LLR Partners’ Environmental, Social, and Governance Policy (“ESG Policy”) as of November 2017

OVERVIEW

Since our founding in 1999, LLR Management, L.P. (“LLR”) has been committed to conducting business in a manner that is 1) compliant with applicable laws, regulations, and best practices, 2) honest, fair, and respectful to our stakeholders, including our investors, portfolio companies, employees, communities, and environment, and 3) considerate of the environmental, social, and governance (“ESG”) impact of our investment decisions. As active investors, we take seriously our commitment to corporate responsibility and transparency and strive to account for these considerations wherever consistent with the fiduciary duty that we owe to our limited partners.

LLR’s ESG Policy is an integral part of our business model and its guiding principles are to consider factors such as the environment, labor and human rights and ethics when evaluating, managing and monitoring investments. This ESG Policy formalizes LLR’s longstanding commitment to adhering to the highest standards of conduct and business practices while complying with all regulations and laws governing the protection of human rights, occupational health and safety, the environment, and labor and business practices within the jurisdictions in which we conduct business.

This ESG Policy will apply to all private equity investments considered or made by LLR following the date hereof and will be interpreted in accordance with local laws and regulations. In cases where LLR determines it has limited ability to conduct diligence on or to influence and control the integration of ESG considerations in the investment (for example, in cases where LLR is a minority shareholder, or where other circumstances affect LLR’s ability to assess, set or monitor ESG-related performance goals), it will not necessarily be feasible to implement ESG-related principles. LLR also recognizes that industry guidelines and best practices in managing ESG issues will continue to evolve over time and will review this ESG Policy from time to time to incorporate changes it believes are necessary.

LLR’s ESG Policy will be implemented in the spirit of the six principles outlined by the Principles for Responsible Investing (“PRI”) (source: https://www.unpri.org/about/the-six-principles as of November 2017):

1) To incorporate ESG issues into investment analysis and decision-making processes;
2) To be an active owner and to incorporate ESG issues into our ownership policies and practices;
3) To seek appropriate disclosure on ESG issues by the entities in which we invest;
4) To promote acceptance and implementation of the Principles within the investment industry;
5) To work with other PRI signatories to enhance effectiveness in implementing the Principles;
6) To report on our activities and progress towards implementing the Principles.

LLR’S ESG POLICY

LLR will, to the best of our ability, and wherever consistent with the fiduciary duty we owe to our limited partners:

  • Conduct our business dealings to the highest standards of honesty, integrity, fairness and respect;
  • Comply with all relevant regulations and laws governing the protection of human rights, occupational health and safety, the environment, and labor and business practices within the jurisdictions in which we conduct business;
  • Integrate the identification and management of these ESG issues into our due diligence, decision-making and investment management and monitoring processes; and
  • Provide our stakeholders with accessibility and transparency into our decision-making processes.

LLR ESG POLICY MANAGEMENT

To support the implementation of the principles set forth in this ESG Policy, LLR will:

  • Allocate the resources necessary for the implementation of this ESG Policy;
  • Distribute and discuss the importance of this ESG Policy with our employees, instructing them in the identification and management of ESG risks, opportunities and appropriate mitigating measures, including the use of external subject matter experts and resources when needed;
  • Identify ESG risks and opportunities as part of the due diligence process through inclusion of ESG-related issues in investment committee materials and discussions;
  • Discuss the importance of this ESG Policy with our portfolio companies and prospective portfolio companies and encourage our portfolio companies to operate in a manner that is consistent with this ESG Policy and the PRI;
  • Work with our portfolio companies to assist in the development of action plans to mitigate material ESG- related issues where it is commercially practical to do so, with appropriate targets and a recommended timetable for improvements;
  • Subject to any confidentiality obligations, provide timely information to limited partners on material ESG matters.

CONTACT US

If there are any questions regarding this ESG policy, contact Jason Jerista, Director of Investor Relations, at jjerista@llrpartners.com or 215.717.2900.


LLR Partners’ Environmental, Social, and Governance Policy