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ESG Policy

Borgman Capital’s Environmental, Social & Governance Policy

Borgman Capital (“Borgman”, “we”, “us”, or “our”) believes that the effective evaluation and management of Environmental, Social, and Corporate Governance (“ESG”) issues can impact investment performance and is committed to investing in the spirit of corporate sustainability. By formalizing and enhancing our commitment to integrating ESG considerations, Borgman intends this policy to define a set of principles that will guide its consideration of material ESG issues throughout the investment process.

Through this ESG Policy, we strive to align with the factors pertinent to us as defined by both the Sustainability Accounting Standards Board (“SASB”) and our core principles. We recognize that industry guidelines and best practices in managing ESG issues will continue to evolve over time. As such, we will review this ESG Policy regularly to incorporate substantive changes.

Pertinent E, S, & G factors as defined by both the SASB and our core principles are as follows:

Environmental

Environmental impact consideration and assessment

Social

Community relations, data security, selling practices & product labeling, employee engagement, diversity & inclusion

Corporate Governance

Product design & lifecycle management, business ethics, systemic risk management

We are committed to the implementation of the principles set forth in this ESG Policy and will seek to enhance ESG management and awareness among our employees. We are currently implementing this commitment by:

  • Conducting environmental impact assessments as part of our investment due diligence process, when appropriate

  • Donating to and sponsoring non-profit and professional organizations in our community

  • Participating in and hosting volunteer events and fundraising campaigns in our community

  • Encouraging and financially supporting employee involvement in professional organizations and events in pursuit of continuous education and training

  • Following a well-defined compensation structure for all employees

  • Mitigating risk through detailed analysis and modeling prior to making substantial business decisions

  • Striving to always adhere to our mission statement, core values, and brand promises

Our Future ESG Goals

We are passionate about continuous learning and improvement. In order to ensure our ESG approach is as robust and effective as possible, we are committed to the following:

  • Frequently monitoring our information technology (“IT”) needs and risks and creating a Data Breach Response Plan

  • Conducting regular training sessions for employees regarding the importance of data security

  • Formalizing our policies and practices regarding the attraction and advancement of a more diverse and inclusive workforce

  • Implementing a formalized process for submitting anonymous whistleblower complaints