Eagle Trading Systems Inc. (“Eagle”) has always believed in and adhered to Responsible Investing and Environmental, Social and Governance (“ESG”) principles. The purpose of this policy is to formalize Eagle’s principles and operations in Responsible Investing and ESG issues. Eagle is committed to investing responsibly and to the management of ESG issues and applies the highest legal and ethical standards in its commodity and investment management activities. The firm takes its fiduciary duties seriously. In addition to articulating the guiding principles of Eagle’s Responsible Investing and ESG Policy, this document describes the policies and procedures integrated into Eagle’s ongoing investment activities and operations. Eagle Investment Solutions is an alternate name for Eagle Trading Systems Inc.
Eagle is committed to integrating ESG factors alongside other financial considerations in its investment analysis and decision-making process, both in evaluating existing investment programs as well as designing new investment programs. ESG factors and their impact, such as climate change, will be considered if they are determined to be relevant, material and aligned with the firm’s investment mandate and fiduciary duty. In particular, Eagle will not directly invest in companies which have poor Responsible Investment or ESG records. The firm will require any private company in which it has a direct investment to attest to its Responsible Investment and ESG standards and may choose to divest from such company if the company is not transparent regarding ESG issues. In its investments in public companies, financial instruments and derivatives, ESG factors will be considered and evaluated to avoid adverse ESG effects, including the exclusion of companies and ETFs with poor ESG records from the firm’s investable universe. In addition, Eagle will evaluate the opportunities for participating in environmental commodity markets, like Emission and other Carbon contracts, based on their liquidity and price behavior patterns, if they are determined to be aligned with the firm’s investment mandate, strategies and fiduciary duty. Our approach to Responsible Investing is not prescriptive and we do not seek to limit our investment universe; rather we believe that the consideration of ESG factors may provide opportunities to further develop existing programs, identify new trading opportunities and enhance risk management. In addition, Eagle ensures that its investment professionals act in accordance with the above principles and the highest legal, ethical and professional standards.
At Eagle, we recognize the importance of diversity to foster creativity and innovation. The firm is an equal opportunity employer and makes efforts to encourage diversity within the workforce. As a small organization, Eagle is well-positioned to cultivate a diverse team. The firm complies with all applicable human resources laws and promotes a fair and safe environment for all employees. Specifically, we are committed to paying our team fairly and equitably, regardless of race, religion, sexual orientation, gender identity or expression, national/ethnic/social origin, family or marital status, age, disability, medical condition, or military service. Eagle believes that every employee has the right to work in an environment that is free from harassment or unwelcome conduct, and employees are encouraged to report any issues that may arise.
Eagle is committed to maintaining environmentally sustainable workplaces and reducing waste in order to reduce the firm’s carbon footprint. Specifically, the firm and its employees are engaged in recycling initiatives and employees are encouraged to play their part by recycling, avoiding unnecessary printing, using reusable mugs, turning off lights when not in use, and properly disposing of equipment. Eagle’s principals have been closely involved and invested considerable funds in alternative, low emission, energy sources like hydrogen.
Eagle encourages volunteer work and charitable contributions. The firm and its principals have been actively involved with (directly and through industry initiatives) and contributed significant resources to diverse environmental, social (provided scholarships for underprivileged individuals to attend university and participate in extracurricular activities), educational (supported university technology and campus development), medical (funded novel medical and scientific research) and cultural causes. The firm’s Chairman, CEO and CCO, Menachem Sternberg, is an active philanthropist through the Menachem and Liora Sternberg Family Foundation, supporting a range of initiatives related to education and academic research in the United States and globally.
Eagle is committed to complying fully with all applicable rules and regulations, and, where appropriate, will adhere to industry best practice, including with regard to Responsible Investing and ESG issues. A subcommittee within Eagle’s Operations and Governance Committee will regularly evaluate the changing landscape and industry standards to update and improve Eagle’s ESG approach. In addition, this policy will be reviewed and updated (if necessary) at least annually. In accordance with the high priority given to the issue, Menachem Sternberg, Eagle’s Chairman, CEO and CCO, will be responsible for oversight of ESG issues at Eagle to ensure that appropriate ESG considerations are taken into account in the investment process. As part of employees’ compliance and ethics training, special attention will be devoted to Responsible Investing and ESG issues, and employees will be required to attest to their compliance with Eagle’s Responsible Investing and ESG standards.
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