1. Orlando Management AG shall adhere to and promote responsible management practices in its internal affairs as well as in all advisory activities at the level of the Portfolio Companies. Orlando Management AG shall thus periodically consider and appropriately manage ESG factors in undertaking any and all business activities.
Orlando Management AG shall exercise its influence in respect of the Portfolio Companies, such that they also adhere to and implement these ESG guidelines.
2. The members of the board, as well as the investment professionals shall be provided with adequate training in respect of ESG. The ESG performance and compliance shall form an appropriate part of each employee’s and partner’s individual appraisal.
3. Orlando Management AG shall strive to ensure that any persons employed or otherwise engaged by it adhere to these ESG guidelines. An undertaking to such effect will generally form a part of any corresponding contractual relationship.
4. Orlando Management AG shall create a comprehensive, internal compliance manual pertaining to ESG issues, as well as other compliance-related matters, such as anti-money laundering and the prevention of corruption and bribery, and shall ensure that all directors, employees, contractors and agents are contractually obliged to comply with such manual.
5. Orlando Management AG shall appoint a person responsible for compliance matters, who possesses the relevant capabilities and sufficient experience, to ensure Orlando Management AG’s compliance with this ESG policy and its other ESG-related obligations (the “Compliance Officer”). The Compliance Officer shall also serve as the point of contact for investors and Portfolio Companies with respect to ESG-related questions. The Compliance Officer shall promptly notify Orlando Management AG of any material ESG-related risks that manifest or any material ESG-related incidents that occur, whether such risks or incidents occur at the level of Orlando Management AG or in the Portfolio Companies. The Compliance Officer shall also act as the contact person for informants and shall accept the anonymous provision of compliance-related “tip-offs” from such persons. The Compliance Officer shall document the way in which such compliance-related information is dealt with and the actions taken with respect to breaches of ESG and other compliance-related obligations.
6. Orlando Management AG shall consider reasonable requests to alter and/or expand its compliance manual, whether such stems from Investors and/or is a result of the ongoing development of ESG matters. Orlando Management AG shall continuously monitor and optimise its internal organisation in view of ESG performance and compliance.
7. Orlando Management AG shall ensure that Orlando Management AG, as a company, is charitably and socially active both locally and globally, in a sustainable, conscientious and exemplary manner (“Good Citizen”) and encourages and incentivises its employees and business partners to do the same.