Responsible Growth Policy

Scope
Our Responsible Growth Policy was first implemented with the commencement of GHEP VI, a 2017 vintage fund. This Policy applies to all investments considered by our Investment Committee, in accordance with applicable law and regulations, beginning with GHEP VI. While the Responsible Growth Policy outlines our general approach to Responsible Growth across our firm and portfolio, there may be circumstances where we only apply elements of the Responsible Growth Policy that we determine to be commercially reasonable and practical.

Responsible Growth Integration Guidelines

Due Diligence
We designed our diligence process to provide a comprehensive understanding of a company’s opportunities and risks. As such, we integrate Responsible Growth considerations into our due diligence process for investments. Our objective is to make financial decisions on a full set of risk-reward factors, and we view Responsible Growth considerations as important inputs to our investment process.

Our diligence review is customized for each target company, taking into account company size, industry sector, and geography to identify relevant topics such as climate change, environmental footprint, employee health & safety, human rights, non-discrimination and inclusion, data privacy and security, and intellectual property protection and competitive behavior. For each company, we identify a subset of relevant Responsible Growth topics. We aim to incorporate a Responsible Growth analysis in the Investment Memorandum for every deal and discuss any Responsible Growth topics identified as potentially material in our Investment Committee discussions.

Monitoring and Reporting
We provide all portfolio companies with our Responsible Growth Policy, and request that management teams be aware of and advance these principles in their operations. We aim to monitor portfolio company Responsible Growth-related performance and include a Responsible Growth section in the Quarterly Reporting documentation.

Governance
The Responsible Growth Committee consists of Executive Committee Members & Managing Directors Christopher Gaffney and Christopher Busby, Managing Director & Head of Investor Relations Mary Kate Bertke, Investor Relations Vice President of Project Management Emily DeGrado, Compliance Manager Christina Hong, and Responsible Growth Manager Paige Shetty. The Responsible Growth Committee is responsible for program oversight and annual review. The Executive Committee, consisting of Managing Directors Christopher Busby, Nick Cayer, Rafael Cofiño, Christopher Gaffney, Drew Loucks, Mark Taber, and Matthew Vettel, maintains ultimate responsibility for determining how to manage significant Responsible Growth issues and opportunities at the Firm and investment level, including changes to our Responsible Growth Policy. The investment team aims to participate in Responsible Growth training annually.

Conclusion
We are focused on staying informed on Responsible Growth developments and best practices. We aim to evaluate our Responsible Growth Policy annually and consider changes or additions as appropriate to help ensure the way we integrate Responsible Growth into our investment process helps us earn attractive returns. We believe that by investing in companies and management teams with integrity and that are accountable for their impacts on society and the environment, we will achieve attractive results for our investors.

Disclaimer
This Responsible Growth Policy sets forth Great Hill Partners’ goals and aspiration as it relates to Responsible Growth factors. There can be no assurance that we will ultimately be successful in implementing this Policy or that any investments or operations will have a positive or desired Responsible Growth-related impact. Applying Responsible Growth factors to investment decisions involves qualitative and subjective decisions and there is no guarantee the criteria used by Great Hill Partners to formulate decisions regarding Responsible Growth, or that our judgement regarding the same, will be reflected in the beliefs or values of any particular client or investor. There are significant differences in the interpretation of what constitutes positive Responsible Growth impact, and those interpretations are rapidly changing. The description of Responsible Growth integration contained in this Policy is provided to illustrate Great Hill Partners’ intended approach to investing and firm operations. Subject to applicable legal requirements, Great Hill Partners reserves the right to update, modify, or rescind this policy at its discretion.