TowerBrook publishes our Responsible Ownership Statement on our website, distributes it to all of our controlled portfolio companies and asks for it to be observed. In addition to establishing the policies described in the Responsible Ownership Statement, TowerBrook periodically asks all of its portfolio companies to complete a comprehensive questionnaire designed to identify ESG issues. TowerBrook continues to enhance its monitoring of its portfolio company's ESG risk during 2020.
During ownership, ESG related risks are managed by the boards and management teams of the individual portfolio companies. Since TowerBrook invests in a wide range of sectors, ESG risks vary widely from company to company. TowerBrook seeks to discuss the importance of ESG with each CEO of private equity portfolio companies, together with the Chair, who would have been separately instructed during onboarding with a Welcome Pack that explicitly addresses Responsible Ownership and the Chair's role therein.
TowerBrook actively monitors ESG at the portfolio company level, ensuring that systems and resources are in place to enable ESG risks to be effectively managed and that each portfolio company assigns specific management responsibility for ESG operations. TowerBrook ensures that all controlled portfolio companies have instituted the following formal policies in place: (i) Anti-Bribery, (ii) Code of Conduct, (iii) Corporate Governance, (iv) Health and Safety and (v) Anti-Harassment. TowerBrook also seeks to ensure that each portfolio company has established a dedicated board Committee (for example ESG or CRS), or modified an existing governance committee, to (a) establish a corresponding charter that is bespoke to the language, culture and business of each company, (b) review the company's significant strategies, activities and policies regarding ESG (including labor practices) and community impact and charitable activities, and (c) make recommendations to the Board that focus on maximizing long-term, sustainable value creation. TowerBrook has increased its touch points with the boards of portfolio companies. ESG is an issue we raise explicitly in onboarding each portfolio chair and expect each chair to attend to, in partnership with TowerBrook, as a matter of providing effective governance. Portfolio company management would then engage with third parties (such as suppliers, developers, and contractors) to verify sound ESG practices. Finally, TowerBrook reviews annually the ESG program at each Portfolio Company board level. TowerBrook also provides training to senior management of its portfolio companies periodically that addresses ESG issues, covering relevant employee-related policies, sourcing policies, and environmental policies. TowerBrook also organizes periodic manager roundtables and/or conference calls, at which ESG features as a topic for discussion (together with anti-bribery, cybersecurity, diversity, etc.).