Lighthouse is committed to responsible investing, which means it integrates Environmental and Social (E&S) factors into investment decision-making and portfolio management processes and also engages in active stewardship. The brand believes that E&S factors are material to the long-term performance and sustainability of its portfolio companies. By addressing these factors, Lighthouse creates value for its investors, its portfolio companies, and society at large.

Lighthouse follows a stringent process to monitor and measure the E&S impact of its potential portfolio companies before making an investment decision.

Lighthouse’s comprehensive E&S Policy confirms its compliance with all E&S legislative requirements and ensures continual improvement by adopting responsible E&S management processes. It has also undertaken preventative measures to control, minimise or eliminate related risks and impacts across all its operations and portfolio investments.

Lighthouses’ approach towards responsible investing is guided by the following principles:

• It invests in businesses that have a positive impact on the society and the environment, or have the potential to improve their impact through its engagement.
• It avoids investing in businesses that are involved in any of the activities listed in the Exclusion List, which are deemed to be harmful or unethical.
• It complies with all applicable local, national, and global environmental and social laws and regulations, as well as the E&S Reference Standards that it has adopted.
• It screens each prospective investment to assess its compliance with the E&S Reference Standards and identify any gaps or risks that need to be addressed.
• It monitors and reports on the E&S performance of its portfolio companies on a regular basis, using relevant indicators and metrics.
• It engages with its portfolio companies, investors and stakeholders to share best practices, learn from each other, and promote responsible investing in India.

To learn more about our Responsible Investment Policy and how we incorporate ESG aspects into our investment decisions, click here.

Indian Laws and Regulations

Lighthouse complies with all applicable laws and regulations related to E&S aspects within the jurisdictions of India for investment purposes, and expect its portfolio companies also to comply with all the applicable national and local laws of the country.

Other Key E&S Reference Standards

Lighthouse also recognises that applying other key E&S reference standards, including the global standards, may better align with the E&S aspects in the overall investment cycle. It is committed to implementing these standards in its investment process through various procedures developed as a part of the ESMS. The E&S reference standards that it follows include:

• National Investment and Infrastructure Fund Limited (NIIFL) E&S Management Policy ¹
• International Finance Corporation (IFC) Performance Standards (2012) ²
• The World Bank Group General EHS Guidelines (2007) ³
• Asian Development Bank (ADB) Safeguard Policy Statement (2009) ⁴
• ADB Social Protection Strategy (2001) ⁵
• ADB Gender and Development Policy (1998) ⁶
• Asian Infrastructure Investment Bank (AIIB) Environment and Social Framework (2016) ⁷
  - Environmental & Social Policy (ESP)
  - Environmental & Social Standards (ESS)
  - Environmental & Social Exclusion List (ESEL)
• AIIB Project-Affected People’s Mechanism (PPM)
• AIIB Sustainable Energy for Asia Strategy (SEAS) and other relevant sectoral strategies
• New Development Bank (NDB) E&S Framework & Standards (2016) ⁸
• United Nation’s Principles of Responsible Investment (UNPRI) ⁹
• DEG Guideline for E&S Sustainability
• International Labour Organization (ILO) Conventions

• For more information, refer to the following link: https://www.niifindia.in/uploads/about/NIIFL_ES-Policy.pdf
• For more information, refer to the following link: https://www.ifc.org/wps/wcm/connect/c02c2e86-e6cd-4b55-95a2- b3395d204279/IFC_Performance_Standards.pdf?MOD=AJPERES&CVID=kTjHBzk
• For more information, refer to the following link: https://www.ifc.org/wps/wcm/connect/29f5137d-6e17-4660-b1f9-02bf561935e5/Final%2B- %2BGeneral%2BEHS%2BGuidelines.pdf?MOD=AJPERES&CVID=jOWim3p
• For more information, refer to the following link: https://www.adb.org/sites/default/files/institutional-document/32056/safeguard-policy-statement-june2009.pdf
• For more information, refer to the following link: https://www.adb.org/sites/default/files/institutional-document/32100/social-protection.pdf
• For more information, refer to the following link: https://www.adb.org/sites/default/files/institutional-document/32035/gender-policy.pdf
• For more information, refer to the following link: https://www.aiib.org/en/policies-strategies/_download/environment-framework/20160226043633542.pdf
• For more information, refer to the following link: https://www.ndb.int/wp-content/uploads/2017/02/ndb-environment-social-framework-20160330.pdf
• For more information, refer to the following link: https://www.unpri.org/pri/what-are-the-principles-for-responsible-investment

Lighthouse has a set of policies that reflect its commitment to responsible investing and ethical conduct. These policies include:

Staff Trading & Personal Dealing Policy

Lighthouse ensures that personal investment activities are always conducted with the Fund’s reputation in mind, and are in compliance with all applicable laws and regulations. It (the Fund) generally discourages personal securities transactions where preclearance is required. However, it permits limited personal trading where preclearance is required. The policies to be adhered to while trading in Employee Related Accounts are delineated in this policy.

This policy regulates the personal trading activities of its staff, and ensures that they do not engage in any transactions that may conflict with the interests of the Fund or its investors.

Anti-bribery and Anti-corruption Policy and Procedures

Lighthouse is committed to upholding its highest ethical standards and operates on a zero-tolerance policy with respect to bribery and corruption. Its policy includes Lighthouse partners, employees, members, owners, principals, directors, and officers and, where applicable, consultants and also includes portfolio companies of funds managed/advised by Lighthouse and “Portfolio Company Covered Persons.

Anti-Money Laundering Policy

Lighthouse ensures that proper policy frameworks are put in place as per the guidelines on Anti Money Laundering standards notified by SEBI. This policy also extends to all investment advisory/management entities of Lighthouse. Portfolio Companies (as defined below) shall also adhere to the provisions of this policy, unless an anti-money laundering policy of suitable standards has been adopted by them internally.

Procurement Policy

Lighthouse understands that a robust procurement policy can help to ensure a consistent, efficient, and best practice approach to procurement, as well as to support purchasing processes and sourcing strategies.

With that objective, Lighthouse’s procurement policy creates a framework:

• of governance for procurement and a structure that enables the use of appropriate process steps and tools to enable the right selection of vendors and solutions; and
• to provide a competitive advantage to the business by reducing costs and developing excellence in purchasing and sourcing processes.

Lighthouse understands the importance of its stakeholders and are actively on the lookout to address any concerns/complaints raised by the stakeholders in a timely and effective manner. It has developed a comprehensive Grievance Redressal Mechanism (GRM) to allow external and internal stakeholders to submit their concerns, grievances and feedback without retribution and with the assurance of a timely response. GRM provides a procedure for the stakeholders to submit queries or concerns related to the Fund’s environmental and social performance and investments.

A person, community or other external stakeholder, such as a civil society organis ation, can submit their questions or concerns to the E&S Officer either by sending an e-mail or a mail to the following address:

Mailing address: Lighthouse AMC, 102/B Hallmark Business Plaza, Guru Nanak Hospital Road, Bandra East, Mumbai – 400051.

E-mail: info@lhfunds.com

The E&S Officer will provide a confirmation of receipt to the sender within 48 hours of receiving the written question or concern and inform them that they will receive a response in writing within 15 business days.