DwyerOmega seeks to incorporate Environmental, Social, and Governance ("ESG") considerations into our investment process and the operation of majority owned DwyerOmega brands ("Brands”). The purpose of this policy is to outline the responsible investing efforts of DwyerOmega and our Brands.
Philosophy
DwyerOmega recognizes the criticality of evaluating and monitoring ESG risks and opportunities associated with the companies in which we invest. We believe that ESG policies can improve returns when implemented correctly and be detrimental to returns when ignored. This policy provides the framework for our efforts to incorporate ESG risk and opportunity oversight inbalance with our broader goals of investor returns and is consistent with our fiduciary duty. ESG factors that are included in our evaluation of investment opportunities and/or the operation of our Brands in accordance with this policy may include some or all of the below:
- Environmental factors relating to the health of our environment and natural ecosystems
- Social factors relating to the rights, well-being, and interests of our stakeholders
- Governance factors relating to ethical behavior and responsible decision making
DwyerOmega seeks to invest in technology driven, meaningful to the world industrial businesses that enable a better future.
We focus on investing in businesses that have the potential to impact society on a global level. As such, we seek to align the ESG practices of DwyerOmega and our Brands with the principles outlined in the United Nations (UN) Global Compact, and are taking steps to formalize our assessment of investment opportunities and/or the operation of our Portfolio Companies by reference to some or all of the UN Sustainable Development Goals (SDGs). Additionally, this policy has been informed by certain of the recommendations of the Task Force on Climate Related Financial Disclosures (TCFD) andrelevant provisions of the Paris Agreement, as applicable.
Purpose
This policy has been developed to outline DwyerOmega’s approach to managing ESG risks and opportunities in DwyerOmega's evaluation of investment opportunities and/or the operation of our Brands. Where relevant, ESG considerations must be weighed in conjunction with other investment criteria, opportunities, and risks of Brands.
Roles and Responsibilities
DwyerOmega's Head of ESG, its Chief Financial Officer, and various other members of the company are responsible for defining, implementing, and updating this Policy, as needed. These individuals set the responsible investing standards and associated implementation tools within the company and our Brands. They also conduct annual ESG trainings to update DwyerOmega team members on the evolving standards as well as trainings to support our brands with ESG management best practices. DwyerOmega also utilizes external ESG resources where necessary or desirable.
ESG considerations are relevant throughout the investment process. The responsibility for implementing this Policy in the context of DwyerOmega's investment operations is shared by members of the team working on each investment, with ultimate oversight from DwyerOmega’s CEO.
ESG Integration into Investment activities
DwyerOmega believes ESG topics can be considered in multiple stages of DwyerOmega’s investment lifecycle. Relevant ESG considerations will vary by company and sector and may include, but shall not be limited to:
Environmental
Social
& InclusionGovernance
Exclusions
DwyerOmega incorporates an ESG pre-screening process in each investment opportunity evaluation lifecycle which allows our teams to pass on high-risk companies before beginning more detailed reviews. DwyerOmega passes on opportunities directly engaged in the production of any of the following:
- Alcohol
- Tobacco/Cannabis
- Adult Entertainment
- Gambling
Conflicts of Interest
DwyerOmega seeks to identify and mitigate any conflicts of interest with respect to its approach to ESG integration or ESG-related commitments made by DwyerOmgea. Our governance structure, policies, and procedures enable us to appropriately identify and manage risk and potential conflicts of interest at the highest level. Additionally, where applicable, DwyerOmega will endeavor to assist Brands with employing governance structures that provide appropriate levels of oversight in the areas of audit, risk management, and potential conflicts of interest.
Pre-investment
DwyerOmega endeavors to identify material ESG considerations during the due diligence review of investments using our ESG Screening Checklist. The Checklist includes the pre-screening process noted above, a predefined list of topics in the ESG categories that are relevant across all investments, and potentially material topics identified by the company’s industry as aligned with the Sustainability Accounting Standards Board (SASB). Our due diligence review process may also include end market and business model screening, management team interviews, reviews by third party service providers including environmental liability assessments, and operating site inspections. ESG factors identified as material and deemed “high risk” will be flagged and passed along to the investment team before beginning more detailed reviews.
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