Responsible Investing Guidelines

Amicus Capital has drawn-up the following eleven point guidelines for ‘Responsible Investing’ adopted from the American Investment Council (formerly Private Equity Growth Capital Council). The firm has also adopted a policy called ‘Policy on Management of Environmental, Social and Governance Aspects’ (“ESG Policy”). The ESG Policy guides the decision-making process both within Amicus Capital and those relating to investments made by it.

• Remain committed to compliance with IFC Performance Standards, applicable national, state, and local labour laws in the countries in which Amicus Capital operates and/or invests in.
• Commit to continuous improvement with respect to management of environment, social and governance matters.
• Consider environmental, public health, safety, and social issues associated with target companies when evaluating whether to invest in a particular company or entity, as well as during the period of ownership.
• Seek to be accessible to, and engage with, relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.
• Seek to grow and improve the companies in which Amicus Capital invests for long-term sustainability and to benefit multiple stakeholders, including on environmental, social and governance issues.
• Seek to use governance structures that provide appropriate levels of oversight in the areas of audit, risk management and potential conflicts of interest and to implement compensation and other policies that align the interests of owners and management.
• Support payment of competitive wages and benefits to employees; provide a safe and healthy workplace in conformance with national and local laws; and apply relevant international best practice standards.
• Maintain policies that prohibit bribery and other improper payments to public officials consistent with the US Foreign Corrupt Practices Act, 1977; UK Bribery Act, 2010; The Prevention of Corruption Act, 1988; similar laws in other countries, and the OECD Anti-Bribery Convention.
• Respect the human rights of those affected by its investment activities and take steps to ensure that its investments do not flow to companies that utilize child or forced labour or maintain discriminatory policies.
• Provide timely information to Amicus Capital’s limited partners on the matters addressed herein, and work to foster transparency about the activities of Amicus Capital.
• Encourage portfolio companies of Amicus Capital to advance these same principles in a way which is consistent with the fiduciary duties of Amicus Capital.