Pathway educates its investment professional with regard to their specific obligations in implementing ESG practices.
Fundamental to Pathway’s due diligence process is a thorough review of the general partner’s organization, structures, and internal processes. Pathway’s investment professionals perform comprehensive onsite interviews with the key senior professionals of the manager under analysis. These interviews provide the opportunity for an in-depth discussion on the general partner’s incorporation of ESG issues into its investment decision-making process and other investment-related issues. The deal team, which is assigned by Pathway’s chief investment officer for each investment opportunity, presents to the Investment Committee any material ESG concerns, including but not limited to, the general partner’s ESG policies, the general partner’s investment history reflecting any known ESG issues that would have clearly been in violation of this policy, and the likelihood of a recurrence.
The CCO conducts a formal risk-analysis of the firm’s responsible investing procedures each year. This analysis assesses the firm’s exposure to risks from an ESG perspective and the impact it could potentially have to the firm if the responsible investing policy is not functioning properly.
The CCO, along with the firm's general counsel, reviews and updates Pathway's Responsible Investing Policy.