ESG & IMPACT

Environmental, Social and Governance (“ESG”) Policy

Environmental and Social

Sustainable development is core to delivering on our growth objectives. Underpinning our corporate philosophy and growth path is an appreciation that our growth drivers cannot be achieved effectively without a committed focus to sustainable development.

Governance

Good governance is essentially about leadership that must rise to the challenges of modern governance. Such leadership is characterised by the ethical values of responsibility, accountability, fairness and transparency and is based on moral duties. Responsible leaders direct company strategies and operations with a view to achieving sustainable economic, social and environmental performance. Starting at the initial stages of the investment process, Kleoss will look to apply the below mentioned principles to its portfolio companies and their operational activities. Post investment, Kleoss will continue to monitor progress on ESG matters and compliance by portfolio companies to this framework and policy guidelines. In line with this commitment Kleoss will endeavour to:

• Undertake its activities in line with applicable international standards and industry good practice
• Meet the requirements of national legislation in all the countries in which the Fund will be invested and/or its portfolio companies operate
• Foster value-driven ethical behaviour and good governance practices, informed by respect for human rights
• Ensure social and environmental impacts are avoided or reduced as far as practicable
• Communicate and work closely with portfolio companies to ensure their understanding and shared commitment to conformance with this policy
• Implement all reasonable precautions to protect the health and safety of portfolio company employees and promote the health and safety of contracted workers
• Implement responsible practices to ensure that good governance will always enhance and maintain the reputation of the Fund.

In terms of the ESG requirements of the IFC, Kleoss undertakes to:

• Identify and assess ESG impacts, both adverse and beneficial, in Kleoss’ area of influence
• To avoid, or where avoidance is not possible, minimize, mitigate, or compensate for adverse impacts on workers, stakeholders and the environment
• To ensure that stakeholders are appropriately engaged on issues that could potentially affect them
• To promote improved ESG performance of portfolio companies through the effective use of management systems and legally binding action plans.

This policy and other elements of the manual shall be regularly reviewed and updated in order to ensure its continued applicability to the activities of the Fund and its portfolio companies.