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Environmental, Social and Governance (ESG) Policy

Environmental, Social and Governance (ESG) Policy

Last Updated: April, 2024

Capria Ventures takes an inclusive approach to impact and ESG. We apply global best practices of impact investment and ESG management to support entrepreneurs using digital technology to build highly scalable, profitable businesses that improve the lives of 100s of millions of middle and low-income families. We favor companies driven by local consumption, resulting in uncorrelated growth (vs. the West) and resilience to global downturns. Our ecosystem development efforts amplify the impact created by companies across the global markets in which we and our partners invest.

Three Dimensions of Impact

Our investment strategy generally envisages impact across three dimensions

Underserved Markets—Foster innovative, fast-growing tech-enabled businesses in vast, largely underserved markets of the Global South, including India, Southeast Asia, Latin America, and Africa.
Catalytic Capital—Provide access to early-stage and early-growth capital to companies that are comparatively undervalued and/or undercapitalized in forms best suited to their needs.
People and Environment—Invest in diverse companies primarily addressing local
consumption of essential products and services, resulting in greater impact per dollar
invested and greater resilience to economic downturns.

Delivering Scaled Positive Impact

Capria believes positive, sustainable change comes from delivering social and environmental returns coupled with market-rate financial returns. We will maximize positive impact through:

Investment Selection. We will screen companies and funds that invest in companies that positively impact their communities in underdeveloped and developing economies with critical needs for early-stage capital.
Portfolio Support. We will facilitate workshops and provide resources to help Capria’s portfolio integrate impact strategies into their firms.
Internal Policy & Values Alignment. We have a set of core policies and guiding principles, which are memorialized in our corporate documents, employee handbooks, and policies.

Environmental, Social and Governance (ESG) Commitments

We invest in companies directly and indirectly through investments into funds. Capria commits to:

Social and Environmental Risk Mitigation

Capria has developed and implemented an Environment and Social Management
System (ESMS) using IFC’s Performance Standards as a guiding principle to manage 1
the risks associated with companies in Capria’s portfolio. This includes conducting
our business operations according to assessments of all environmental, health, and
social legislation and risks, including efficiency in resource usage, pollution
prevention, and ensuring community health, safety, and security.
Capria will review our ESG policies, processes, and systems regularly and, based on
market changes, provide appropriate training to our team.
Capria will provide training and support to our portfolio of companies and funds to
help them develop their own ESG policies and ESMS, if necessary.
Funds and companies that receive a substantial commitment from Capria will be
required to adhere to their ESG policies and implement their ESMS in accordance
with side letters entered into between Capria and each investee. Those with lesser
commitments will have limited requirements due to having limited risk profiles,
fewer company execution capabilities, and market expectations.
For all transactions, Capria will use the “TEMPLATE: Capria Environmental and
Social Due Diligence Form” to require that portfolio companies:
Have or create a system to enforce a zero-tolerance anti-corruption policy
and appropriately address any identified corruption and/or money
laundering issues.
Are or will be compliant with all local and national laws.
Are not participating in any activities on the IFC Exclusion List and are not
Category A investments.
Where ESG issues are identified, Capria will work with investees to develop
and implement an Environmental / Social Action Plan (ESAP).

Inclusion of Impact Strategy

Capria will require portfolio funds to develop and implement an impact strategy
integrated with their investment strategy, with buy-in and commitment from all
partners and constituents.
Capria will include impact goals and expectations in formal documents with
portfolio funds.
Capria will support fund managers to enable their portfolio companies to adopt an
impact strategy and grow their impact.

Impact and ESG Intent

Capria will allocate capital to entrepreneurs creating businesses that positively
impact the environment or populations lacking access to resources, essential
products or services, finance, or opportunities for improvement. This includes
low—and middle-income populations, minorities, women, etc.
Capria will not invest in and support any activities on IFC’s Exclusion List (see
Appendix I). Capria will also require portfolio funds not to invest in IFC’s Exclusion
List.

Compliance and Reporting

Capria will require portfolio companies to report impact and ESG metrics at least
annually, either directly to Capria (for direct investments) or indirectly (via portfolio
funds).
Capria will provide its investors with reasonable access to all information necessary
to monitor and evaluate Capria’s portfolio’s compliance with ESG policies.
Funds and companies that receive a commitment from Capria will be provided with
our Anti-Corruption, Impact, and ESG Questionnaire, which will be self-assessed and
answered annually.
Capria will review and update, if needed, on a regular basis, the Capria ESG Policy in
compliance with IFC Performance Standards.

