Sustainability

At W Capital (“we,” “W Capital,” or “the Firm”), we believe that a Firm-wide, ongoing commitment to the highest standards of business practices and corporate ethics is essential. W Capital is committed to incorporating environmental, social, and governance (ESG) in the investment lifecycle, recognizing that sound management of ESG practices can both mitigate risk and create value for our Firm, portfolio companies, investors and communities.

This excerpt of the Firm’s ESG Policy is intended to provide an overview of our commitment to integrating ESG considerations in our secondary investments; the full policy may be made available upon request to investors and other stakeholders. Understanding that ESG best practices and W Capital’s ESG program will continue to change across time, we will periodically review our full ESG policy and this excerpt to make any necessary updates.

I. Governance and Education

To promote accountability for W Capital’s ESG program, we maintain an internal ESG committee that is comprised of Firm leadership and operations personnel. The committee convenes on at least a biannual basis and is tasked with managing W Capital’s ESG activities and policies. To promote ongoing awareness of ESG considerations, all investment professionals are provided the Firm’s ESG Policy and are required to undergo formal and informal training on ESG best practices during the investment process and ownership period.

II. ESG Due Diligence and Stewardship

W Capital intends to evaluate material ESG risks and opportunities during pre-investment due diligence. To the extent our ownership stake and position allows, and in collaboration with our co-investors and GP partners if feasible, W Capital endeavors to support portfolio companies on ESG topics to promote long-term sustainability.

III. ESG Issues Considered in Diligence and Ownership

During pre-investment due diligence and portfolio company ownership, W Capital considers the ESG risks and opportunities that are material to a company’s business operations, industry, maturity and geography. Below is a non-exhaustive list of considerations common for our asset-light business services, enterprise software and tech-enabled investments:

Data Privacy and Security
• Ethics and Compliance
• Climate Change
• Employee Matters
• Human Rights
• ESG Governance

IV. Accountability and Reporting

We intend to provide material updates on our ESG program and portfolio company performance when appropriate, such as in our annual report and annual meetings with investors. W Capital became a signatory of the UN Principles for Responsible Investment (UN PRI) in May 2024, further codifying our commitment to ESG integration in alignment with recognized industry standards.

V. Scope and Limitations

As professional investment managers, W Capital has a duty to act in the best long-term interests of its investors as a whole. Thus, no ESG-related activity will be required to be undertaken, or investment decision made, that would potentially be adverse or inconsistent with the fiduciary and contractual duties owed by W Capital to its investors, portfolio companies or other constituents.

The Firm’s ESG Policy is intended to reflect W Capital’s general framework for managing ESG issues through the lifecycle of a W Capital-sponsored fund investment. W Capital’s ability to influence the companies in which we invest will vary depending on the investment structure and terms. In cases where W Capital determines it has limited ability to conduct diligence or to influence the consideration of ESG issues in connection with an investment, the Firm will only apply those elements of this Policy that it determines to be practicable. W Capital may reassess or modify our ESG Policy from time to time.

For the purposes of the Firm’s ESG Policy, “material” ESG issues are defined as those issues that W Capital determines have—or have the potential to have—a material impact on an organization’s going-forward ability to create, preserve, or erode economic value, as well as environmental and social and governance value, for that organization and its stakeholders.