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
- Active Ownership
- 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 integrate ESG risks and opportunities into investment screening, due diligence, investment approval, portfolio management, and exit planning.
We work closely with portfolio companies to improve ESG performance, strengthen governance, and create long-term financial, operational, and reputational value.
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
- Exclusion Policy
- Clean Investor will not invest in businesses involved in:
- Businesses generating significant revenue from:
- Tobacco products
- Fossil fuel extraction or transportation
- Gambling
- Pornography
- Weapons and arms manufacturing
- Controversial weapons prohibited under international conventions
ESG findings are incorporated into investment selection and due diligence prioritization.
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.
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
- Managing ESG Breaches
Portfolio companies are expected to provide regular ESG reporting, including progress against agreed ESG objectives and material risk areas identified during due diligence.
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
- Health and Safety
- Employee Engagement and Wellbeing
- Diversity, Equity, and Inclusion
- Community Engagement
- Ethical Supply Chains
- Cybersecurity and Data Privacy
We support the transition toward a low-carbon economy and aim to contribute toward achieving Net Zero emissions across our portfolio by 2050.
We promote safe, healthy, and secure workplaces across all portfolio companies.
We support fair compensation, employee development, workplace wellbeing, and strong organizational culture.
We encourage equal opportunity, inclusive leadership, and workforce diversity across all levels of business.
We support charitable initiatives, community development, and meaningful social impact programs.
We maintain zero tolerance toward modern slavery, child labor, unethical sourcing, and environmentally harmful supply chain practices.
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