Environmental, Social and
Governance Policy

‍Introduction

This policy sets out our commitment and approach to integrating Environmental,
Social and Governance (“ESG”) factors into the investment process as well as
across the culture and operations of the firm.

Tangency Capital drives ESG initiatives in two ways: on a corporate level, by
delivering an inclusive, carbon negative, future oriented work environment; and
through our investments, by active stewardship and engagement with our portfolio
companies.

Tangency Capital believes that ESG is not only our core to our investment process
but also our own business culture and operation. We seek to demonstrate best
practice in ESG initiatives at a firm level.


ESG Committee

The senior management of Tangency Capital has developed an ESG culture.
Tangency Capital maintains oversight and accountability of its approach to ESG.
Tangency Capital has established an ESG Committee consisting of senior individuals
representing a range of business areas. The ESG Committee meets at least
quarterly (or more if required on an ad hoc basis) and meetings are minuted.


ESG Integration within investment process

The senior management of Tangency Capital has developed an ESG culture.
Tangency Capital maintains oversight and accountability of its approach to ESG.
Tangency Capital has established an ESG Committee consisting of senior individuals
representing a range of business areas. The ESG Committee meets at least
quarterly (or more if required on an ad hoc basis) and meetings are minuted.


Industry Bodies

Principles for Responsible Investment
Tangency Capital became a signatory to the UN-supported Principles for
Responsible Investment (PRI) in February 2019, i.e., within the first year of fund
launch.  The PRI is fast becoming a global standard for investment managers’ ESG
alignment.
Through its association with the PRI, Tangency Capital is committed to adhering to
the six Principles for Responsible Investment:


Principle 1: We will incorporate ESG issues into investment analysis and
decision-making processes.
Principle 2: We will be active owners and incorporate ESG issues into our
ownership policies and practices.
Principle 3: We will seek appropriate disclosure on ESG issues by the
entities in which we invest.
Principle 4: We will promote acceptance and implementation of the
Principles within the investment industry.
Principle 5: We will work together to enhance our effectiveness in
implementing the Principles.
Principle 6: We will each report on our activities and progress towards
implementing the Principles.

Tangency Capital will report annually to the PRI on the firm’s responsible investment
initiatives, activities and achievements.We seek to meet the standards expected by
the PRI in doing so and plan to share this reporting with investors on request once it
has been completed.

Standard Board for Alternative Investments

Tangency Capital is a signatory to the Standard Board for Alternative Investments
(SBAI) standards. The SBAI is an active alliance of alternative investment managers
and institutional investors dedicated to advancing responsible practice, partnership,
and knowledge across the alternative investment industry.


ESG Procedures

In addition to the ESG approach deployed within the investment process, Tangency
Capital believes it is important to operate its own business in line with good ESG
practices. As such, Tangency Capital has implemented the following business
initiatives across the three pillars of ESG. The ESG Committee is responsible for
ESG initiatives at the management company level and is constantly seeking to
improve and enhance our own ESG culture.

Firm ESG initiatives are focused in the following areas:
Environmental Initiatives
Carbon Neutral Organisation
Energy Efficiency
Travel Practices
Waste Management
Social Initiatives
Diversity & Inclusion
Employee Wellbeing and Internal Engagement
External Engagement
Governance Initiatives
Governance Structures
Governance Policies
Memberships of Industry Bodies

ESG Training

The ESG landscape is constantly evolving, and Tangency Capital is keen to ensure
that all staff are educated and aware of ESG developments across the investment
universe. To that end, training is provided to all staff on ESG matters on an annual
basis, or more if required.

Policy Review      

The ESG Policy is reviewed at least annually.