This Environmental and Social Policy (“E&S Policy”) sets out objectives, procedures, and guidelines to manage and monitor related risks. This Policy facilitates developmental impacts reporting in line with the aims of investment partners and is a framework that integrates E&S risk management into the ACCT Fund’s processes. This is achieved through a set of actions and procedures concurrently implemented along with other broader risk management procedures. This Policy ensures that the ACCT Fund’s activities are in compliance with relevant environmental and social standards, enabling it to avoid and/or manage Portfolio Companies with potential adverse E&S risks. Built into the procedures is the Environmental and Social Due Diligence (ESDD) conducted prior to deal completion to facilitate the development of appropriate mechanisms for the adequate monitoring of the Portfolio Companies activities during the investment period.

Objectives of the E&S Policy

The ACCT Fund was created to provide emergency relief support to tourism businesses impacted by the COVID-19 pandemic. It recognizes that environmental and social (E&S) sustainability are central to the attainment of sustainable development outcomes that are inclusive and equitable, hence the need to be mainstreamed into its core activities. This ACCT Fund’s policy has been developed to underpin its resolve to reduce and/ or avoid negative E&S impacts that may potentially result from its activities, towards ensuring sustainable development outcomes. The ACCT Fund uses a range of interventions to promote efforts that advance responsible and sustainable tourism through operational best practices in the focus countries to achieve its objectives. The ACCT Fund will therefore screen all the Portfolio Companies for E&S risks at a Portfolio Companies level, to define their management/monitoring as per its policy.

This E&S Policy will enhance effective E&S management practices in all the ACCT Fund’s activities with a focus on the following considerations:

• Ensuring that applicable E&S requirements are met for all Portfolio Companies

• Integrating E&S risk assessments into the Portfolio Company due diligence processes

• Ensuring appropriate consultations and transparency in all the activities

• Collaborating with Portfolio Companies to put into practice applicable E&S requirements; and,

• Deliberately focusing on positive conservation and community benefits during sourcing of potential Portfolio Companies

Implementation of E&S Principles

The ACCT Fund will implement its E&S Policy through the Environmental and Social Management System (ESMS), ensuring compliance with the respective governing laws and regulations as well as international standards relevant to the ACCT Fund. This Policy is designed to guide the implementation of and adherence to the ACCT Fund E&S requirements, and the ACCT Fund will establish and maintain the following E&S operational requirements:

• The ACCT Fund will integrate E&S requirements into every step of the investment process

• Screen all potential Portfolio Companies requesting funding and their activities against the ACCT Fund’s Exclusion List in alignment to the ACCT Fund’s investment strategy

• Make informed decisions based on robust categorization of Portfolio Companies according to their E&S risk levels, ascertained by thorough review of the proposed activities through E&S Due Diligence (ESDD)

• Clearly define roles and responsibilities for the effective implementation of the E&S responsibilities at the ACCT Fund level, with proper emphasis on management review and reporting procedures

• Develop appropriate measures to monitor compliance with all relevant E&S policies, laws, and regulations of Portfolio Companies in the country(s) that the ACCT Fund’s activities are implemented

• Continuously develop and improve institutional capacity to understand, assess and manage E&S risks and impacts associated with the ACCT Fund’s activities

• Implement the ESMS to deliver the E&S objectives of the ACCT Fund while monitoring compliance with its Policy across its portfolio and periodically report to management

• Collaborate and share information among relevant stakeholders involved in the ACCT Fund on its activities including with project beneficiaries

• Ensure that the E&S Policy is communicated to relevant persons within the ACCT Fund’s implementation team, partners and across its investment portfolio; and,

• Establish mechanisms to monitor and manage E&S risks, working with various stakeholders, partners, and employees to raise awareness on E&S risks and, if identified, to ensure that they are handled appropriately