We have a clear vision of our role: to build value for our investors by building great businesses. That’s why our ESG efforts are so important. We believe ESG contributes to value creation just like our other operating initiatives do, and we structure our ESG engagement to support the ongoing work to build stronger, more resilient, more inclusive, and more valuable companies.

This Environmental, Social, and Governance Policy (the “Policy”) of Clayton, Dubilier & Rice (“CD&R” or the “Firm”) reflects the Firm’s view that addressing environmental, social, and governance (“ESG”) considerations is an important part of investing and building better businesses.

The Firm believes that sound ESG practices help businesses deliver value, not only to investors, customers, and suppliers, but also to employees and communities. In addition, the Firm believes that furthering an effective ESG strategy is essential for building strong brands and safeguarding reputation, which in turn are vital for long-term success.

The Policy outlines CD&R’s approach to integrating ESG in our decision-making across the life cycle of our investments and commercial activities.

CD&R is committed to ensuring that ESG concerns and opportunities are identified and addressed appropriately in its business and to taking steps to manage actively the impact of its activities as a fund adviser in the countries in which it operates. The Firm also encourages its portfolio companies to assess and manage the ESG impacts of their business operations.

Investing Responsibly

CD&R seeks to pursue the following:

1. Consider ESG issues during the due diligence stage for target portfolio companies;

2. Work with management teams of portfolio companies to grow and improve their businesses, including addressing environmental, public health, safety, and social issues, with the goal of enhancing long-term sustainability and performance and minimizing adverse impacts arising from these areas;

3. Assess and monitor environmental impacts, as well as climate-related risks and opportunities, and seek to reduce or mitigate environmental impacts of our activities and those of our portfolio companies;

4. Advance diversity, equity, and inclusion in both our own teams and those of our portfolio companies, including efforts to increase diversity among portfolio company boards of directors;

5. Respect the human rights of those affected by our funds’ investment activities and seek to confirm that their investments do not flow to companies that utilize child, forced, compulsory, or coerced labor; deprive individuals of their personal freedoms; engage in human trafficking; or maintain discriminatory practices;

6. Ensure that portfolio company managers are able to maintain appropriate levels of oversight in the areas of audit, risk management, and potential conflicts of interest;

7. Remain committed to compliance with applicable national, state, and local labor laws in the countries in which our funds invest; support the payment of competitive wages and benefits to employees; provide a safe and healthy workplace in conformance with national and local laws; and, consistent with applicable laws, respect the rights of employees to decide whether to join a union and engage in collective bargaining; and

8. Maintain strict policies that prohibit bribery and other improper payments consistent with the U.S. Foreign Corrupt Practices Act, UK Bribery Act, and similar laws in other countries.

There may be certain exceptional cases in which CD&R does not pursue all of the above goals.

Engaging with Stakeholders

The Policy is informed by the American Investment Council’s Guidelines for Responsible Investing, the U.N. Global Compact, and the U.N. Principles for Responsible Investment. CD&R will seek to be a constructive member of its communities and to be transparent about how it incorporates ESG considerations into its investment decisions by:

1. Reporting periodically to limited partners regarding actions taken to address the ESG issues outlined in the Policy and foster transparency in portfolio companies regarding these matters;

2. Seeking to be accessible to, and engage with, stakeholders on key issues and challenges relating to the ESG issues addressed by the Policy; and

3. Advancing thoughtful responsible investment processes by collaborating with industry peers, standard-setting organizations, and other stakeholders.

Governance

CD&R generally commits to maintaining strong ESG governance:

1. CD&R’s Executive Committee has ultimate oversight of the ESG program, including integration of ESG into business strategy and priorities.

2. CD&R deal teams are responsible for implementing the Policy, with the support of the ESG and the Legal and Compliance teams. CD&R provides its investment staff with specific training and resources to help them fulfill the Firm’s ESG commitments.

3. The Investment Committee oversees ESG issues that are determined by CD&R in its sole discretion to be material to making a decision to invest.

4. CD&R’s ESG Initiatives Group, a team of multi-disciplinary specialists from across the Firm both in the U.S. and Europe, helps ensure internal coordination of the ESG-related initiatives embedded across the Firm’s functional activities and industry verticals. The ESG Initiatives Group, which meets at least three times annually, is chaired by an Operating Partner and includes investment partners, the Human Capital Partner, the head of external relations and public affairs, and a Principal focused on ESG matters. Members of the ESG Initiatives Group regularly report to the CEO and update the Executive Committee and the full partnership as appropriate.

5. The ESG Initiatives Group will review at least annually and, where necessary, update the Policy to reflect the Firm’s commitment to continuously improving its ESG approach, as well as emerging legal standards and requirements from stakeholders. The ESG Initiatives Group will communicate the Policy and any updates to the Policy to investment teams.