Environmental, Social, and Governance Policy

Introduction

The consideration of environmental, social, and governance (ESG) factors is a key priority to Corbin Capital Partners' investment philosophy. Corbin believes that thoughtful and consistent ESG integration and monitoring can mitigate risk, create value, enhance the sustainability of capital, and contribute to competitive returns to investors.

The following pages detail Corbin's ESG policy which was developed as our work and program evolved. The policy will be reviewed and refreshed, as needed, as Corbin continues to develop and refine its approach to ESG. Adherence to this policy will be monitored by the Sustainability Committee (described below).

Additionally, Corbin became a signatory to the United Nations Principles of Responsible Investment (PRI) in April 2021 and a member of the Global Impact Investing Network (GIIN) in December 2021 to align with industry best practices around ESG engagement and reporting.

Sustainability Committee

The Sustainability Committee brings together representatives from different functions across the firm to share insights from and collaborate on implementing ESG initiatives within their respective functions. In doing so, the committee seeks to preempt the formation of knowledge silos and facilitate cross-functional idea generation and discussion. This group is responsible for reviewing and updating the ESG Policy annually to reflect the latest developments in Corbin's ESG program, as well as monitoring adherence of the investment process to the ESG Policy and coordinating the firm's internal sustainability initiatives. The committee or a selected subset thereof meets quarterly and as needed. The Sustainability Committee is comprised of: Tracy Stuart, Managing Partner and CEO; Courtney Birnbaum, Director of Sustainability; Neil Mandal, Director of Strategic Initiatives; John Maguire, Chief Compliance Officer; Christina Neilson, Chief Administrative Officer; Rob Zellner, Senior Partner and Deputy CIO; Adriana Clancy, Partner, Research and Portfolio Management; Elizabeth Yusupova, Senior Client Relations Analyst; and Connor Aller, Operational Due Diligence Analyst.

Values and Guiding Principles

Recognizing its role in the investment ecosystem, Corbin is focused on driving progress across the hedge fund and private credit industry in sustainable investing. We provide a framework and resources to underlying managers so they can then integrate ESG factors and risks in a manner that best fits their firm and strategy. Given the reach of its client portfolios, Corbin believes it has a responsibility to engage with its managers and to encourage their engagement with issuers and companies on ESG issues.

Engagement serves as a tool to unlock the value of ESG integration through routine monitoring, management, and improvement of ESG performance. Corbin's ESG policy, its integration and engagement processes with its managers, and the specific ESG factors it tracks and encourages its managers to track, have been shaped in adherence to the following values:

1. Integration: Within its own investment selection and management processes, Corbin seeks to integrate ESG across key investment decisions. Additionally, Corbin proactively encourages its managers to do the same across their portfolios.
2. Materiality: To ensure that maximum value is delivered to its clients, Corbin focuses on the ESG factors which can have a material effect on either investment or manager performance. Further, Corbin seeks to engage with managers on ESG issues to add value to investment processes and performance.
3. Engagement: Corbin seeks to continually improve its ESG integration and engagement efforts and actively encourages two-way dialogue with managers, issuers, and companies; reflection by its Sustainability Committee and investment teams; and adaptation in line with industry best practice and emerging research.

In line with these values, Corbin adheres to the following six core principles:

1. Corbin's overriding mission is to be a trusted partner who delivers superior results and brings effective, insightful solutions to clients.
2. Corbin is adjusting its operating procedures to incorporate responsible and sustainable practices across the firm.
3. Corbin recognizes that ESG factors can be important contributors to long-term investment returns from both opportunity and risk-mitigation perspectives.
4. Corbin considers ESG factors in context: materiality depends on asset type, strategy focus, geography, industry, etc.
5. Corbin works to tailor our framework to fit each manager's investment approach and meets managers where they are:
6. Corbin engages managers on sustainability to positively impact portfolio returns over the long-term.

Corbin will pursue continuous improvement as knowledge and experience with this topic deepens.

