White Deer Energy’s Corporate, Social, and Responsibility Policy

White Deer Energy (WD) is committed to promoting responsible corporate citizenship, operational excellence, and sustainable business practices that support our stakeholders, community, and environment. This Corporate Social Responsibility (CSR) Policy outlines our sustainability activities for our portfolio of companies and our approach to Environmental, Social, and Governance (ESG) reporting. We strive to manage ESG risks and opportunities against climate change, evolving market preferences, and increased ESG-related regulation so that WD and its portfolio companies will be better positioned to enhance value creation for our stakeholders. By integrating CSR into our operations, we enhance our reputation, boost customer loyalty, and achieve efficiency gains, fostering continuous improvement and strengthening our competitive position.

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Investment Strategy

Incorporating guidance from our portfolio companies, Limited Partners, investment team, and industry experts, White Deer is committed to achieving the highest standards of ESG performance in its portfolio, with a particular focus on:

Environmental Responsibility


To minimize our environmental footprint and actively contribute to the health of our planet through sustainable business practices, WD and its portfolio companies strive to adopt policies addressing

  • Carbon Footprint Reduction
  • Waste Management and Recycling
  • Water Conservation
  • Sustainable Sourcing

Social Responsibility


We aim to foster a diverse, inclusive, and ethical workplace that contributes positively to our communities and respects human rights throughout our supply chain.

  • Community Engagement
  • Philanthropy
  • Recruitment and Diversity
  • Employee Safety and Wellbeing

Governance


To uphold strong governance practices that enhance transparency, ethical behavior, and accountability to our stakeholders, WD and its portfolio companies strive to adopt policies addressing

  • Ethical Conduct and Compliance
  • Operating Policies
  • Data Privacy and Cybersecurity
  • Stakeholder Engagement and Transparency

Scope 

The policy is intended to establish a framework for CSR throughout White Deer's (WD’s) investment lifecycle. It applies to all WD employees, the firm’s operations, and all majority-owned investments. It extends to managing our stakeholder relationships, conducting our internal business operations, and strategically positioning the firm.

WD’s influence over each company in which we invest varies. In cases where WD is a minority shareholder or has limited influence to implement a complete CSR program, we will promote the adoption of portions of this policy where reasonable. We will partner with management to implement a holistic CSR program for companies where WD is a majority investor.

Commitment

White Deer commits to responsible ESG management by:

  1. Incorporating ESG factors into investment screening, analysis, and due diligence to identify ESG risks & opportunities.
  2. Establishing ESG programs at new investments within reasonable time periods and fostering a culture of continuous improvement.
  3. Monitoring and managing ESG risks & opportunities for the firm and its investments through an annual ESG assessment process, utilizing best practices and independent standards, including SASB, GRI, and TCFD metrics.
  4. Ensuring transparency by reporting White Deer’s ESG goals and performance to its investors and key stakeholders.
  5. Assigning responsibility for the implementation of White Deer’s ESG Policy to leaders of the firm and executives at portfolio companies.

Approach

Investment Screening & Due Diligence

During the pre-investment process, White Deer will determine whether a target investment (i) presents substantial ESG-related risks or benefits and (ii) exhibits alignment with White Deer’s CSR Policy. The results of this diligence will be reported to the investment committee and included in the investment committee memoranda.

Governing CSR Policy Implementation

During the first year of WD’s majority ownership in a new investment (or longer as appropriate for each company), WD will partner with company management to create a CSR program and establish annual goals and objectives for identifying and acting on ESG-related risks and opportunities.

CSR and ESG Reporting Integration

We are committed to using industry standards and voluntary frameworks, such as the Principles for Responsible Investment (PRI), Global Reporting Initiative (GRI), or the Sustainability Accounting Standards Board (SASB), to provide precise, comparable, and accurate information to stakeholders. 

Utilizing the Value Reporting Foundation’s Sustainability Accounting Standards Board (SASB) Standards, the Global Reporting Initiative’s (GRI) Disclosures, and the Task Force on Climate-related Financial Disclosures (TCFD) as reputable frameworks, White Deer and portfolio company management teams will identify material ESG KPIs and annually assess and report portfolio company performance against those KPIs. These KPIs will include Scope 1, Scope 2, and Scope 3 GHG emissions as well as reporting of TCFD’s Annex D metrics, which seek to normalize GHG emissions to financial performance.  White Deer not only views GHG emissions measurement, both absolute and intensity-based, as a mechanism by which we can facilitate the decarbonization of our investments, but also as a tool to highlight ESG-related risks and opportunities to each company’s business model — particularly Scope 3 (value chain) emissions.

This ongoing monitoring and reporting process is designed to contextualize opportunities for improvement, define next steps for White Deer’s governance of ESG performance across its investments, and provide stakeholder transparency.

Governing ESG Policy Implementation

The full investment team at White Deer shares responsibility for driving the adoption of this policy at the firm and each portfolio company. As board members and partners with portfolio company management teams, implementation and adoption of ESG policies at each company will be included in annual management incentive plans and reviewed during quarterly board meetings. The CEO and CFO of each portfolio company will be held responsible for managing and implementing a CSR program for their company that meets or surpasses White Deer’s objectives as laid out in this policy.

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