Investment professionals at Driehaus incorporate the consideration of material ESG factors into our investment process through quantitative and qualitative analysis, internal monitoring and reporting.

We layer quantitative ESG metrics derived from external ESG rating agencies into our research process. The type of factor and its materiality to a company will vary by industry, region, and type of investment. By analyzing the ESG scores of companies, we seek to identify risks that may not always be obvious through traditional fundamental analysis.

Qualitative fundamental analysis is also conducted on investments, including an assessment of a particular company’s ESG footprint through a review of commentary derived from external ESG rating agencies. This analysis seeks to identify material ESG risk factors and their correlation to a company’s potential future earnings and profitability. More specific examples are as follows:

• Environmental factors may include, but are not limited to, carbon emissions, water stress, toxic emissions and waste, packing material and electronic waste. Material environmental risks may result in higher energy costs, disruptions to operations, environmental accidents, increased regulatory pressures and reputational damage.
• Some examples of social factors are health and safety, data security and privacy, supply chain labor standards, labor management, human capital development, community relations and consumer protection policies. Social factors can negatively affect a company’s reputation and ability to attract talent, which ultimately affects profitability.
• Finally, governance factors, such as business ethics, accounting standards, board structure and oversight, and tax transparency play a crucial role in our risk analysis for a given company. Without strong corporate governance practices, we may lack confidence in the leadership and integrity of a company’s management team.

Consistent with our risk management process, the purpose of this analysis is to seek to identify and understand ESG-related risks to the extent practical. We may disregard ESG scores or external analysis, for instance, if we do not view the ESG commentary as material or if we disagree with the analysis. To be clear, as a single factor in our investment process, ESG considerations are not likely to be a defining factor in any investment decision.

Driehaus’ engagement efforts with companies serve as a tool to further evaluate and explore risks, including material ESG risks, however, our engagement efforts do not focus solely on ESG engagement.

While we recognize the benefits of investor activism, we do not delay in exiting investments where we are uncomfortable with the asymmetric return potential. Much of our engagement efforts are generated on a case-by-case basis and centered around the most relevant or material risks for a given company. Our ESG engagement priorities are generally set forth as follows but may change based on the investment team, the company, region, industry and country and other factors:

• Understanding management practices where disclosures are lacking
• Understanding size, nature and trend of any controversy, as well as a company’s strategy to manage such controversies
• Addressing non-compliance with the UN Global Compact
• The severity of our risk concerns

Discussions with company management allow the investment team to learn about a company’s perspectives and approaches, provide said company with feedback, and raise any issues (including ESG issues) that have been identified during the research process.

Additionally, when a client authorizes Driehaus to vote proxies on their behalf, we generally vote in accordance with a third-party proxy solicitation service’s voting guidelines, which are focused on financial returns. Please see DCM’s Proxy Voting Policy here for more information on proxy voting.

Consideration of ESG factors in the investment process is performed by the various investment teams in partnership with the risk management team. Each investment team’s consideration of ESG factors may vary. Direct oversight and accountability for ESG activities falls under the purview of the Investment Policy Committee (“IPC”). The IPC is responsible for ensuring the investment teams adhere to this policy. Driehaus’ CEO exercises ultimate accountability and authority over the firm’s investment teams and adherence to their investment processes.

Development and maintenance of this policy is the responsibility of the firm’s ESG Committee. The ESG Committee is responsible for reviewing the policy at least annually and amending it as necessary in light of regulatory and industry guidance. The ESG Committee is comprised of legal, investment, risk and marketing professionals.

Driehaus is a signatory of the Principles for Responsible Investment (“PRI”) and the Climate Disclosure Project (“CDP”).