Our Approach

BelHealth Investment Partners, LLC (“BelHealth” or the “Manager”) is committed to the highest standards of business practices and ethics. BelHealth recognizes that environmental, social, and governance (“ESG”) issues can affect investment performance and believes managing these ESG risks and opportunities can protect against and mitigate undue risk and foster an environment for long-term value creation. Further, the consideration of ESG issues in the investment process enables BelHealth to be good stewards of the capital committed to us and good corporate citizens.

This ESG Policy strives to align and incorporate general industry guidelines consistent with our size and available resources. BelHealth recognizes that these general industry ESG guidelines and the approach to managing ESG issues will evolve over time. As a result, we will periodically review this ESG Policy to make appropriate changes and updates.

The purpose of this Policy is to provide guidance regarding the integration of ESG considerations into the investment processes related to potential portfolio companies as part of our Responsible Investment Guidelines.

Roles & Responsibilities

BelHealth’s Investment Professionals that review and evaluate investments for the Funds and their portfolio companies shall incorporate consideration of ESG risks and opportunities in their investment analysis and due diligence. Post-close, where significant material issues are identified for corrective action, investment professionals will continue to consider and/or monitor ESG issues, and will include discussion of progress on such issues during monthly meetings with portfolio company management as appropriate.

If deemed necessary, Third-Party Experts may be engaged to support investment professionals in conducting due diligence and/or ongoing ESG monitoring activities.

BelHealth’s Investment Committee (IC) will consider the findings of ESG reviews in final decision-making. The IC will provide input in the periodic review of this ESG Policy and make recommendations and amendments, as it may determine in its discretion, to promote its effective implementation.

BelHealth’s Chief Compliance Officer (CCO) is responsible for maintaining and overseeing implementation of this Policy. During the periodic review of the Firm’s ESG Policy implementation, the CCO will maintain minutes of these reviews and copies of any materials that were provided at such meetings. Based on results of such reviews, the CCO will periodically update the ESG Policy and hold employee training sessions as required to ensure adequate capacity for effective implementation.

Investment Analysis and Due Diligence

As part of their pre-investment diligence review, investment professionals will identify ESG factors with the potential to have a material impact on the investment, drawing upon guidance from the Sustainability Accounting Standards Board’s (SASB) materiality framework, and accounting for target company characteristics such as sector, business model and geography.

ESG factors could include, but are not limited to, the following:

• Environmental factors: Environmental liabilities and associated costs, use of natural resources, waste management, water or air pollution, climate change, protected habitats and ecosystems, greenhouse gas emissions.
• Social factors: Child or forced labor, working conditions, human rights and community relations, worker health and safety, public health, relations with unions and employees, product safety, protection of consumer rights, and competitive wages and benefits.
• Corporate governance factors: Board composition and independence, executive compensation, shareholder rights, audit and accounting quality and controls, conflicts of interest, and bribery and corruption.

In prioritizing material ESG risks and opportunities with respect to a particular investment of the Funds, investment professionals will consider timing, size, and expected holding period of the investment, prior experience with the target company or its management, the legal regime to which it is subject, and any known or readily available information about ESG policies of the applicable target company. Prioritization of material ESG factors for further diligence and/or for corrective action shall be at the discretion of the investment professionals based on the aforementioned factors.

Investment professionals will summarize findings of the ESG diligence review in the Investment Committee memo. Upon presentation to the Investment Committee, the IC will incorporate findings into investment decision-making, establishing ESG-related corrective actions and goals as appropriate.

Responsible Ownership

Where material ESG factors have been identified and prioritized for corrective action, BelHealth’s investment professionals will work with portfolio companies to incorporate associated goals and metrics. Progress on achievement of goals will be discussed at monthly meetings with portfolio companies, as appropriate, with portfolio companies accountable for collecting metrics data and providing data to BelHealth upon request.

Accountability and Transparency

To promote its dedication to transparency, BelHealth will provide ESG information to its investors upon request.

Conclusion

We believe that effectively managing ESG can protect and/or create long-term value in our investments and the consideration of these ESG issues in our investment processes enables us to be good stewards of the capital committed to us and good corporate citizens. This Policy is considered an evolving document that will be updated periodically. If you have any questions about this Policy, please contact BelHealth’s Chief Compliance Officer.

Important Disclosures

BelHealth does not invest solely on the basis of ESG criteria, but rather it is one of many factors considered by the Frim. This Policy establishes guidelines the relevance of which will depend on the facts and circumstances around each investment. There is no guarantee that BelHealth’s ESG Policy will have a material impact on ESG matters for portfolio companies.

Considering the environmental, social and governance (ESG) implications of our investments enables us to be good stewards of the capital committed to us by our investors as well as being good corporate citizens.

Guidelines for Responsible Investment

• Consider environmental, public health, safety, and social issues associated with target companies when evaluating whether to invest in a particular company or entity, as well as during the period of ownership.
• Seek to be accessible to, and engage with, relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.
• Seek to grow and improve the companies in which we invest for long-term sustainability and to benefit multiple stakeholders, including on environmental, social and governance issues. To that end, we will work through appropriate governance structures (e.g. board of directors) with portfolio companies with respect to environmental, public health, safety, and social issues, with the goal of improving performance and minimizing adverse impacts in these areas.
• Seek to use governance structures that provide appropriate levels of oversight in the areas of audit, risk management and potential conflicts of interest and to implement compensation and other policies that align the interest of owners and management.
• Remain committed to compliance with applicable national, state, and local labor laws in the countries in which they invest; support the payment of competitive wages and benefits to employees; provide a safe and healthy workplace in conformance with national and local law.
• Maintain strict policies that prohibit bribery and other improper payments to public officials consistent with the U.S. Foreign Corrupt Practices Act, similar laws in other countries, and the OECD Anti-Bribery Convention.
• Respect the human rights and seek to prevent investments that utilize child or forced labor or maintain discriminatory policies.
• Seek to provide timely information to limited partners and work to foster transparency in our activities.
• Encourage portfolio companies to advance these same principles in a way which is consistent with our fiduciary duties.

BelHealth Investment Partners, LLC (“BelHealth”) is committed to fostering, cultivating and preserving a culture of diversity, equity, and inclusion. We appreciate a culture that embraces employee differences in age, color, disability, ethnicity, family or marital status, language, national origin, physical and mental ability, race, religion, and other characteristics that make our employees unique.

Our commitment to diversity, equity, and inclusion is reflected in our policies on Equal Employment Opportunity, Non-Harassment, Sexual Harassment, Workplace Violence, Workplace Conduct, Health And Safety, and our practices in recruitment, compensation and benefits, professional development and training, and the ongoing development of a work environment built on the premise of equality that encourages:

Guidelines for Responsible Investment

• Respectful communication and cooperation among all employees;
• Teamwork and employee participation, encouraging the representation of diverse groups and perspectives;
• Work/life balance to accommodate employee needs, where appropriate;
• Encouragement and support of employer and employee community and civic participation

At BelHealth, we strive to create a culture where diversity contributes to a better company and better returns for our investors, where equality and inclusion is achievable for all our stakeholders, and where opportunities, support and accountability are a part of our daily work ethic. We are committed to continually improvements in these areas as we strive to be good stewards of the capital committed to us and good corporate citizens.