This Environmental, Social and Corporate Governance Policy (this “ESG Policy”) reflects CCMP Growth’s commitment that, where consistent with its fiduciary and other duties and otherwise commercially practicable, the Firm will endeavor to consider environmental, social and governance factors in its activities, in particular the ESG Principles set forth below, and incorporate ESG monitoring into our portfolio management process. In developing and enhancing our ESG policy, we have considered a range of industry standards, including the United Nations-supported Principles of Responsible Investment to which we are a provisional signatory, the UN Global Compact, and the American Investment Council’s Guidelines for Responsible Investment.
CCMP Growth recognizes that environmental, social and governance matters will continue to evolve over time and intends to review its practices from time to time to assess appropriate changes.
In executing the above ESG Principles, CCMP Growth’s Senior Leadership team shall:
CCMP Growth strives to use its influence with its portfolio companies to maximize overall long-term value to its clients and investors, taking into consideration economic, social, and environmental matters.
To ensure that adequate ESG-related competence exists at the portfolio company level, CCMP Growth may:
If applicable, CCMP Growth may aim to collaborate with peers in engaging with investee companies to address matters of collective interest.
CCMP Growth’s Investment Committee 1 (“IC”) and investment professionals are responsible for identifying and understanding ESG risks during the due diligence process and investment decision-making.
As part of CCMP Growth’s risk assessment, due diligence protocols, and Portfolio Management Policy, CCMP Growth will also consider climate-related risks, opportunities, and financial impact in its investment activities, encompassing pre- and post-investment phases. This is in addition to financial, commercial, legal, industry due diligence protocols typically conducted for transactions.
Climate-related Risks 2 include, but are not limited to:
These assessments are meant to assist CCMP Growth’s deal team and IC in identifying climate-related opportunities and risks and inform investment decisions.3 According to the Task force on Climate-related Financial Disclosures (“TCFD”), climate-related opportunities may include activities, investments, products, or services aligned with efforts to mitigate and adapt to climate change that may improve a portfolio company’s competitive position, yield positive financial outcome, or be considered accretive to overall asset value.
Employees of the Firm are responsible for knowing and complying with CCMP Growth’s policies and procedures, including those set forth in the RI Framework and its Portfolio Management Policy. CCMP Growth’s ESG Committee will ensure that appropriate responsible investment trainings are provided to its management and employees on at least an annual basis.
Oversight for implementing the RI Framework is the responsibility of the IC and ESG Committee. These parties are responsible for ensuring the adoption of the RI Framework throughout the organization and the periodic review of policies and procedures contained within the framework. CCMP Growth may engage external legal counsel and other third-party consultants in conducting these reviews and due diligence procedures as needed.
At the request of the CCMP Growth’s limited partners, the Firm will endeavor to periodically report material ESG highlights and developments, publicly available Transparency and Assessment Reports generated through the PRI annual reporting process and provide responses to diligence questionnaires received that address ESG related matters.