Five Points Capital (“FPC”) has a fundamental ethical and investment belief in responsible behavior. We seek to execute this belief across our firm’s culture, general business practices, investment considerations, the general partners with which we invest, and the portfolio companies with which we interface. We have based our Environmental, Social and Governance Policy on the ten principles of the United Nations Global Compact, as listed on Annex A hereto and accessed online at, as well as the six principles of the United Nations Principles for Responsible Investment, as listed on Annex B hereto and accessed online at

By implementing this ESG Policy, FPC strives to align its operations with broader societal objectives, including consideration of the following ESG issues:

  1. Environmental: Precaution for depletion of natural resources, disruption of fragile ecosystems, loss of endangered species, and pollution.
  2. Social: Elimination of child labor, forced or compulsory labor, discrimination, and sexual harassment; protection of human rights and diversity; and promotion of business fairness.
  3. Governance: Evaluation of corporate behaviors and values, non-shareholder stakeholder interests, and employee relations.

Specifically, our ESG Policy includes the following commitments and initiatives:

  1. During the diligence, execution, monitoring and disposition stages of our investment process, FPC will evaluate and contemplate ESG, as appropriate.
  2. FPC will encourage the financial sponsors and companies in which we invest to also consider relevant environmental, social and governance issues.
  3. FPC is committed to compliance with applicable national, state, and local labor laws in the jurisdictions in which we operate.
  4. FPC respects the human rights of those affected by the operation of our business, including our investment activities.
  5. FPC incorporates ESG issues into our ownership policies and practices.
  6. FPC seeks to use governance structures that provide appropriate levels of oversight in the areas of audit, riskmanagement and potential conflicts of interest.
  7. FPC maintains policies that prohibit bribery and other improper payments to public officials consistent with the USForeign Corrupt Practices Act and similar applicable laws in other jurisdictions in which we operate and invest.
  8. FPC strives to be a responsible employer by creating a culture in which we develop a diverse pool of high caliber employees and by committing to talent management and development in order to give everyone at FPC an opportunityto perform to the best of his or her ability.
  9. FPC’s employees will work together to consider and promote ESG.

To promote ESG culturally at FPC and to establish accountability for such promotion, FPC has appointed two senior professionals and two additional team members to serve as ESG Champions: Marshall White (lead), Whit Edwards, Dudley Commander, and Mary Lou Cianci. Each is passionate about ESG and works to instill these principles in FCP’s activities and culture. Additionally, FPC maintains a “Green Team” consisting of FPC employees whose goal is to promote ESG initiatives throughout the firm.

FPC strongly believes in and promotes honesty, integrity, fairness and respect in all of our business dealings. Furthermore, we believe that introducing ESG considerations in our business and investment decisions can create value for our clients and investors.

Annex A
The Ten Principles of the United Nations Global Compact

Human Rights
Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; and

Principle 2: make sure that they are not complicit in human rights abuses.

Principle 3: Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining;

Principle 4: the elimination of all forms of forced and compulsory labor;

Principle 5: the effective abolition of child labor; and

Principle 6: the elimination of discrimination in respect of employment and occupation.

Principle 7: Businesses should support a precautionary approach to environmental challenges;

Principle 8: undertake initiatives to promote greater environmental responsibility; and

Principle 9: encourage the development and diffusion of environmentally friendly technologies.

Principle 10: Businesses should work against corruption in all its forms, including extortion and bribery.

Annex B
The Six Principles of the United Nations Principles for Responsible Investments

Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes;

Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices;

Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest;

Principle 4: We will promote acceptance and implementation of the Principles within the investment industry;

Principle 5: We will work together to enhance our effectiveness in implementing the Principles; and

Principle 6: We will each report on our activities and progress towards implementing the Principles.

Information • Education • Action

The increasing severity of climate change brings with it a range of material and immaterial risks pertinent to long-term investment activity. An increasing arsenal of scientific research highlights a complex profile of climate-related risks pertaining to regulation, asset yield and pricing, consumer preferences and firm reputation, all of which make outcomes of long-term investing difficult to predict or control.

Five Points Capital (“FPC”) is focused on the long-term prosperity of its employees, clients, various stakeholders, and planet. To that end, FPC seeks to take actions to both mitigate climate change instigators and, to the extent that certain environmental conditions are irreversible, cautiously adapt to existing risks.

To accomplish this, FPC has created a three-pronged approach to its Climate Policy centered around Information; Education; and Action. This keeps FPC accountable for:

  1. Staying informed about climate-related research and regulations
    1. Forming a team of employees across various levels of management to follow climate-related news and identify risks and opportunities accordingly
    2. Appointing at least one Managing Partner to convey these risks and opportunities to the rest of the investment team
    3. Actively reading and internalizing the literature provided by partner organizations, including the UN Global Compact and UN Principles for Responsible Investment
  2. Playing a proactive role in increasing awareness of industry practices that help mitigate the various long-term climate- driven risks by:
    1. Communicating climate-conscious and risk-mitigating practices to financial sponsors and portfolio companies
    2. Encouraging financial sponsors and portfolio companies to develop policies pertaining to environmental, social, and governance issues
    3. Periodically communicating FPC’s climate-focused practices to limited partners
    4. Providing FPC employees with guides and training pertaining to making more climate-friendly decisions
  3. Taking actionable steps firmwide to reduce FPC’s carbon footprint by:
    1. Taking advantage of various programs that help divert waste from landfills and increase energy and water efficiency
    2. Adjusting practices during different seasons to minimize energy use (e.g., lowering shades during the day in summertime to prevent excess heating)
    3. Subsidizing and/or encouraging the use of alternative transportation to work (walking, cycling) to decrease emission of fossil fuels
    4. Engaging FPC employees in a quarterly activity related to environmental or social issues
    5. Evaluating the effectiveness of FPC’s climate-focused actions on an annual basis, identifying areas forimprovement, and adjusting actions accordingly