Delta Rock® Global Capital invests with a long-horizon orientation. Companies that fail on environmental responsibility, basic governance, or social legitimacy tend to fail on long-term returns, often slowly and then all at once. We treat material environmental, social, and governance (ESG) factors as part of fundamental investment analysis rather than as a separate overlay applied after the fact.
1. Our Posture
This policy is intentionally honest. We are not an impact-first investor. Our primary duty is to the capital our investors entrust to us, and the framework below describes how sustainability considerations bear on that duty. Where material ESG factors affect long-term return outcomes, we integrate them. Where they do not, we do not pretend they do.
2. How ESG Integrates into Each Strategy
Growth
For the Growth strategy, we evaluate climate-transition exposure, governance quality (board composition, related-party alignment, capital allocation discipline), regulatory risk under reasonably foreseeable policy regimes, and talent and culture factors that affect a company's ability to execute over a multi-decade hold. We avoid businesses whose long-term thesis depends on the indefinite delay of regulation we believe is likely.
Income
For the Income strategy, ESG considerations inform credit analysis, covenant evaluation, and sector exposure. We assess whether issuers and borrowers have governance and operational structures that can withstand long-tail risks (climate-related physical risk, transition risk, regulatory enforcement) over the duration of the instrument. Sector concentration is reviewed in this context.
Venture Capital
For venture capital investments, we examine founder and board alignment, product safety, regulatory exposure, workforce practices, data governance, and the resources required to build controls as the company scales. The analysis is company-specific and reflects the information reasonably available at the relevant stage; early-stage companies may have limited operating history and less-developed governance systems.
Late-Stage Opportunities
For late-stage private positions, we evaluate governance maturity, the readiness and integrity of disclosure systems, the company's social license to operate in its markets, and the existence of internal controls appropriate for a company on the path to public-market scrutiny. Late-stage governance gaps are a frequent cause of failed liquidity events.
3. Stewardship and Engagement
We invest with concentration and on long horizons. This gives us the standing, and the obligation, to engage directly with management teams and boards on issues we believe affect long-term value. Our engagement is private, substantive, and consistent over multiple cycles. We prefer constructive dialogue to public statements, and durable change to short-term symbolism.
4. Exclusions
We will not invest in:
- Manufacturers of cluster munitions, anti-personnel landmines, biological or chemical weapons, or other instruments prohibited under widely ratified international conventions.
- Businesses whose primary economic activity is the production or distribution of pornography, predatory consumer finance, or known facilitators of human trafficking.
- Counterparties subject to sanctions under U.S. Office of Foreign Assets Control (OFAC) or comparable jurisdictional regimes.
This list reflects our minimum exclusions. Additional restrictions may apply at the strategy or vehicle level and will be set out in the relevant offering documents.
5. Climate
We treat climate change as a material long-term financial factor across every strategy. We do not market a climate-themed product or claim climate-aligned outcomes. We do incorporate transition risk, physical risk, and regulatory risk into investment analysis where they bear on the underlying thesis. We expect our material public-market positions to have credible plans for managing climate-related risks over reasonable time horizons.
6. Governance and Conflicts
The integrity of an investment depends in large part on the integrity of its governance. We evaluate board composition, related-party transactions, executive compensation alignment, audit independence, and the company's history of disclosure quality. We give particular weight to capital-allocation history, which we view as the highest expression of board-level governance.
7. Reporting
We report on our sustainability approach, notable engagements, and any material ESG-driven decisions in our annual letter to investors. We do not publish a separate sustainability report or commit to particular ESG ratings, scoring methodologies, or third-party labels at this time.
8. Limitations
This policy is a statement of approach, not a guarantee. ESG factors may evolve, data may be incomplete or contested, and reasonable people may disagree on materiality. Nothing in this policy is intended to expand, alter, or supersede the terms of any offering document, subscription agreement, or limited partnership agreement.
9. Updates
This policy is reviewed at least annually and updated as our approach develops. The "Last reviewed" date at the top reflects the most recent review. Material changes will be disclosed to investors in our annual letter.
10. Contact
Questions about this policy may be directed to [email protected].