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Clean Investor – Responsible Investment Policy


1. Introduction

This Responsible Investment Policy outlines Clean Investor’s commitment to integrating Environmental, Social, and Governance (ESG) principles across every stage of the investment lifecycle. Our approach ensures ESG considerations are embedded into investment screening, due diligence, portfolio management, and exit strategies to support sustainable long-term value creation.

This policy provides a consistent and principled framework for responsible investing, aligned with investor expectations, global ESG best practices, and Clean Investor’s mission to support high-growth businesses while delivering positive environmental and social outcomes.


2. Our Purpose and Commitment

At Clean Investor, our purpose is twofold: to deliver strong long-term returns for investors while contributing positively to the environment, industries, and communities in which we operate.


Our responsible investment philosophy is guided by the following core beliefs:

We believe responsible investing creates stronger, more resilient, and future-ready businesses.

We are committed to being responsible global citizens and generating measurable ESG impact through our investments and operations.

As active investors and strategic partners, we believe we can amplify positive outcomes through the businesses we support.

We recognize that founders, investors, employees, and stakeholders increasingly expect transparency, accountability, and sustainable business practices.

We believe long-term investment success requires continuous improvement in governance, operational integrity, sustainability, and ESG performance.

By integrating ESG factors into our investment decisions and portfolio management processes, we aim to mitigate risk, unlock long-term value, and support sustainable business growth.


3. Scope

This policy applies to all current and future investments, investment decisions, portfolio management activities, industries, and geographic regions in which Clean Investor operates.

While we seek to apply this policy consistently across all investments, we acknowledge that our level of influence may vary depending on ownership structure, board representation, and investment position.


4. Our Responsible Investment Principles

Clean Investor’s ESG approach is guided by the following principles:

Integrated ESG Approach

We integrate ESG risks and opportunities into investment screening, due diligence, investment approval, portfolio management, and exit planning.

Active Ownership

We work closely with portfolio companies to improve ESG performance, strengthen governance, and create long-term financial, operational, and reputational value.

ESG Priorities

We focus on ESG risks and opportunities relevant to each business and industry, with particular emphasis on:

Decarbonization and climate action

Employee health and safety

Employee engagement and wellbeing

Diversity, equity, and inclusion

Community impact and social responsibility

Ethical and sustainable supply chains

Cybersecurity and data privacy

Transparency and Accountability

We are committed to transparent ESG reporting, performance measurement, and stakeholder communication.


5. ESG Integration Across the Investment Lifecycle


5.1 Investment Screening

During the initial investment screening phase, Clean Investor:

Screens opportunities against our exclusion criteria

Assesses industry-specific ESG risks and opportunities

Evaluates climate-related risks and sustainability impacts

Considers human rights, labor standards, modern slavery risks, and supply chain ethics

Reviews governance standards, operational integrity, and regulatory compliance

ESG findings are incorporated into investment selection and due diligence prioritization.


Exclusion Policy

Clean Investor will not invest in businesses involved in:

Illegal activities or operations violating international laws, environmental standards, or human rights principles.

Unethical business practices, including severe environmental harm, exploitative labor practices, or animal cruelty unrelated to approved medical or pharmaceutical research.

Businesses generating significant revenue from:

Tobacco products

Fossil fuel extraction or transportation

Gambling

Pornography

Weapons and arms manufacturing

Controversial weapons prohibited under international conventions


5.2 ESG Due Diligence

During due diligence, we assess material ESG risks and value-creation opportunities through:

Management interviews

Documentation reviews

ESG risk assessments

Industry benchmarking

External specialist advisors where required

Our evaluation includes:

Management alignment with ESG priorities

Governance quality and ethical standards

Sustainability readiness and operational resilience

Risk management systems and compliance frameworks

Long-term ESG value creation opportunities

Investment decisions incorporate ESG findings alongside commercial and operational considerations.


5.3 Portfolio Management and Active Ownership

Clean Investor actively supports portfolio companies in embedding ESG principles into their operations and growth strategies.

We work closely with management teams to:

Integrate ESG goals into business strategy and KPIs

Develop sustainability and governance frameworks

Improve operational resilience and risk management

Strengthen workforce wellbeing and inclusion

Enhance cybersecurity and data protection practices

Implement measurable ESG reporting systems

ESG Monitoring

Portfolio companies are expected to provide regular ESG reporting, including progress against agreed ESG objectives and material risk areas identified during due diligence.

Managing ESG Breaches

Where ESG issues arise, Clean Investor prioritizes engagement, remediation, and operational improvement. However, we reserve the right to divest from investments where serious or sustained ESG breaches remain unresolved.


5.4 Exit Readiness and Responsible Stewardship

As part of exit planning, Clean Investor supports portfolio companies in demonstrating ESG maturity, operational sustainability, and long-term value creation.

We incorporate ESG achievements, sustainability initiatives, and governance improvements into exit positioning and transaction materials.

Where appropriate, we also assess the ESG credentials and stewardship approach of prospective buyers.


6. ESG Priority Areas

While ESG considerations vary across industries, Clean Investor focuses on seven key ESG priorities across all investments:

Decarbonization and Climate Action

We support the transition toward a low-carbon economy and aim to contribute toward achieving Net Zero emissions across our portfolio by 2050.

Health and Safety

We promote safe, healthy, and secure workplaces across all portfolio companies.

Employee Engagement and Wellbeing

We support fair compensation, employee development, workplace wellbeing, and strong organizational culture.

Diversity, Equity, and Inclusion

We encourage equal opportunity, inclusive leadership, and workforce diversity across all levels of business.

Community Engagement

We support charitable initiatives, community development, and meaningful social impact programs.

Ethical Supply Chains

We maintain zero tolerance toward modern slavery, child labor, unethical sourcing, and environmentally harmful supply chain practices.

Cybersecurity and Data Privacy

We prioritize robust cybersecurity systems, responsible data management, and stakeholder trust.


7. Governance and Responsibilities

Clean Investor Board

The Board holds ultimate responsibility for overseeing responsible investment strategy and ESG integration.

Investment Committee

The Investment Committee ensures ESG considerations are incorporated into investment decisions and portfolio oversight.

ESG Working Group

The ESG Working Group supports ESG integration, policy development, due diligence processes, and continuous improvement initiatives.

Portfolio Companies

Portfolio company leadership teams are responsible for implementing ESG initiatives, monitoring performance, and maintaining transparent ESG reporting practices.


8. Disclosure and Reporting

Clean Investor is committed to transparency and accountability in ESG reporting.

We provide regular ESG updates to investors and stakeholders, including reporting on ESG initiatives, material metrics, sustainability outcomes, and progress against ESG priorities.

This Responsible Investment Policy will remain publicly available through our official channels.


9. Policy Review

The Clean Investor Board of Directors will review this Responsible Investment Policy annually and update it as required to reflect evolving ESG standards, investor expectations, regulatory requirements, and industry best practices.


Policy Updated: February 2026

Next Review Date: February 2027