Updated February 2023

At Norwest, we aim to incorporate fundamental environmental, social and governance (ESG) and diversity, equity and inclusion (DEI) considerations into our investment decision-making and portfolio services. ESG is a framework for considering relevant focus areas that contribute to financial performance and sustainable growth. DEI is one of the highly relevant focus areas we identified to focus on internally and with our portfolio companies. We believe optimizing ESG and DEI performance can drive value creation, while ignoring such performance exposes a company to material risks. This has been reflected in how we do business for decades.

We take pride in helping our companies enhance their value and long-term sustainability. We recognize the value of ESG and DEI considerations in our internal operations as a firm and aim to hold ourselves to the same standard as our portfolio companies.

How We Define ESG and DEI

Norwest follows a definition of ESG that is consistent with the UN Global Compact principles. We aim to incorporate ESG and DEI considerations in our approach to responsible investing.

• Environment: Performance related to environmental risks and impacts
• Social: Impacts on and relationship with stakeholders
• Governance: Performance related to fair, accountable, and transparent corporate practices

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Our commitment to the concepts of diversity, inclusion and equity are consistent, though the acronyms may change over time.

• Diversity: Presence of a variety of perspectives, backgrounds and experiences within the organization
• Equity: Access to opportunities; acknowledging that barriers exist for some in our society
• Inclusion: Leveraging the talents and skills of every employee

Integrating Responsible Investing at Norwest

We seek to take a responsible approach to investment. We aim to recognize the potential impact of portfolio companies on the environment, workers, communities and society, as well as the potential impacts of ESG issues on the companies the firm invests in.

Building on Norwest’s values and firm culture, and representing a formalization of our long-running commitment to responsible investing, we are currently focusing on three areas related to responsible investing.

1: Risk Screening & Due Diligence

We aim to screen companies and exclude from investment any company that we are reasonably able to determine to be in direct and knowing violation of UN Global Compact principles, and inquire about ESG risks and opportunities during the due diligence process. Our risk screening and due diligence process will enable us to flag risks, make better investment decisions, and indicate what forms of ESG portfolio services may be most valuable to the investee over time. We will also inquire during the due diligence process whether the target is willing to engage on ESG topics.

2: Investment

We hope companies we invest in will share our commitment to the UN Global Compact principles integration. We will seek to include a clause in term sheets that expresses our mutual intent to improve the company’s ESG performance over time.

3: Portfolio Management

A central focus of our approach includes engaging with and educating our portfolio companies on ESG and DEI topics, and relevant risks and opportunities. Once invested in, we will aim to support our companies in developing best practices related to ESG and DEI performance.

• We will work closely with those portfolio companies that are willing to educate about best practices
• Companies that are unwilling or unable to educate will still receive encouragement to see the value in ESG performance management, and resources to mitigate ESG risks that Norwest identifies in due diligence.

Our Focus on DEI

At Norwest, an intentional commitment to diversity, equity, and inclusion is foundational to our team’s work. This belief is core to how we have operated for decades. Some of our DEI initiatives include:

• DEI focused educational fireside chats with industry leaders
• Resources & frameworks entrepreneurs can leverage for their organizations
• Investing in entrepreneurs from underrepresented groups
• Investing in underrepresented funds
• Events focused on building a diverse board pipeline for our portfolio companies

Scope of Policy

Norwest and its affiliated investment funds will make reasonable efforts to encourage all portfolio companies to consider relevant ESG and DEI-related principles. In certain investments, factors such as our ownership stake or influence may affect our ability to assess, set or monitor ESG and DEI-related performance goals.

We and our affiliated investment funds will also apply the policy to our internal operations, based on the belief that effective ESG and DEI management begins with diverse and inclusive governance and team environments.

Policy Implementation Governance

Norwest has developed an “ESG & DEI Steering Committee” composed of internal team members representing key functions at the firm, and external advisors.

The Steering Committee is responsible for the following:

1. Facilitating the implementation of this policy
2. Maintaining and updating this policy
3. Providing training to employees of the firm and interested portfolio companies to ensure continued relevance and education
4. Helping to develop ESG strategies at interested portfolio companies

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This policy has been approved by the Managing General Partners and will be reviewed and updated annually.