Guidelines For Responsible Investment

Environmental, Social and Governance (ESG) Considerations

Elarolah Capital and its business units utilize a strategic, fact-based and diligence-driven investment approach that by definition includes a multitude of environmental, social and governance (ESG) considerations.

Elarolah Capital believes that these ESG practices lead to better investment outcomes while considering the firm’s broader impacts on the environment and society. The firm takes its responsibility seriously and continually monitors the broad consequences of every investment to ensure we are taking all of our stakeholders’ needs into account. By living these values, we create lasting impact for our investors, teams, businesses and communities where we live and work.

ESG Considerations

Elarolah Capital takes the following considerations into account when making investments:

  • Consider environmental, public health, safety, and social issues associated with target companies when evaluating whether to invest in a particular entity, as well as during the period of ownership.
  • Be accessible to relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.
  • Respect the human rights of those affected by our investment activities and seek to confirm that our investments do not flow to companies that utilize child labor or forced labor or maintain discriminatory policies.
  • Provide information to limited partners on the matters addressed herein, and work to foster transparency about our activities.
  • Encourage our portfolio companies to advance these same principles in a way which is consistent with fiduciary duties.
  • Maintain strict policies that prohibit bribery and other improper payments to public officials consistent with the International Corrupt Practices Act applicable to the laws of every countries, and the OECD Anti-Bribery Convention.

When making control investments, Elarolah Capital undertakes the following additional activities:

  • Seek to grow and improve the companies in which we invest through long-term sustainability initiatives, while also considering stakeholders on environmental, social and governance issues. We work through appropriate governance structures (e.g. board of directors) within portfolio companies with respect to environmental, public health, safety and social issues, with the goal of improving performance and minimizing adverse impacts in these areas.
  • Seek to use governance structures that provide appropriate level of oversight in the areas of audit, risk management and potential conflicts of interest and to implement compensation and other polices that align the interests of our funds and management.
  • Remain committed to compliance with applicable national, state and local laws in countries in which we invest; support the payment of competitive wages and benefits to employees, provide a safe and healthy workplace in the conformance with national and local law; and, consistent with applicable law, respect the rights of employees to decide whether or not to join a union and engage in collective bargaining.

While the consideration of ESG factors has traditionally fallen under the purview of active equity investors with a greater ability to influence outcomes, we believe that credit and other minority investors also have an obligation to take into account ESG factors. In evaluating minority investments, teams:

  • Examine the impact a company has on society and the environment during the diligence process. Where applicable, take into consideration not only the specific products or services a company provides, but also the manner in which it does business and conducts itself in the broader world.
  • Seek to comprehend and consider ESG factors from a company-specific and sector-wide perspective.
  • Encourage companies, where appropriate, to adopt responsible practices and promote transparency.
  • Treat the responsibility of acting as a shareholder seriously and continue to diligence holdings throughout the course of ownership.
  • Engage companies via proxy voting, corporate actions and board seats, where applicable.
  • In certain funds, utilize a negative screen to avoid investing in companies having more than 10% of their revenue in gaming, munitions, alcohol, tobacco and adult entertainment.


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