Effective Date: January 2026
Policy Owner: Board of Directors
Review Cycle: Annual
This Environmental, Social & Governance (ESG) Policy establishes Croze Ventures’ commitment to responsible investment practices and operational conduct across our offices in Basel, London and São Paulo. This policy applies to all investment activities, operational decisions and business relationships maintained by Croze Ventures on behalf of our client families.
ESG integration protects long-term value, mitigates risk and aligns investment activities with the principles that guide the families we serve. This is not ideological positioning. Croze Ventures treats ESG as rigorous risk management and fiduciary responsibility.
ESG Oversight Committee
Croze Ventures maintains an ESG Oversight Committee responsible for policy implementation, monitoring, and continuous improvement.
The Committee comprises:
Chief Investment Officer (Chair)
Representatives from Basel, London and São Paulo offices
External ESG advisor (non-voting)
Committee Responsibilities:
Quarterly review of portfolio ESG performance
Annual policy review and updates
Approval of ESG-related investment decisions above defined thresholds
Oversight of ESG training programs
Engagement with external managers on ESG practices
Incident review and remediation oversight
Climate Risk Assessment
Croze Ventures integrates climate-related financial risks into investment analysis and portfolio construction:
Assessment of physical climate risks (extreme weather, resource scarcity, transition impacts) for all material investments
Evaluation of portfolio companies’ carbon intensity, emissions reduction targets and climate adaptation strategies
Preference for investments demonstrating credible transition pathways aligned with Paris Agreement objectives
Engagement with high-emission portfolio holdings to encourage disclosure and reduction strategies
Environmental Due Diligence
All investment opportunities undergo environmental screening:
Resource efficiency and waste management practices
Regulatory compliance history and environmental litigation exposure
Water usage and pollution prevention in water-stressed regions
Biodiversity impact for investments in land-intensive sectors
Renewable energy adoption and energy efficiency initiatives
Operational Environmental Standards
Croze Ventures offices in Basel, London and São Paulo implement:
Energy-efficient office operations and renewable energy procurement where feasible
Waste reduction and recycling programs
Sustainable procurement policies for office supplies and services
Minimization of business travel through video conferencing technology
Labour Practices
Croze Ventures evaluates portfolio companies and business partners on labour standards:
Compliance with International Labour Organization (ILO) core conventions
Fair wages, working conditions, and employee safety protocols
Freedom of association and collective bargaining rights
Prohibition of child labour, forced labour and human trafficking (see Modern Slavery Statement)
Diversity, equity, and inclusion initiatives
Human Rights
Investment decisions incorporate human rights considerations:
Assessment of operations in jurisdictions with elevated human rights risks
Supply chain transparency and ethical sourcing practices
Community impact and indigenous rights for extractive industries
Data privacy and consumer protection for technology investments
Stakeholder Engagement
Portfolio companies should demonstrate:
Responsible customer relations and product safety
Community engagement and local economic contribution
Transparent stakeholder communication
Corporate Governance Standards
Croze Ventures expects portfolio companies and fund managers to maintain robust governance:
Independent board composition with appropriate skills and diversity
Separation of CEO and Chairman roles where appropriate
Executive compensation aligned with long-term performance
Transparent financial reporting and audit quality
Shareholder rights protection and anti-dilution provisions
Clear succession planning for key leadership positions
Ethics and Compliance
Investment holdings should demonstrate:
Anti-corruption and anti-bribery policies and controls
Whistleblower protection mechanisms
Regulatory compliance programs
Tax transparency and responsible tax practices
Political contribution disclosure
Due Diligence Process
ESG factors integrate into investment analysis at every stage:
Initial Screening: All investment opportunities undergo preliminary ESG assessment to identify material risks
Deep Due Diligence: Material investments receive detailed ESG evaluation including third-party research, management interviews, and site visits where appropriate
Investment Committee Review: ESG findings form part of investment committee decision-making
Ongoing Monitoring: Portfolio holdings face continuous ESG monitoring with quarterly reviews
Manager Selection
External fund managers undergo ESG evaluation:
Review of ESG policies, integration practices, and resources
Assessment of proxy voting records and shareholder engagement activities
Evaluation of ESG-related controversies and incident response
Preference for managers with demonstrated ESG expertise and commitment
Exclusions
Croze Ventures maintains exclusionary screens for activities inconsistent with our families’ values and risk tolerances:
Companies deriving significant revenue from tobacco production
Manufacturers of controversial weapons (cluster munitions, anti-personnel mines, biological/chemical weapons)
Companies with egregious human rights violations or environmental disasters without adequate remediation
Entities subject to international sanctions
Additional exclusions may apply based on individual family preferences.
Proxy Voting
Croze Ventures exercises proxy voting rights in the interests of our families:
Active participation in shareholder votes on director elections, executive compensation, and major corporate actions
Independent vote decisions based on company-specific analysis, not generic proxy advisor recommendations
Support for shareholder resolutions that enhance long-term value and ESG practices
Annual disclosure of significant proxy votes to families
Active Engagement
When appropriate, Croze Ventures engages with portfolio companies:
Direct dialogue with management on material ESG issues
Collaborative engagement with other institutional investors
Escalation strategies including voting against directors when engagement fails
Support for board representation in significant private investments
Performance Monitoring
Croze Ventures tracks ESG performance through:
Portfolio-level ESG scoring using third-party data providers
Sector-specific KPIs (carbon intensity, board diversity, safety incidents)
Controversy monitoring and incident tracking
Manager ESG performance assessments
Family Reporting
ESG reporting to families includes:
Annual ESG portfolio review with key metrics and trends
Quarterly updates on significant ESG incidents or controversies
Proxy voting summaries
Progress against ESG objectives and initiatives
Continuous Improvement
Croze Ventures commits to ongoing enhancement:
Annual policy review incorporating regulatory developments and best practices
Staff training on ESG integration and analysis
Investment in ESG research tools and data
Participation in industry forums and knowledge-sharing initiatives
Croze Ventures applies ESG principles to our own operations:
Vendor Management:
ESG screening of material service providers
Preference for vendors with strong ESG practices
Contract terms requiring ESG compliance
Employment Practices:
Fair compensation and professional development opportunities
Workplace diversity and inclusion initiatives
Employee wellbeing programs
Business Ethics:
Strict anti-corruption and conflicts of interest policies
Transparent fee structures
Confidentiality and data protection protocols
Accountability:
Board of Directors: Ultimate policy oversight
ESG Oversight Committee: Implementation and monitoring
Investment team: Day-to-day integration
Review and Amendment:
Annual policy review by ESG Oversight Committee
Updates to reflect regulatory changes, best practices, and family preferences
Material amendments require Board approval
Training:
Annual ESG training for all investment professionals
Ongoing education on emerging ESG issues and methodologies
Policy Approval:
This ESG Policy has been approved by the Board of Directors of Croze Ventures.
Date: January 2026