To our Limited Partners:

I am pleased to confirm that The EuroMena Funds reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to sharing this information with our Limited Partners using our primary channels of communication.

Sincerely yours,

Romen Mathieu
Managing Partner

Our policy includes the following:
- Ensure our team is provided with safe, suitable and sanitary work facilities
- Ensure gender equality and diversity within the team as well as support Women empowerment within our portfolio companies.
- Protect our team from workplace harassment, including physical, verbal, sexual or psychological harassment, abuse or threats
- Do our best efforts to implement Human rights principles within our portfolio companies

The way we implement our policies is as follows:
- Respect and implement all applicable national laws
- Make sure to have equal job opportunities and treatment of employees
- Encourage women at board and support nomination and election of women within the board of directors of our portfolio companies
- Support and encourage the creation and implementation of policies and code of conducts that include human rights principles such as: grievance mechanisms, training for employees, as well as other policies and procedures

Monitoring and performance evaluation are followed up closely through:
- Key performance indicators relating to Human rights that we collect and report on annually
- Follow up on any complaints received from staff by ensuring fair treatment at all times

Labour rights apply to us as follows:
- As our limited partners are Development Financial Institutions, we make sure to follow international health and safety standards
- We ensure that we follow national laws and abide by international standards relating to labour
- Within our Environmental and Social Management System (ESMS) guidelines, we have listed that EuroMena ensures that it has the systems and resources to understand and monitor any applicable ILO Conventions for any changes
- Ensure that the company does not participate in any form of forced or bonded labour
- Comply with minimum wage standards
- Ensure that employment-related decisions are based on relevant and objective criteria

EuroMena actively implements its standards relating to labour conditions as follows:
- Ensure a grievance mechanism is available and applied within portfolio companies
- Ensure employees are provided with suitable training on diversified topics (governance, E&S, AML, etc..), as well as provide them with a handbook containing all relevant information
- Ensure all employees are covered with a suitable health insurance plan
- Make sure that the portfolio company provides its workers with a safe and healthy work environment
- Ensure that the company establishes and implements occupational health and safety procedures in line with good international industry practices to prevent accidents, injury, and disease
- Ensure that the portfolio companies have training programs in place for workers on occupational health and safety

A yearly E&S questionnaire is sent to our portfolio companies requiring them to report on:
- Compliance with national environmental, health & safety or labour laws and regulations
- Strikes (with or without violence) or other labour disputes
- Any incident of a social nature (including without limitation any violent labour unrest or dispute with local communities), which has or is reasonably likely to have a material negative effect on the social and cultural context

Environmental protection is very valued within The EuroMena Funds, the below highlights the main commitments the fund has regarding this matter:
- EuroMena has created an Environmental & Social Management System (“ESMS”) detailing the policy, procedures and workflow pre and post investments in addition to E&S requirements to be applied by our portfolio companies
- The Fund ensures that all investments are reviewed and evaluated (due diligence) against the Environmental & Social requirements such as the IFC Environmental and Social Performance Standards, the applicable national laws on environment, health, safety and social issues and any standards established therein, the World Bank EHS Standards, the CDC Code of Responsible Investment, and the IFC, EIB, DEG, Proparco, and CDC Exclusion Lists
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The implementation of environmental standards within the fund are as follows:
- Assign an Environmental and Social category to each of our portfolio companies determining the level of E&S risk it has and implementing accordingly the right action plan and monitoring process
- If the target company is assigned the high and medium risk categories, a qualified consultant with an experience in IFC Performance Standards’ will be appointed to conduct the Environmental & Social Due Diligence (ESDD)
- All investment agreements will contain appropriate environmental representations, warranties, and covenants requiring that investments be in compliance with all material respects with host country environmental, health, safety and social requirements embodied by state general laws and implementing agencies
- During due diligence, the evaluation of environmental compliance of a target portfolio company with Applicable Requirements through a prepared questionnaire. The Fund will make sure that the selected consultants conducting the due diligence process will be qualified with an experience in IFC Performance Standards and have the adequate skills to run the ESDD.

Supervision and monitoring goes as follows:
- The Fund will be supervising and monitoring investments in the portfolio against on-going compliance with the applicable requirements. The team conducts an assessment on the compliance of the portfolio companies to applicable requirements through a regular reporting process, informal quarterly follow-up calls and visits to the premises of the companies when judged necessary.
- The Fund also does its best effort so that the target companies proactively report any serious incidents that result in loss of life, severe permanent injury or severe permanent damage to health, a material adverse environmental or social impact, or material breach of law relating to environmental or social matters including financial irregularities, and promote corrective actions.

The Fund has a manual for anti-money laundering and funding terrorism prevention that sets specific rules on anti-corruption, this includes:
- The fund shall do the necessary inquiry that no investor is a prohibited person nor is any amount invested or agreed to be invested in the Fund of illicit origin nor related to drug trafficking, corruption, bribery, organized crime or terrorism.
- A number of factors should be assessed in determining when a country poses a higher risk such as countries identified by credible sources as having significant levels of corruption, or other criminal activity.
- Ensure the implementation of the CDC code of responsible investment

The implementation is covered in the due diligence which is conducted pre-investment covering corruption matters among others.
The fund also requires spreading awareness within the portfolio companies relating to relevant corruption matters.

- Risk-management procedures should be introduced to control and mitigate higher risk situations.
These procedures should, as a minimum, provide for the following measures:
(a) the implementation of a program which sets out the additional measures to be applied by the subject person in higher risk situations;
(b) requiring a higher standard in relation to the quality of documents obtained; and
(c) monitoring transactions/activities to a higher degree where the risk warrants such additional measures.
- Team members are required to monitor transactions to determine if any particular transaction is suspicious in nature and may be related to money laundering or funding terrorism activities. Monitoring does not require looking at every transaction.
The extent of the monitoring will be determined on a risk based approach. Ongoing monitoring is an important part of the Fund's money laundering and funding terrorism prevention procedure.
- On-going monitoring is required to be carried out in relation to all portfolio companies. The team's knowledge of the business activities and experience of the portfolio company is extremely important in order to ensure that the transactions being carried out by the portfolio company fall within the business rationale underlying the portfolio company business activities.