Updated March 2024

At Norwest we integrate responsible investing practices into our investment decision-making and portfolio services because we believe that optimizing responsible business performance can drive value creation, while ignoring such performance exposes a company to material risks. This has been reflected in how we do business for decades.

We recognize the importance of responsible business strategies in our internal operations as a firm and aim to hold ourselves to the same standard as our portfolio companies.

How We Define Responsible Investing

Responsible investing to us means doing ethical and sustainable business with companies ready to do the same. We aim to consider performance across governance, social, and environmental categories in order to generate better returns.

• Environment: Performance related to environmental risks and impacts
• Social: Impacts on and relationship with stakeholders
• Governance: Performance related to fair, accountable, and transparent corporate practices

At the same time, our commitment to the concepts of diversity, inclusion and equity are consistent, though the acronyms may change over time.

• Diversity: Presence of a variety of perspectives, backgrounds and experiences within the organization
• Equity: Access to opportunities; acknowledging that barriers exist for some in our society
• Inclusion: Leveraging the talents and skills of every employee

Integrating Responsible Investing at Norwest

We seek to take a responsible approach to investment. We aim to recognize the potential impact of portfolio companies on the environment, workers, communities, and society, as well as the potential impacts of sustainability issues on the companies the firm invests in.

Building on Norwest’s values and firm culture, and representing a formalization of our long-running commitment to responsible business practices, we are currently focusing on three areas related to responsible investing.

1: Risk Screening & Due Diligence

We screen companies and exclude from investment any company with a primary business that is on our exclusion risk list. We also aim to perform due diligence on our companies to learn how they align with the UN Global Compact principles. Our risk screening and due diligence process will enable us to flag risks, make better investment decisions, and indicate what forms of portfolio services may be most valuable to the investee over time.

2: Investment

We hope companies we invest in will share our commitment to responsible and sustainable business practices. We will seek to include a clause in term sheets that expresses our mutual intent to improve the company’s responsible business performance over time. We will work with our portfolio companies that agree to the term sheet clause to develop and evolve responsible and sustainable business practices.

3: Portfolio Management

A central focus of our approach includes engaging with and educating our portfolio companies on responsible and sustainable business strategies, and relevant risks and opportunities. Once invested in, we will dedicate resources to support our companies in developing best practices related to responsible business performance.

• We will work closely with those portfolio companies that are open to education about best practices.
• Companies that are unwilling or unable to participate in targeted responsible investing efforts will still receive encouragement and resources to mitigate risks that Norwest identifies in due diligence.

Our Focus on Diversity, Equity and Inclusion

At Norwest, an intentional commitment to diversity, equity, and inclusion is foundational to our team’s work. This belief is core to how we have operated for decades. Some of our initiatives include:

• Educational fireside chats with industry leaders
• Resources & frameworks entrepreneurs can leverage for their organizations
• Investing in entrepreneurs from underrepresented groups
• Investing in underrepresented funds
• Events focused on building a diverse board pipeline for our portfolio companies

Scope of Policy

Norwest and its affiliated investment funds will make reasonable efforts to encourage all portfolio companies to consider relevant responsible business principles. In certain investments, factors such as our ownership stake or influence may affect our ability to assess, set or monitor responsible business performance goals.

We and our affiliated investment funds will also apply the policy to our internal operations, based on the belief that effective responsible business growth and management begins with diverse and inclusive governance and team environments.

Policy Implementation Governance

Norwest has developed a “Responsible Investing Steering Committee” composed of internal team members representing key functions at the firm, and external advisors.

The Steering Committee is responsible for the following:

1. Facilitating the implementation of this policy
2. Maintaining and updating this policy
3. Providing training to employees of the firm and interested portfolio companies to ensure continued relevance and education
4. Helping to develop responsible and sustainable business strategies at interested portfolio companies

This policy has been approved by the Managing General Partners and will be reviewed and updated annually.