portfolio company’s risks and opportunities based on its industry sector, the type of data such portfolio company handles and overall cyber risk to such company’s operations, and provide opportunities for portfolio company management cybersecurity training.

Governance Guidelines

• We are committed to establishing or maintaining proper governance structures within our portfolio companies and seek to use our voice as board members to promote ESG initiatives and create, enhance or support strategic solutions that we believe will maximize our long‐term investment returns.
• In pre-acquisition diligence, we review a potential portfolio company’s business ethics and professional integrity through a review of company policies and procedures and discussions with management, as needed, and such pre-acquisition diligence will inform topics for continued monitoring. Informed by SASB standards of materiality applicable to a potential portfolio company’s specific sector and geography, we will also review other specific and/or systemic risks to a company, such as supply-chain considerations, including management and sourcing, competitive behavior and intellectual property management, among other topics.
• We also seek to identify and mitigate potential conflicts of interest that may arise from time to time related to Fund investments and/or our business activities (e.g., portfolio company business interactions).
• As part of the board of directors of our private companies, Trilantic North America also aims to monitor any applicable regulations, including regulatory changes, that could affect a portfolio company’s operations.

Investment Exclusions

In light of the forgoing guidelines, Trilantic North America will not make investments in portfolio companies that are:

(i) directly and primarily involved in the manufacture of certain controversial weapons (such as cluster munitions and anti-personnel mines, or chemical, biological or toxic weapons),
(ii) directly and primarily involved in the production or distribution pornography or involved in the sex or pornography industry,
(iii) suspected to be involved in criminal or terrorist activities,
(iv) beginning with its Fund VII North America, directly and primarily involved in the exploration, development or production of oil, gas, coal or other hydrocarbon-based or fossil fuels (“Upstream Energy Investment”), or
(v) associated with child or forced labor or other exploitative or discriminatory practices.

Any fund-level investment limitations or prohibitions noted above are not intended to be comprehensive; additional prohibitions or specific exclusions from the above could and have been specifically negotiated in the operative documents of a specific Fund. In addition, additional exclusions are included from time to time in side letter agreements with specific investors within any Fund.

Sustainable Development Goals

Trilantic North America recognizes the importance of understanding how the Firm’s investment activities intersect with topics that are relevant on a global context. As such, the Firm has elected to consider the United Nation’s Sustainable Development Goals (UN SDGs) while developing and implementing our ESG-related practices to support a clearer understanding of how our business practices both within our operations and within our investment strategies connect on a global stage.

Specifically, the Firm’s ESG Policy aims to consider:

• UN SDG 5: Gender Equality
  Achieve gender equality and empower all women and girls.
• UN SDG 8: Decent Work and Economic Growth
  Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.
• UN SDG 12: Responsible Consumption and Production
  Ensure sustainable consumption and production patterns.

Oversight

To oversee the execution of ESG initiatives within the Firm and its portfolio companies, Trilantic North America has established an ESG committee that identifies and communicates key ESG issues Firm‐wide, provides resources and training, including access to vetted outside consultants where appropriate, and periodically updates this ESG policy to reflect changes in industry best practices or changes in laws or regulations. Giulianna Ruiz, Partner and General Counsel, serves as Chair of the ESG committee and oversees Firm- and investment-level ESG initiatives. Additionally, material ESG considerations will be raised to the Executive Committee and/or Principals of the Firm once identified. The Firm recognizes that any or all identified ESG risks cannot be eliminated but will endeavor to mitigate such risks to the extent reasonably practical. While there can be no guarantee that the criteria or process used by the Firm or any judgment exercised by the Firm will reflect the beliefs or values of any particular investor, sector or community, the ESG committee will periodically review and monitor relevant industry standards to inform the Firm’s ESG approach and update this ESG policy as needed. In addition, this ESG policy will be reviewed annually as part of the Firm’s overall policy review process and the ESG committee strives to conduct periodic ESG educational sessions for relevant team members to ensure the efficacy of the Firm’s ESG program.

*These ESG Guidelines are intended to reflect the Firm’s general framework for managing ESG issues through the lifecycle of an investment. The Firm’s ability to influence and exercise control over the companies in which the funds invest will vary depending on the investment structure and terms. In cases where the Firm determines it has limited ability to conduct diligence or to influence and control the consideration of ESG issues in connection with an investment, whether at the investment or at the fund-level, the Firm will only apply those elements of the ESG Guidelines that it determines to be practicable. Examples of such cases at the investment-level include where a fund is a minority shareholder, has limited governance rights or where other circumstances affect the fund’s ability to assess, set or monitor ESG-related performance goals. In addition, the Firm will only integrate ESG guidelines in accordance with its fiduciary duties to maximize investment value and any applicable legal, regulatory or contractual requirements. The Firm acknowledges that applying ESG factors to investment decisions is qualititative and subjective by nature and therea are significant differences in interpretations of what positive or material ESG characteristics mean by region, industry and issue, and these interpretations are rapidly evolving.