Navigating ESG issues during the private fundraising process
SEC examinations
Documentation
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Ensure that documentation regarding the consideration of ESG factors is created and preserved throughout the
investment process, consistent with any standards established by disclosures and policies/procedures
Create contemporaneous disclosure demonstrating that disclosures align with actual practices during
investment process, including at investment (e.g., investment committee memos), monitoring, voting and exit
Demonstrate adherence to scoring / standards
Oversight
Ensure that investment teams are aware of policies, procedures and disclosures
Enforce and provide regular training to employees on all ESG policies
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ROPES & GRAY
Develop controls and consensus over ESG frameworks and memberships
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Perform annual reviews and mock ESG reviews to test adherence to policies and procedures
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