ESG Guidelines

ESG Guidelines and Exclusion Criteria of Bridgetower Capital

Bridgetower is committed to upholding strict Environmental, Social, and Governance (ESG) standards across its operations. To ensure compliance, Bridgetower has implemented exclusion criteria and extended due diligence processes for certain industries and business activities.

Exclusion Criteria: Bridgetower does not engage in operations related to the following industries:

• Production and processing of fur

• Military support services

• Sex business and pornography

• Tobacco cultivation and tobacco products

• Production of weapons and ammunition, including components, trade, and maintenance

• Animal experiments

• Deforestation of primary forests

• Dark web-related content and business

• Cyber warfare, malware, and other activities related to cybercrime

• Electronic espionage

• Surveillance systems in violation of international law and human rights

• Data collection obtained in violation of international law and human rights

Extended Due Diligence: For funds and companies involved in the following activities, an extended due diligence is required:

• Alcohol and products containing alcohol

• Hemp cultivation and processing for medical purposes

• Gambling

• Animal trade and transport, slaughterhouses

• Waste and recycled materials

• Aquaculture and fishing

• Forestry

• Gas, coal, and oil

• Wood, wood products, cardboard, and paper

• Mining and metals

• Monocultures, including biofuels, palm oil, and soya

• Financial businesses with questionable Anti-Money Laundering (AML) protection, prone to be used for money laundering

• Lending, credit, or fintech businesses with a potential of over-indebting their users/clients, if not falling under local financial sector regulation

ESG Questions in Due Diligence: As part of the investment due diligence, questions are asked about risks and opportunities related to sustainability issues. Focus lies on ESG risks that could negatively affect investment performance or reputation, such as risks from controversial business practices or bad governance.

Amendments to Investment Contracts: If relevant, reporting obligations or information requirements covering specific ESG issues may be integrated into the investment agreements. This allows Bridgetower to monitor specific ESG risks within the outstanding investment portfolio.

Blockchain Infrastructure Services Exclusion Criteria: In principle, Bridgetower does not operate blockchain infrastructure, staking services, or running validator nodes for protocols or applications related to industries such as military support services, sex business and pornography, tobacco cultivation and tobacco products, production of weapons and ammunition, animal experiments, deforestation of primary forests, dark web-related content, cyber warfare, malware, electronic espionage, surveillance systems in violation of international law and human rights, and data collection obtained in violation of international law and human rights.

Extended Due Diligence for Blockchain Infrastructure Services: For protocols or applications supporting business activities such as supply chain applications in general, alcohol and products containing alcohol drug cultivation, distribution and processing for medical purposes, gambling, gas, coal, and oil-based energy production dependent businesses and business applications (e.g., crypto mining), automated electronic data collection, surveillance systems (e.g., for medical purpose, tracking apps, etc.), financial and other businesses with questionable AML protection or KYC standards, Bridgetower requires an extended due diligence process to ensure compliance with ESG standards.