ALPINE INVESTORS ENVIRONMENTAL, SOCIAL AND GOVERNANCE POLICY

At Alpine, we believe that the private equity industry has the opportunity to create jobs, grow businesses, distribute wealth, increase employee engagement, and affect positive change in the world.

As do many of its private equity fund limited partners, Alpine Management Services III, LLC and its affiliated general partners (together “Alpine”) recognize the importance of investing responsibly with sensitivity to environmental and social concerns and are dedicated to conducting ourselves in accordance with applicable legal, ethical and industry standards in our business. Alpine believes that appropriate consideration of environmental, social and governance (“ESG”) factors when choosing investments and overseeing the management of its portfolio companies is important to investment processes and can be a contributor to investment returns. The firm wishes to run businesses that are operated with due attention to these concerns, and is committed to the integration of ESG factors into its day-to-day activities.

Generally, Alpine’s investment professionals are primarily responsible for ensuring that consideration of ESG issues is integrated into private equity investment decisions. Where additional subject matter expertise is needed, Alpine’s investment professionals may consider utilizing external resources to advise them on an appropriate course of action.

Alpine has chosen the following actions to appropriately identify and manage ESG issues and opportunities in our investing activities. It should be noted that Alpine’s investment strategy focuses on companies in the Software and Services (including Online) sectors. These types of businesses rarely operate in asset heavy environments (e.g., those with plants and machinery, or selling a tangible product) and tend to have a highly skilled workforce. Through the course of all investment decisions, Alpine seeks to:

  1. Inform members of the Alpine investment staff of this ESG policy and periodically seek input from them on its implementation and effectiveness.
  2. Review appropriate ESG factors as part of the due diligence review of every investment prior to committing to that investment. These factors may include: environmental impacts and conservation opportunities; corporate governance; management structure and compensation; employee relations; and similar matters.
  3. Consider ESG concerns or opportunities identified during due diligence as part of the approval process for each investment; where a material ESG concern or opportunity is identified, the approval of the investment will require a plan to address it as part of the operating improvement plan developed for each investment which will then be monitored during the course of the investment. The investment committee’s approval will note whether an ESG concern or opportunity was identified.
  4. Work through appropriate governance structures (e.g., boards of directors) of portfolio companies to encourage attention to factors identified in #2 above with the goal of improving performance and minimizing adverse impacts in these areas.
  5. Direct Alpine personnel who are members of portfolio company boards of directors to report to the firm on any material ESG issues that arise during oversight of a company’s business and on plans to remediate them.
  6. Seek to be accessible to, and be willing to engage with, relevant stakeholders either directly or through representatives of portfolio companies.
  7. Remain committed to compliance with applicable national, state, and local labor laws; support the payment of competitive wages and benefits to employees; and seek to provide a safe and healthy workplace in conformance with national and local law.
  8. Avoid investments in business that derive a material portion of their revenues from the sale of alcohol, tobacco, pornography, gambling, or firearms, and businesses that are known to utilize child or forced labor or maintain unlawful discriminatory employment policies.
  9. Remain informed about ESG developments and best practices within the private equity industry and periodically consider changes and additions to this policy based on those developments.