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.

Principles for Responsible Investment
Serengeti supports the UN-backed Principles for Responsible Investment (“PRI”), and is a formal signatory to the PRI and its six principles:
- Incorporating ESG issues into our investment analysis and decision-making processes.
- Being active owners and incorporating ESG issues into ownership policies and practices in proportion to our level of influence.
- Seeking appropriate disclosure on ESG issues by the entities in which we invest.
- Promoting acceptance and implementation of the PRI principles within the investment industry.
- Working together to enhance our effectiveness in implementing the six principles.
- Reporting on our activities and progress towards implementing the six principles.
Applicability
The policy is effective from 31 October 2021, covering 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. In applicable funds and investment vehicles, we seek to consider ESG factors in new investments as part of a wider due diligence process, evaluating ESG risks, issues and opportunities, in proportion to our leverage, influence and access to information, as well as holding period and the size of the deal.
ESG as a Firm
In addition to considering ESG factors as part of our investment processes, Serengeti aims to increase its focus on incorporating responsible and sustainable practices throughout the organization.
Implementation
To implement this policy, Serengeti will:
- provide ESG training to employees;
- engage external ESG advisors where appropriate;
- become a signatory to PRI; and
- incorporate reference to this Policy into its compliance manual.