Last updated December 16, 2021

The Company is committed to developing a strong ESG strategy. However, given the structure of an Investment Trust, which has no employees and relies entirely on external advisers for its activities, the Company cannot independently address all material ESG factors. Day-to-day management of ESG is therefore the responsibility of the Investment Adviser and other Bluefield companies which service the portfolio.

In areas where it does not have direct control, the Company works with its service providers to ensure an appropriate approach is taken. Where these service providers relate to the Bluefield Group, the Company will work with the Investment Adviser to develop an appropriate ESG strategy to address material topics. For service providers outside of the Bluefield Group, additional diligence and engagement will be undertaken to ensure risks and opportunities are managed to a satisfactory level.