Governance and Anti-Discrimination

Capria will follow hiring and employment practices such as paying fair wages,
providing appropriate benefits, maintaining clean and safe working conditions, and
providing flexible hybrid work environments.
Capria will treat all team members and external partners equally without
discrimination, regardless of race, gender, ethnicity, abilities, religious or political
beliefs, age, national origin, sexual orientation, family or marital status, and culture.
(Read our DEI Policy for further explanation).

Legal and Ethical Compliance

Capria will comply with principles of applicable civil, environmental, and social laws
and will pledge not to accept or offer bribes, and will require employees to pledge to
do the same.
Capria will be transparent, ethical, and accountable in all business operations,
including adhering to the principles of good corporate governance.
Capria has a zero-tolerance anti-corruption policy. Capria will comply with the U.S.
Foreign Corrupt Practices Act (FCPA) and national and local anti-corruption laws of
any countries in which partners and their portfolio companies are doing business.
Capria will also comply with all International Labor Organization (ILO) conventions,
the UN Convention Against Corruption, and the OECD Convention (collectively
“Anti-corruption Laws”) as sanctioned by the countries where partners maintain
operations. Capria will adhere to the International Finance Corporation’s 2012
Policy on Environmental and Social Sustainability and Performance Standards.
Capria will respect the right of every person to be treated with dignity and equality.
Capria works to prevent and address any negative human rights impacts related to
the operations of its fund and portfolio companies in accordance with United
Nations Guiding Principles on Business and Human Rights.
Capria will use a risk-based approach to anti-money laundering and anti-terrorist
financing, assessing exposure to risks for each transaction and relationship and
taking the appropriate mitigation measures in accordance with the level of risk.
Capria has a system in place to ensure compliance with AML regulations in
applicable jurisdictions, including KYC, a reporting mechanism, and risk assessment
guidelines.
Capria will proactively educate its staff on anti-corruption policies and processes.
This document will be required reading during the employee and contractor
onboarding process.

This policy is approved by the Managing Partners of Capria Ventures LLC.

Appendix I

Exclusion List

Production or trade in any product or activity deemed illegal under host country laws or
regulations or international conventions and agreements or subject to international bans,
such as pharmaceuticals, pesticides/herbicides, ozone-depleting substances, PCBs, wildlife
or products regulated under the Convention on International Trade in Endangered Species
(CITES) of Wide Fauna and Flora.2
Production or trade in weapons and munitions.
Production or trade in alcoholic beverages (excluding beer and wine).
Production or trade in tobacco.
Gambling, casinos, and equivalent enterprises.
Production or trade in radioactive materials. This does not apply to the purchase of medical
equipment, quality control (measurement) equipment and any equipment where IFC
considers the radioactive source to be trivial and/or adequately shielded.
Production or trade in unbonded asbestos fibers. This does not apply to the purchase and
use of bonded asbestos cement sheeting with less than 20% asbestos content.
Drift net fishing in the marine environment using nets in excess of 2.5 km in length.
Production or activities involving harmful or exploitative forms of forced labor /harmful 3
child labor .

Except when engaged in microfinance activities as specified below*, the following exclusions will
be applied:

Commercial logging operations for use in primary tropical moist forests.
Production or trade in wood or other forestry products other than sustainably managed
forests.

*When investing in microfinance activities, the following items will be excluded:

Production, trade, storage, or transport of significant volumes of hazardous chemicals or
commercial-scale usage of hazardous chemicals. Hazardous chemicals include gasoline,
kerosene, and other petroleum products.
Production or activities that impinge on the lands owned or claimed under adjudication by
Indigenous Peoples (as defined in Standard 7 of the Performance Standards) without the
full documented consent of such peoples.

Appendix II

Organizational Capacity & Competency

Internal Roles and Responsibilities

This section provides an overview of the roles and responsibilities within Capria Ventures LLC,
ensuring transparency and clarity in our organizational structure.

Team Member	Role	Responsibilities
Will Poole	Managing Partner & Co-Founder	Assigned E&S Officer; Senior Management & Human Resources
Mobola da-Silva	Impact & ESG Lead Partner	E&S Strategy and
Bryan Njuguna	Impact & ESG Officer	Pipeline/Portfolio Management