Introduction

Gavekal Capital Limited believes that high standards of environmental, social and governance (ESG) considerations lead to smarter and more responsible investing. We strive to deliver superior long-term returns by integrating financial and ESG elements into our portfolio construction and investment processes. Gavekal Capital Limited commits to considering material ESG issues in the course of its investment decision process and in the monitoring of investments to the extent reasonably practicable under the circumstances, subject to, in any event, the provisions of the Private Placement Memorandums and other offering documents of the funds under management, and the best interests of those funds.

In implementing this sustainability policy (Sustainability Policy) Gavekal Capital Limited seeks to:

  1. Consider environmental, public health, safety, and social issues associated with target companies (a) when evaluating whether to invest in a particular company or entity, and (b) during the period of ownership.

  2. Grow and improve the companies in which Gavekal Capital Limited’ funds under management invest for long-term sustainability and to benefit multiple stakeholders, including on environmental, social, and governance issues. To that end, Gavekal Capital Limited will (when we deem it to be appropriate to do so) seek to suggest, recommend or implement appropriate governance structures (such as board of directors) with portfolio companies with respect to environmental, public health, safety, and social issues, with the goal of improving those companies’ performance and minimizing those companies’ adverse impacts in these areas.

  3. Monitor energy and carbon impacts of the investments of our funds under management, as well as other environmental risks such as water pollution and waste impacts of these businesses.

  4. Remain committed to compliance with applicable national labour laws in the countries in which Gavekal Capital Limited invests on behalf of our clients.

  5. Encourage Gavekal investee companies to provide benefits, as well as a safe and healthy workplace in conformance with national and local laws to employees.

  6. Use governance structures that provide appropriate levels of oversight in the areas of audit, risk management, and potential conflicts of interest, and to implement compensation and other policies that align the interests of owners and management.

  7. Respect the human rights of those affected by Gavekal Capital Limited’s investment activities and seek to confirm that Gavekal Capital Limited does not invest on its own behalf or on behalf of its clients in companies that utilize child or forced labour or maintain discriminatory policies.

  8. Encourage strict policies that prohibit bribery and other improper payments to public officials consistent with the U.S. Foreign Corrupt Practices Act, similar laws in other countries, and the OECD Anti-Bribery Convention.

  9. Be accessible to, and engage with, relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.

  10. Our Sustainability Policy is regularly reviewed and amended where applicable on an annual basis.

Please download our sustainability policy.