ESG Integration Approach

Across its client portfolios, Corbin maintains a focus on two primary tiers of ESG factors, as detailed below. Corbin monitors these factors through its managers, each of whom is encouraged to track these factors directly.

1. Policy and Process: Factors pertinent to assessing ESG integration across Corbin's managers include but are not limited to whether each manager:

   • has a clear and actionable ESG policy in place;
   • has become a PRI signatory and adheres to PRI signatory reporting requirements;
   • considers ESG factors in the management of the firm and/or in its investment process and how such factors are evaluated;
   • reports on ESG and at what frequency;
   • has a clear point person(s) for its ESG evaluation process;
   • and has representation, policies, and resources to support recruitment, retention, mentorship, and promotion of Black, Indigenous, or People of Color (BIPOC) and/or women across the organization, within the investment team, and among partners or portfolio managers.

   In addition to tracking these policy and process factors among its managers, Corbin will also track its own internal performance in these areas.

2. Portfolio Evaluation Factors: These factors are focused on selection, valuation, and management/monitoring of the underlying investments made by Corbin managers. Moreover, the set of material factors varies by the specific private or public strategy deployed by a given manager to reflect the nuances of potential for engagement and the nature of value creation by strategy. Various industry-level factors may also be pertinent, and Corbin looks to the Sustainability Accounting Standards Board (SASB) aligned factors that reflect five overarching dimensions of ESG, by industry:

   • environment;
   • social capital;
   • human capital;
   • business model and innovation; and
   • leadership and governance.

   Corbin will use aggregate scores across its managers, Additionally, Corbin will track how its portfolio evolves over time. Transparency of information and reporting at the individual holding level will, naturally, vary across its portfolio.

A full set of ESG factors is utilized in Corbin's ESG Factor Framework.

ESG Integration and Engagement Process

Corbin considers ESG across the investment process. The evaluation of the set of material ESG factors naturally depends on the strategy implementation, geographic exposure, industry concentration, i.a., of the given portfolio and is considered in light of these contextual elements. This approach enables us to assess how ESG is integrated throughout the portfolio.

• Operation Due Diligence: ESG evaluation begins during operational due diligence (ODD), when Corbin assesses ESG factors pertaining to managers' policies and processes, alongside standard ODD criteria, across managers within its pipeline. This process is led by Terence Brady, Director of Operational Due Diligence, and Connor Aller, Operational Due Diligence Analyst.
• Investment Due Diligence: ESG risks and corresponding mitigation strategies will be noted and discussed, as needed, in Investment Committee (IC) meetings.
• ESG Baseline: Once a manager enters a portfolio, Corbin's investment team and Neil Mandal, Director of Strategic Initiatives, with support from external consultants as needed, will collect additional information about ESG performance to establish a baseline across both categories of ESG factors.
• Ongoing Monitoring and Engagement: As a result of the ESG manager baseline, Corbin discusses priority areas in advancing ESG integration with the manager in question. The investment and ODD teams will then collect and review ESG data on an ongoing basis to gauge changes across ESG factors over time. Corbin will revisit selected priority areas as well as progress on ESG integration more broadly on an annual basis to track momentum with the manager.

Corporate Sustainability

Corbin maintains a strong commitment to incorporating sustainability into how the organization itself operates. In April 2019, Corbin conducted an evaluation of its operational procedures to identify areas for improvement on sustainability with the help of external consultants. Corbin has since adopted new technology which reduces reliance on paper and improves operational efficiency and resilience.

Another key area of focus is diversity, equity, and inclusion (DEI); for more information, please see Corbin's DEI Policy.

Reporting

Corbin will track its key ESG factors annually, and, as a PRI signatory, complete our required reporting on our sustainable investing activities. Additionally, Corbin will request that managers monitor and report ESG data to Corbin on an annual basis. ESG insights will be synthesized and reported to clients semi-annually, as well as integrated into Corbin's annual report.