VINCI has a formal ESG Policy which is applicable to its business, portfolio companies, their suppliers and business partners with the goal of improving performance and minimizing adverse impacts in these areas. The policy is based on the following principles:

•         Environment Aspect:

1. Conduct business and establish partnership with high levels of environmental performance;
2. Comply with environmental laws and regulations;
3. Reduce environmental impact; and
4. Preserve natural resources.

•         Social Aspect:

1. Treat people with dignity and respect in a safe workplace;
2. Respect the rights of workers, complying with relevant laws and regulations relating to compensation, working hours, rest periods, equal opportunity, diversity, anti-discrimination and other benefits and welfare;
3. Respect the human rights preventing child and forced labor;
4. Provide a safe and health workplace in conformance with national and local law;
5. Improve employees’ knowledge and skills which may include internal and external training and courses offered by the firm;
6. Manage social risks of the supply chain of portfolio companies; and
7. Be accessible to, and engage with, relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.

•        Governance Aspect

1. Conduct business and establish partnership in an ethical manner at all times;
2. Establish independent annual audits and transparent disclosure of portfolio companies’ financial statements;
3. Create effective board structures;
4. Comply with relevant anti-corruption laws and regulations relating to bribery, extortion, fraud and money laundry; and
5. Provide timely information to VINCI limited partners on the matters addressed herein, and work to foster transparency about VINCI activities.

 Based on its manual, VINCI is able to demonstrate that it follows a systematic investment review and decision-making process comprised of multi-staged reviews by the Investment Committee.

The ESG-related policies are integrated throughout the investment cycle as summarized:

• Pre-Investment Phase: Upon the initial screening and approval of the investment committee, the investment is subject to two due diligence steps, which take into account the ESG factors in order to evaluate the potential ESG material topics. The potential material ESG topic are included in discussion with the Investment Committee to defined how they will be assessed during the following phased - i.e., it can be either conducted internally or by external advisors, as appropriate. When issues or gaps are identified during the ESG due diligence, related actions and deadlines are included in the Environmental and Social Action Plan (ESAP) section for evaluation. For each action, the following will be defined: the responsible party, priority, complexity and the deliverable or indicator of completion.
• Monitoring Phase: In addition to the due diligence and ESAP, some material ESG topics require frequent review during the project life cycle, such as compliance with related permits. Those questions will be monitored based on the period to be defined during the ESG due diligence