Foresight : Sustainability Policy 2023

Confidentiality Classification Status: Public 01/09/2023

POLICY	3
INTRODUCTION	3
SCOPE AND APPLICATION	3
DEFINITION	3
INDUSTRY ASSOCIATIONS AND MEMBERSHIPS	3
SUSTAINABLE INVESTMENT ACTIVITIES	4

APPROACH	5
INTRODUCTION	5
GOVERNANCE	5
FORESIGHT'S COMMITMENTS AND INITIATIVES	6
INVESTMENT PROCESS	10
ACTIVE MANAGEMENT AND STEWARDSHIP	11
INVESTMENT EXCLUSIONS	12
INDIVIDUAL ACCOUNTABILITY	12
COMPETENCY	13
GOVERNANCE POLICIES	13
POLITICAL INFLUENCE	13
MANAGING CONFLICTS OF INTEREST RELATED TO RESPONSIBLE INVESTMENT	13
DIVERSITY, EQUITY AND INCLUSION ("DE&I")	13
ANNEX A - SUSTAINABILITY COMMITTEE: PURPOSE	14

For the purposes of this document, references to "Foresight", "Group" and "Foresight Group" shall mean Foresight Group LLP together with any entity in which Foresight Group Holdings Limited directly or indirectly owns at least a 50% controlling interest/shareholding.

Reviewed by:	Sustainability Policy
Date reviewed by Governance:	19 September 2023
Date approved by Executive Committee:	19 September 2023
Date of termination:	N/A
Effective Date: September 2023 | Confidentiality Status: Public	2

Policy

INTRODUCTION

To support Foresight'1s commitment to Sustainability reporting, it has adopted this policy to apply to its corporate and investment activities across its business operations globally to the benefit of its stakeholders.

SCOPE AND APPLICATION

This policy applies to Foresight's business areas and staff globally.

In that regard, to ensure that the policy is embedded within all parts of the business, all Foresight staff must confirm that they have read its contents. Best practice training sessions on Sustainability related issues shall be provided for all staff so that they can give consistent consideration to these issues throughout the investment cycle and in their day-to-day activities.

DEFINITION

Foresight has adopted the following definition of sustainable development:

"Sustainable development meets the needs of the present, without compromising the ability of future generations to meet their own needs."

This is a concept that must be practically applied by staff through the making of viable and supportable decisions that will offer continued, long-term social and environmental benefits.

Foresight will continually integrate sustainability with the long-term in mind when executing its business plan, making investments, building trusted relationships with investors and/ or creating environments where people can flourish and contribute year-after-year.

INDUSTRY ASSOCIATIONS AND MEMBERSHIPS

Foresight will strive to adopt and implement internationally recognised standards, to become signatories and members of relevant industry organisations and to seek opportunities to promote strong ESG2 standards to those in its investments and supply chains to bring around positive change where needed.

All industry associations, memberships and applications for signatory status must be notified to both the Sustainability team, who will review the criteria to ensure it fits with the Foresight's policy and strategy, and the Governance team, who will record the association, membership, signatory status, etc.

1. References to "Foresight" or "Group" throughout this policy shall be to Foresight Group Holdings Limited and all its subsidiary undertakings.
2. "ESG" means Environment, Social and Governance" and are the key components of a sustainability framework.

Effective Date: September 2023 | Confidentiality Status: Public

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SUSTAINABLE INVESTMENT ACTIVITIES

INVESTMENT POLICY STATEMENT

As a business, Foresight carries out a varied and diverse range of investment activities, principally investing in private and listed infrastructure and real assets and UK, Ireland International SMEs. Its policy statement for investment is:

"Our purpose is to invest for a smarter future, providing institutional and private investors with access to hard-to-

reach private markets, using sustainable, ESG-orientated strategies at the core of our investment process."

