Incorporating policies

The Firm has taken various steps to seek to prevent modern slavery, human trafficking and human rights abuses in our organization or supply chains, and we have integrated considerations on modern slavery, human trafficking and human rights risks within the evaluation and management of investments on behalf of ourselves and our clients, the engagement of third parties providing services to the Firm, and the operations of firms servicing the funds and entities managed or advised by the Firm.

Our Code of Business Conduct and Ethics describes the standards of behavior expected of our employees, including the maintenance of high ethical standards, which are contrary to modern slavery practices.

Our Reporting Violations, Misconduct, and Legal or Ethical Concerns Policy details the manner in which employees can confidentially raise any issues, including in relation to modern slavery and human trafficking, which the Firm will investigate and deal with appropriately. We have provided both internal and external contacts for employees to use should they need to raise concerns.

The Firm is dedicated to promoting an atmosphere of a diverse meritocracy and equal opportunity, and our Employee Handbook details our prohibition of discrimination and harassment against individuals based on their actual or perceived race, religious creed, color, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status (including registered domestic partnership status), sex (including gender identity and expression), age, sexual orientation, military and veteran status, or any other characteristic protected by law. This contributes to a culture of respect which can help reduce the risk of slavery and other adverse human rights impacts occurring.

Conducting due diligence and monitoring of suppliers

As part of our initiative to identify and manage risk, we seek to: (a) identify, assess, and monitor potential higher risk areas in our supply chains; (b) mitigate the risk of slavery and human trafficking occurring in our supply chains through enhanced contract term controls (to the extent appropriate and obtainable); (c) train our employees as to these risks and the need to manage them; and (d) protect whistleblowers.

The Firm performs due diligence on suppliers to assess their compliance with modern slavery laws. We include standard questions in supplier questionnaires, and seek representations in contracts, relating to slavery, human trafficking and other human rights-related concerns from prospective suppliers.

Embedding sustainability considerations into investment decisions

The Firm maintains a Sustainable Investing and Impact Policy, which provides a framework for how we apply sustainability and impact considerations regarding our business, how we engage with our communities, and how we pursue, evaluate, and implement investments.

GCM Grosvenor views sustainability considerations as a core value, which we embrace at every level of the organization. This philosophy drives us to invest responsibly, operate our business with integrity, and build a diverse meritocracy workplace where our employees can thrive and volunteer, providing resources for organizations that strengthen the communities where we live and work. As we view sustainability and impact as core components of the investment process, we have embedded sustainability and impact analysis into our existing investment process. Part of our investment team’s responsibilities is to perform analysis and monitor for sustainability and impact factors as part of their day-to-day investment responsibilities.

Given that sustainability and impact are a firm priority, the Office of the Chairman and the firm’s most senior leaders have ultimate governance over firmwide sustainability matters and are responsible for establishing key strategic initiatives for the Sustainability Committee and GCM Grosvenor’s Sustainability team. The Sustainability Committee in turn has responsibility for translating the firmwide sustainable initiatives into a formal Policy, which is reviewed and, if necessary, updated annually and serves as a guide for activities and integration across the various business lines. The Sustainability Committee includes our Managing Director of Sustainability, select members of the Office of the Chairman, our Chief Investment Officer and Chief Risk Officer, and senior investment professionals representing each asset class.

The Firm’s commitment is also reflected in its status as a signatory to the Principles for Responsible Investment (PRI), which provides a framework for appropriately considering sustainability issues and human rights in our investment process. GCM Grosvenor and its affiliates have been signatories to the PRI since 2012. This promotes upfront awareness of, and internal discussions on, potential issues from the initial investment screening stage. We request that investment managers and management teams provide updated responsible investing-related information in our annual sustainability questionnaire, and we monitor sustainability and impact compliance regularly. We seek the PRI’s assurance of our policies and practices via its annual transparency report. In the PRI’s most recent assessment, we received four out of five stars for the Indirect – Private Equity category and three out of five stars for Indirect – Hedge Funds and Investment & Stewardship policy.

We also share knowledge among industry colleagues and employees. We seek to educate clients on responsible investing and discuss with investment managers and industry peers how to become PRI signatories. We have also spoken at, and participated in, conferences to promote responsible investing.

We continue to broaden and enhance our efforts in sustainable and impact investing in a number of ways. For example, to improve transparency and reporting from managers, we are expanding the means by which we assess and track how managers fit into our sustainability framework across our investment strategies. We are active participants in PRI initiatives and seek to drive accountability among those with whom we invest, partnering with responsible investment organizations, hosting small and diverse manager conferences, and supporting the missions of diverse professionals’ organizations.

Conducting due diligence in the investment process

The Firm includes specific questions regarding modern slavery, human trafficking and adverse human rights impacts in its due diligence questionnaires with respect to most potential

investments being evaluated, and each internal investment memorandum must contain a section dedicated to addressing the investment’s level of sustainability integration. Post-investment, the Firm implements ongoing monitoring and seeks to be engaged on sustainability matters where it has a board seat or limited partner advisory committee membership. We also seek engagement with investment managers to advocate for and support their sustainability process improvements.