NSSK believes that implementing an Environmental, Social and Governance (“ESG”) policy is socially responsible and can also improve the returns in our investment portfolio. We embed the following principles in our investment process:
1. Consider ESG issues associated with target companies when evaluating whether to invest in a particular company or entity, as well as during the period of ownership.
2. Seek to engage with relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.
3. Seek to grow and improve the companies in which we invest for long‐term sustainability; work with portfolio companies through representation on their boards or other governance structures, with the goal of improving performance and minimizing adverse impacts in ESG areas.
4. Seek to provide appropriate levels of oversight in the areas of audit, risk management and potential conflicts of interest and to implement policies that align the interests of owners and management.
5. Comply with applicable labor laws in all respects, including those on wages, workplace safety, equal employment opportunities and rights of employees to join unions and collective bargaining, in the countries where we invest.
6. Maintain strict policies that prohibit bribery and other improper payments in order to gain commercial advantage.
7. Respect the human rights of those affected by our investment activities and seek to confirm that our investments do not flow to companies that utilize child or forced labor or maintain discriminatory policies.
8. Provide timely information to our limited partners on ESG matters.
9. Seek ESG disclosures from our portfolio companies, and encourage our portfolio companies and service providers to advance ESG principles consistent with this policy when they do businesses.