The GrowthCurve Capital, LP (“GCC” or "The Firm") Environmental, Social and Corporate Governance (“ESG”) policy is rooted in our belief that, in alignment with our fiduciary duty, the financial success of our partners is integrated with the broader needs of stakeholders within our industry, our portfolio companies and our community at large. The foundation of this approach is based on our conviction that we are responsible for incorporating a sustainability mindset and an environmental, social and governance (“ESG”) lens from the time we source investment opportunities, through the diligence process, during ownership and including the path to monetization and exit. GCC’s commitment to ESG includes a recognition of the impact that companies or industries can have on vulnerable individuals or communities, the environment, or society at large. Indeed, we believe that empowering collective stakeholders without compromising climate, health, freedom and equity, consistent with applicable regulatory or contractual requirements, can help create better risk-adjusted returns for our investors. GCC considers material ESG risks and opportunities in our investment decisions and oversight of our portfolio companies. This policy will be reviewed annually and updated as required.

The following factors are considered when implementing GCC’s ESG policy (non-exhaustive list):

 Environmental

o  Energy management

o  Climate impact, including physical and transition risk

Social:

o  Customer data privacy, cybersecurity and data usage governance

o  Diversity, equity and inclusion

o  Employee health and safety

Governance:

o  Board quality and independent governance

o  Risk management and accountability

o  Financial controls and reporting

‍1. ESG Governance and Firm-Wide Culture

A key element of our ESG Policy is facilitating the implementation of our commitments to ESG throughout our firm and our advisors. GCC has designated an internal ESG committee to oversee and support ESG commitments. We strive to ensure that employees are held accountable for day-to-day responsible investment efforts. We seek to enhance ESG management capacity among our employees and advisors by distributing this policy and related ESG materials to our employees and advisors, as appropriate, and building ESG awareness among our employees through formal and informal training on ESG issues and their impact on investment value.

2. Considering ESG in Due Diligence

GCC is committed to investing responsibly by incorporating ESG considerations into the due diligence process for potential acquisitions to ensure that our investments conform with this policy. We intend to implement this commitment by:

o  Identifying and assessing material ESG factors associated with an investment target (i.e., factors that    may have a meaningful positive or negative impact on financial performance) as part of the due      diligence process.

o  Engaging internal and external expertise as needed to enhance our assessment of investment target’s    ESG issues. If due diligence identifies significant concerns, engaging outside ESG consultants for      further review.

o  Aligning investment criteria with sustainability and ESG principles, and ensuring that findings related   to material ESG risks and opportunities are documented and appropriately communicated in      investment committee materials.

o  Sharing material ESG due diligence findings, including risks and opportunities, with the portfolio       company post-close to promote hold period integration.  

3. Portfolio Company Ownership Consistent with our ESG Principles

GCC’s commitment to ESG continues throughout its ownership of its investments. After it closes an investment, GCC provides oversight of the implementation of and adherence to this ESG policy by its portfolio companies during the ownership period. GCC provides ESG issues that a company may face to company management and provides guidance to assist management in implementing solutions, mitigating risks and addressing opportunities for improvement, where applicable. We expect these processes to continue through the life of an investment.

4. ESG Accountability and Transparency

GCC strives to create accountability within the organization and provide transparency to its investors of its approach to, and assessment of, ESG issues. We do this by:

 o  Allocating internal and external resources to support the commitments made in this policy.

 o  Integrating discussions of material ESG issues, management activities, and progress in reporting and       communications internally and with investors.

 o  Notifying investors of material negative portfolio company ESG incidents that are likely to result in       additional scrutiny for investors, where appropriate or deemed necessary after consultation with the        ESG Committee and/or Investment Committee.

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Updated as of May 2024.