Responsible Investment Policy

Pembroke’s mission is to help our clients secure their financial futures. As fiduciaries acting on behalf of our clients, we analyze all potential investments with regard to their returns, and both their financial and non-financial risk characteristics. In the appraisal of potential investment returns and risks, Pembroke believes that non-financial factors including environmental, social and governance (ESG) factors, can be as important as financial factors.

Pembroke expects the companies it invests in to comply with all laws and regulations under which they operate and to be responsible stewards of their assets. The firm’s business and investment philosophy is rooted in the concept of ownership, good stewardship, and aligned interests. Pembroke believes that owners have a responsibility to act in the long-term interests of their stakeholders to maximize their wealth.

Pembroke believes that sound ESG practices can reduce a firm’s risk and improve its operational, financial and stock price performance. Pembroke integrates the analysis of non-financial factors, including ESG factors, into its appraisal of the long-term risks and growth prospects of companies through a process of risk-prioritized inquiry, engagement and collaboration. With the goal of enhancing long term risk adjusted returns, Pembroke will:

• Inquire about ESG factors as part of our research effort
• Engage with management on ESG related issues through active ownership
• Inquire and encourage ESG related disclosure when appropriate
• Collaborate with other long-term market participants to promote responsible investing
• Monitor new reforms, potential risks, and opportunities related to responsible investing and ESG factors that can impact the companies in which we invest

Pembroke’s Corporate Governance and Responsible Investment Committee (CGRI Committee), which reports directly to the firm’s managing partner, is responsible for coordinating the firm’s responsible investing activities. The committee includes members from the firm’s investment management, client service, and operations departments.

Pembroke commits to reviewing its Responsible Investment Policy at least annually.