ESG POLICY

Spire Capital believes that in order to provide significant risk adjusted returns to our investors, we need to be committed to the highest standards of business practices and ethical standards. We believe that introducing environmental, social and corporate governance (“ESG”) considerations to our investment process can be essential to creating value for our investors and to developing more sustainable long-term success at our portfolio companies. A wide range of ESG issues are addressed as part of the investment decision-making process, and these issues are managed post-investment. By incorporating ESG considerations into investment analysis and ownership practices, Spire Capital can create additional value for all stakeholders and reduce the financial and reputational risks to which they are exposed.