WE TAKE COMPLIANCE SERIOUSLY

Last Modified: March 30, 2023

If you are a member of the Renew Capital Angels, these documents are for you. Please click on the links below to view or download the attachments:

• Renew Capital Angels Disclosures - Effective Date: January 9, 2024

• Template Confirmation of Accredited Investor Status (Canada)

• Business Continuity and Succession Plan Disclosure Statement for RENEW LLC

If you have any additional questions, please contact renew@renewcapital.com.

Please read the following carefully as it contains the conditions governing any electronic communications between you and Renew Capital LLC and its affiliates (“Renew Capital”). By messaging with Renew Capital, you agree to these terms and conditions, and you acknowledge and accept all risks associated with electronic communications. Renew Capital may amend these terms and conditions at any time without notice. You should check this webpage from time to time to review the current terms and conditions because they are binding on you.

Electronic communications may contain confidential and legally privileged information, or may otherwise be protected by work product immunity or other legal rules. If you are not the intended recipient of an electronic communication, viewing, copying, distribution of, or reliance on such electronic communication (and any attachments) is strictly prohibited. If you have received an electronic communication in error, please notify Renew Capital immediately by replying to such message and deleting it and any copies of it from your computer.

Renew Capital is committed to protecting the security of your information and takes reasonable precautions to protect it. However, internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure, and as a result, we cannot ensure the security of any information you transmit to us through an electronic communication; accordingly, you acknowledge that you do so at your own risk. Specifically, Renew Capital cannot and does not guarantee that electronic communications (sent or received) are secure, accurate, complete, not corrupted or virus free and/or that they won’t be lost, misdelivered, destroyed, delayed, intercepted or decrypted by others. Therefore, we advise against sending sensitive or personally identifiable information via electronic communications. You may contact us to learn about secure ways to share your sensitive or personal information with Renew Capital.

Electronic communications are not a reliable means of communicating with Renew Capital. As such, Renew Capital does not accept any responsibility for the contents of any electronic communication or for any delays, inaccuracies or omissions in the receipt of your instructions or in the transmission of other information to Renew Capital, and Renew Capital disclaims all liability to the fullest extent permitted by applicable law for any loss or damage arising from any reliance on or use of electronic communications in any way.

Information in an electronic communication is subject to change without notice and, unless otherwise indicated, the views expressed are the author’s and may differ from those of others within Renew Capital. The information represents a view as of the date of the electronic communication and is subject to change and/or withdrawal at any time without notice.

Please note that any electronic communication that is conducted within or through Renew Capital's systems is subject to monitoring, review, retention and external production in order to comply with relevant laws, regulations and regulatory requests, for risk management purposes and/or for the proper operation of our business; may be stored or otherwise processed in countries other than the country in which you are located; and will be treated in accordance with Renew Capital's policies and applicable laws and regulations.

If you are not comfortable with the risks associated with electronic communications, you may decide not to use electronic communications to communicate with Renew Capital. 

Renew Capital is committed to the prevention of and response to sexual exploitation and abuse.

Renew Capital will not tolerate harassment/sexual harassment of any applicant, employee or customer by a managing partner, fellow employee, or independent contractor on Renew Capital premises or at "on location" sites, nor will Renew Capital tolerate sexual exploitation and abuse of any member of the communities in which Renew Capital operates by any staff member, employee or independent contractor of Renew Capital or of our partners or portfolio companies.

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual or (3) such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment. 

Sexual harassment can take two distinct forms: “quid pro quo” and “hostile work environment.” Quid pro quo harassment occurs when submission to sexual conduct is made a condition of employment or employment benefits. Hostile work environment occurs when sexual conduct unreasonably interferes with an employee’s work performance or creates an intimidating, abusive or offensive work environment. 

Sexual harassment includes verbal harassment, such as epithets, derogatory comments or slurs; physical harassment, such as assault, impeding or blocking movement, or any physical interference with normal work movement; and visual harassment, such as derogatory posters, cartoons, or drawings.

