Responsible Investment Policy

Serengeti Asset Management, LP (“Serengeti”) is a value-driven investment firm focused on investing in niche credit opportunities and providing sophisticated funding solutions. We believe that Environmental, Social and Governance (“ESG”) factors can affect performance to varying degrees across companies, sectors, regions, investment strategies and asset classes. As such, we seek to consider material ESG risks, issues and opportunities, together with financial criteria, in applicable investment processes in line with our fiduciary duty to maximize returns.

Responsible Investment Policy

Serengeti Asset Management, LP (“Serengeti”) addresses complex special situations through structure and creativity. We believe that Environmental, Social and Governance (“ESG”) factors can affect performance to varying degrees across companies, sectors, regions, investment strategies and asset classes. When appropriate, we seek to consider material ESG risks, issues and opportunities, together with financial criteria, in line with our fiduciary duty to maximize returns.

The policy covers all funds and investment vehicles that have been open to new investors since 2018.

Approach to ESG Integration

The nature of our investment strategies means that we typically are not making control investments, limiting our ability to exert influence through ownership, board seats and/or governance rights. Consequently, we may incorporate considerations of ESG risks, issues, and opportunities within a comprehensive due diligence process, taking into account an Escalation List and other factors such as our leverage, influence, access to information, holding period, and the scale of the deal.

ESG as a Firm

Serengeti aims to increase its focus on incorporating responsible and sustainable practices throughout the organization.

Implementation

To implement this policy, Serengeti will:

Policy Sponsors: Chief Investment Officer and General Counsel
Last Update: November 2023