GUIDELINES FOR RESPONSIBLE INVESTING

The American Investment Council membership adopted responsible investment guidelines in 2009 and has continued to update those guidelines throughout the years. These guidelines offer a set of aspirational common principles for the private investment industry to use – in combination with other frameworks and guidance as needed – to implement responsible investment programs that are most suited to their investment mandates.

The AIC Guidelines for Responsible Investing (the “Guidelines”) encourage AIC member firms, subject in all cases to their fiduciary obligations, to:

1. Consider potentially financially material sustainability issues associated with investments throughout the investment process, including pre-acquisition, ownership, and at exit.
2. Seek to be accessible to, and engage with, relevant interested parties either directly or through representatives of portfolio companies, as appropriate.
3. Seek to grow and improve the companies in which their funds invest for long-term value creation. This may include taking steps, where and if appropriate, to mitigate and/or adapt to severe weather events and other environmental impacts over the longer term to help build stronger and more resilient assets and companies.
4. Provide appropriate levels of oversight in the areas of audit, risk management, compliance, and potential conflicts of interest and to implement compensation and other policies that align the interests of owners and management.
5. Seek to support and improve the well-being of employees as part of human capital management strategy and in compliance with applicable laws. This includes supporting the payment of competitive wages and benefits to employees; providing a safe and healthy workplace; and respecting rights of employees to decide whether or not to join a union and engage in collective bargaining.
6. Promote high performance workplaces that attract and retain employees with a broad range of business relevant experiences, backgrounds, and viewpoints, consistent with applicable law.
7. Maintain strict anti-corruption policies that prohibit bribery and other improper payments to public officials, consistent with applicable law.
8. Respect fundamental human rights and take appropriate steps to identify potential human rights issues in due diligence and investment decision-making processes.
9. Provide timely information to their funds’ limited partners on the matters addressed by these Guidelines, and work to foster transparency with respect to such matters.
10. Seek to engage with portfolio companies on the application of these Guidelines as appropriate and commensurate with the investment objective, level of control, or other factors, with the goal of improving long-term financial performance and minimizing adverse impacts.