Sexual exploitation is defined as actual or attempted abuse of a position of vulnerability, power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. Sexual abuse is defined as actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. All sexual activity with a child is considered as sexual abuse. Sexual exploitation and abuse are distinct from sexual harassment. Sexual exploitation and abuse occurs when a position of power is used for sexual purposes against a beneficiary (whether of Renew Capital’s products or services, or of Renew Capital’s partners or portfolio companies) or vulnerable member of the communities in which Renew Capital operates, whereas sexual harassment is directed against a colleague, employee or other person in the workplace.

In addition, Renew Capital will not tolerate harassment on other grounds, including race, color, national origin, religion, age, disability and any other basis prohibited by applicable law. Harassment includes jokes, verbal abuse and epithets, degrading comments, the display of offensive objects and pictures, and other physical or verbal conduct that the individual might reasonably find to be offensive or that creates a hostile work environment.

In addition, supervisors are prohibited from dating employees who are employed in their immediate area of supervision or responsibility. Any supervisor who is involved in a relationship with a subordinate must report the relationship to the CFAO or a managing partner so that a reassignment of supervisory duties can be made. Employees who engage in personal relationships with co-workers should conduct themselves in a business-like manner and not engage in inappropriate physical contact while on Renew Capital premises or at “on location” sites.

REPORTING EXPLOITATION, HARASSMENT OR ABUSE

Any individual who believes that he/she has been subject to harassment/sexual harassment or sexual exploitation and abuse, or has reason to believe harassment/sexual harassment or sexual exploitation and abuse may be taking place towards other individuals, either within Renew Capital or externally in related organizations or settings (such as in our portfolio companies, Chigign Tobiya or other Renew Capital-led initiatives), whether or not it directly affects that individual, should report the circumstances as soon as possible to the CFAO or a managing partner. All complaints will be treated with confidentiality, to the extent possible given Renew Capital’s obligation to investigate and report to development partners, and no retaliatory or punitive action will be taken against an employee on account of filing a complaint in good faith.

In exceptional circumstances where a person has been discouraged from reporting to the CFAO or a managing partner or may fear retaliation impacting his job or well-being by reporting, reporting anonymously is possible via the following link: LINK. We note, however, that anonymous reporting can present fact-finding and verification challenges and be prone to abuse and may be subject to legal limitations. Typically, the most effective way to address a problem is by speaking first with an executive or manager and allowing the individual to whom you report the incident to take the appropriate action.

When reporting an incident or series of incidents, please provide the following information (“Incident Information”):

• All relevant facts related to the alleged event or circumstances

• The name of the individual/s involved

• The dates, times, location and frequency of the alleged events

• If the circumstance requires immediate attention, please state this clearly and explain the reasons why

• Describe documents, witnesses or other evidence available to support the allegations and the rules or laws that were violated

Incidents of alleged harassment/sexual harassment, or sexual exploitation and abuse, will be taken seriously by Renew Capital and will be promptly investigated by the CFAO and one or more managing partners of Renew Capital when such allegations are made. Investigations will include the review and collection of as much incident information as is possible and appropriate in light of the seriousness, nature of allegations and urgency of addressing the matter and reaching a resolution.

RETALIATION AND INTERMEDIATION PROHIBITED

Persons who feel that they are experiencing harassment or discrimination must feel free to come forward with complaints, and Renew Capital must be free to conduct a thorough investigation without any interference.

Accordingly, Renew Capital wants to make it clear that no one may retaliate or discriminate against a person for making a complaint or for participating in an investigation. Prohibited retaliation includes intimidation, coercion, harassment or negative acts or comments against a complainant. Reports of any type of conduct of this sort should be made to a managing partner.

TRAINING AND REMEDIAL MEASURES

Renew Capital's policy on preventing harassment, sexual exploitation and abuse is incorporated in its employee handbook, which team members must review and affirm when they begin working with Renew Capital and annually. Training on this policy is conducted periodically, including when any major updates are made to the policy.

The HR department will retain reports of harassment, exploitation and abuse and will analyze any trends that may emerge with respect to team members’ behavior and investigation outcomes. Appropriate corrective action, up to and including termination, will be taken if claims are determined to be true. Under certain circumstances, law enforcement officials may be notified and involved in addressing alleged events.

If you have questions about any of the legal disclosures or policies included on this page, please contact Renew Capital at renew@renewcapital.com, attention Chief Compliance Officer.