Aether's ESG Policy & Procedures guides its evaluation of environmental, social and governance-related risks related to each investment that Aether considers. The explicit goal of this policy is to comply with the principles of the United Nations Global Compact, which in turn depends on compliance by the managers, general partners or sponsors with which Aether partners. Accordingly, Aether believes that a thorough examination of ESG policies and procedures employed by managers or general partners of underlying funds or the sponsors of co-investments in the course of Aether’s due diligence process and ongoing monitoring of the activities of those managers, general partners and sponsors are critical in order to comply with the principles of the UNGC. The key aspects of this policy include reviewing policies, procedures and monitoring practices, and providing feedback on potential policy improvements.
In cases where, prior to investment, gaps are identified with respect to the ESG policies or procedures, Aether will recommend amendments to ESG policies and procedures to ensure that such ESG policies and procedures appropriately address in sufficient detail the four aforementioned categories. If the manager, general partner or sponsor is not willing to amend its policies or procedures, Aether may choose to forego an investment solely on the basis of insufficient ESG policies and procedures if the manager, general partner or sponsor’s resistance to amending its procedures is determined to be unreasonable. Post investment, If Aether determines that the manager, general partner or sponsor knowingly violated its own ESG policies or if Aether determines that violations were a result of gross negligence, additional steps may be taken, including but not limited to notifying other limited partners of the violation, attempting to exercise no-fault removal or no-fault termination provisions, if applicable, or selling the interest in the investment in a secondary sale.