Foresight's Group-wide approach to sustainability shall require all staff to encourage and enable best practice throughout its business. As the sustainability considerations for Foresight's three investment divisions of Infrastructure, Capital Management and Private Equity and their associated portfolios are likely to differ, this policy is designed to be interpreted to suit each division's investment activities and objectives as required. It also aims to ensure staff of all levels conduct their day-to-day activities in the spirit of this policy.

INVESTMENT PRINCIPLES

Under this policy, Foresight has adopted Five Sustainable Investment Principles ("Principles"):

1. Process Driven
   Foresight has confidence in the process it applies and how it is adhered to. This process underpins its investment activities, wherein each asset is taken through the same process, from initial investment stage across the entire asset lifecycle, to ensure all assets meet the required standards.
2. Awareness
   Foresight recognises itself as a component of the wider system of capital flows in a global society. Proactive engagement with both internal and external stakeholders is fundamental to its long-term success and essential for maintaining its social licence to operate.
3. Adaptability
   Foresight's progress in respect of sustainability, in addition to its growth as a leading investment management manager, is an ongoing journey that Foresight recognises is constantly evolving. It actively seeks to identify its shortcomings and embrace any opportunity to learn from others.
4. Transparency
   Sustainability is evolving rapidly. To ensure Foresight's approach to sustainable investing remains market-leading, it must be both transparent to its internal and external stakeholders and self- critical of the processes used to enable continued improvement.
5. Balance
   Foresight believes that fair and balanced dialogue is fundamental in setting and executing a successful investment strategy and in managing its wider business. Risks and opportunities are discussed in an open and constructive manner, with a focus on diversity of thought.
   Staff in all Foresight investment divisions globally are required to conduct themselves in such a way as to promote the above Principles.

Effective Date: September 2023 | Confidentiality Status: Public

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APPROACH

INTRODUCTION

Sustainability lies at the heart of Foresight's business, Group-wide. Foresight believes that acting conscientiously as a corporate entity and investing responsibly by seeking to achieve positive environmental and social outcomes are critical to the long-term success of both Foresight and the funds it manages. This document sets out how Foresight Group interprets its Sustainability Policy and defines sustainability, reflecting the United Nations Sustainable Development Goals, Principles for Responsible Investment, UN Global Compact and the Task Force on Climate Related Financial Disclosures as frameworks, around which its corporate and investment activities are structured. More information on these organisations and initiatives is set out below, under Foresight's Commitments and Initiatives.

GOVERNANCE

SUSTAINABILITY COMMITTEE

The Sustainability Committee was established by Foresight Group's Executive Committee and has the responsibility for shaping and steering the Group's approach to sustainability. An important part of the Committee's remit is to develop and review the Group's sustainability vision and strategy, as well as ensuring that the sustainability considerations and frameworks that are incorporated into Foresight's investment processes and asset management activities are appropriate and market leading. Meeting once a quarter or more frequently on an ad-hoc basis as required, the Sustainability Committee includes senior leadership from the key teams at Foresight to ensure its influence and views reach across the whole business. The Committee is required to report regularly to the Executive Committee on such matters.

Corporate Social Responsibility is also part of the Sustainability Committee's remit, pursuing initiatives to promote social and environmental responsibility in Foresight's own corporate activities, implemented through a comprehensive set of practices which are integrated into Foresight's business operations.

Sustainability issues are not limited solely to the Sustainability Committee but are also discussed by other Group and jurisdictional committees as appropriate to the nature of the authorities delegated to them. Subcommittees and working groups may also be formed and overseen by the Sustainability Committee to manage specific topics to cover, for example, investment activities, governance and diversity and inclusion.

EXECUTIVE COMMITTEE

The Executive Committee is responsible for: (i) the day-to-day management of Foresight subject to the overall leadership of the Group's Board of Directors3; (ii) Foresight's overall performance and delivery of the strategic objectives set by the Group Board; and (iii) the promotion and oversight of the Group's activities in compliance with its values and standards.

3 References to the "Group Board of Directors" or Board of Directors" are to the board of Foresight Group Holdings Limited

Effective Date: September 2023 | Confidentiality Status: Public

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