ESG POLICY

I. BACKGROUND

At AncoraOak, our foundational business philosophy stems from the belief that our responsibility toward our stakeholders is the cornerstone of a sustainable, profitable, and impactful business. We consider value creation and sustainable growth to be harmoniously aligned objectives. Drawing from our rich heritage as a trusted steward of long-term assets, we recognize the integral role ESG factors play in the modern financial landscape. Our focus on the long-term has inherently driven us to embed strong ESG principles across our asset management business and underlying operations. As we build on our legacy, we are continuously enhancing our ESG methodologies and performance metrics. Our commitment to leading ESG practices is also reflected in our affiliations with various global organizations and frameworks, including the United Nations-supported Principles for Responsible Investment (“PRI”).

We define material ESG factors as those having a direct and significant influence on an organization’s ability to generate economic, environmental, and social value for itself and its stakeholders. While our emphasis may vary across industries, activities, regions, and business types (e.g., control, joint control, minority, public equity, or debt), our commitment to ESG remains unwavering. In shaping our approach, we take cues from premier ESG frameworks and standards, including the Sustainability Accounting Standards Board (“SASB”) and the Taskforce for Climate-related Financial Disclosures (“TCFD”).

II. SCOPE AND APPLICATION

The objective of this ESG Policy (“Policy”) is to formalize AncoraOak’s approach to ESG management. This Policy is applicable to all directors, officers, employees, and temporary workers of AncoraOak. In scenarios where AncoraOak invests in an entity but does not hold managerial or controlling stakes (e.g., joint ventures or partnerships), we will exert commercially viable efforts to ensure the asset and operational management of that entity aligns with this Policy. We anticipate our controlled public affiliates will either adopt this Policy or formulate an ESG policy that resonates with the tenets of this Policy, with necessary modifications to reflect their distinct investment strategies.

III. GUIDING PRINCIPLES

AncoraOak’s commitment to ESG is built upon the following foundational principles:

Environmental Stewardship:

We continuously aim to lessen the environmental impact of our operations.
We are committed to the objective of net-zero greenhouse gas (“GHG”) emissions by 2050 or earlier.

Employee Well-being & Safety:

We champion a positive work environment rooted in respect for human rights, valuing diversity, and an unwavering stance against discrimination, harassment, or violence.
We ardently pursue the goal of zero severe safety incidents by implementing leading health and safety practices.

Governance Excellence:

We operate with the utmost ethical standards, as outlined in our Code of Business Conduct and Ethics.
We strive for robust stakeholder relationships through transparency and proactive engagement.

Corporate Citizenship:

We ensure the interests and safety of communities in which we operate are integral to our decision-making process.
We actively encourage and support philanthropic efforts and volunteerism among our employees.

IV. ESG INVESTMENT PROCESS

At AncoraOak, material ESG considerations are intricately woven into our investment process. We emphasize:

Due Diligence:

Early stages involve proactive identification of ESG risks and opportunities relevant to potential investments, leveraging industry-specific guidelines and, where applicable, comprehensive risk assessments.

Investment Committee Approval:

All investment decisions require the endorsement of the Investment Committee, which evaluates transactions based on a range of criteria, including those pertinent to ESG.

Ongoing Management:

Ongoing Management: Post-acquisition, we craft tailored integration plans that highlight significant ESG-related considerations. Our investment returns have consistently shown a strong correlation with effective ESG management.

Exit Strategy:

Upon divestiture preparation, we emphasize potential value derived from various factors, inclusive of ESG considerations.

V. STEWARDSHIP

Stewardship remains a pivotal aspect of our ESG strategy. We engage extensively with our portfolio entities and collaborate with industry counterparts to refine our ESG practices. Our influence extends over a significant portion of global assets, where we collaborate to foster sound ESG practices.

VI. ROLES AND RESPONSIBILITIES

AncoraOak’s Board of Directors exercises ultimate oversight of our ESG strategy, receiving frequent updates on our initiatives. Management teams at portfolio companies shoulder the primary responsibility for ESG considerations.

VII. RELATED POLICIES AND PROCEDURES

This ESG policy is complemented by numerous governance documents pertinent to our operations:

Anti-Bribery and Corruption Program

Anti-Money Laundering and Trade Sanctions Policy

Code of Business Conduct and Ethics … [and other policies]

VIII. FRAMEWORKS, MEMBERSHIPS, AND COMMITMENTS

AncoraOak continually aligns with prominent responsible investing frameworks and actively engages in industry forums. We remain signatories to numerous initiatives reflecting our commitment to ESG best practices.

IX. CHANGES TO THIS POLICY

This policy, overseen by our Chief Administrative Officer and General Counsel, undergoes periodic reviews and updates as deemed necessary.