Portfolio Advisors will incorporate certain ESG considerations into its due diligence, monitoring, and reporting processes where consistent with its ESG Policy and fiduciary responsibilities. As part of PA's due diligence and investment committee process, PA will take into account ESG factors that may be relevant to a particular general partner's investment strategy, in particular as it may apply to certain industry sectors and/or portfolio companies. For active investments, PA will track broad ESG parameters of underlying funds. Also, PA will monitor general partners it has invested with and promote ESG principles, where applicable.
Portfolio Advisors has been registered with the SEC as an investment adviser since 1994, thus is subject to the rules and regulations set forth in the Investment Advisers Act of 1940. The broad anti-fraud provisions of the Advisers Act impose fiduciary duties on investment advisers, including an affirmative duty of “utmost good faith” to act in the best interest of the client and the duty to “provide full and fair disclosure of all material facts” that may have an impact on an investment adviser’s independence and judgment. PA professionals must act for the benefit of their clients and place their clients' interests before their own.