This Environmental, Social, and Governance Policy (this “Policy”) of Clayton, Dubilier & Rice (“CD&R” or the “Firm”) reflects the Firm’s recognition that there can be a strong, positive correlation between financial performance and corporate responsibility related to environmental, social, and governance (“ESG”) issues. 

This 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. 

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

CD&R is committed to ensuring that ESG issues are identified and dealt with appropriately in its business and to taking active steps to manage the impact of its activities as a fund adviser in all the countries in which it is active. The Firm also encourages its portfolio companies to take responsibility for the environmental and social impact of their business operations. In particular, CD&R shall: 

1. Consider social, ethical, and environmental issues affecting our portfolio companies, both (a) during the due diligence stage for target portfolio companies and (b) as part of our ongoing collaboration with management of existing portfolio companies; 
2. Seek to be accessible to, and engage with, a range of stakeholders on key issues and challenges relating to the social, environmental, and ethical issues addressed by this Policy; 
3. 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 improving long-term sustainability and performance and minimizing adverse impacts arising from these areas; 
4. Seek to 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; 
5. 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 or not to join a union and engage in collective bargaining;
6. Maintain strict policies that prohibit bribery and other improper payments consistent with the U.S. Foreign Corrupt Practices Act, similar laws in other countries, and the OECD Anti-Bribery Convention;
7. 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;
8. Provide timely information to limited partners and other stakeholders regarding actions taken to address environmental, social, and ethical issues outlined in this Policy and foster transparency in portfolio companies regarding these matters; and 
9. Encourage portfolio companies to advance the principles outlined in this Policy. 

CD&R believes that the principles outlined in this Policy not only serve to align our portfolio companies with the broader objectives of society, but also help build better businesses and thus support the firm’s primary objective of generating superior investment returns.