ESG

Armenian National Interests Fund (hereinafter ANIF or The Fund) is committed to ensuring that all our projects have lasting positive impact on Armenia and its citizens, while benefitting all stakeholders. We firmly believe that putting environmental, social and governance responsibility at the heart of our activities ensures long-term success for all our stakeholders, including our investors and partners. We are conscious about the multitude of adverse environmental and social risks any investment may carry and we are committed to offering the best available solutions for eliminating, mitigating or offsetting possible impacts, to enable lasting success of our projects. We expect all our partners to comply with all Armenian rules and regulations, including on all realms of ESG conduct, and apply best international practices, where relevant.

We aim at integrating the principles of good ESG conduct into our investment decisions not only to ensure that we mitigate any adverse environmental or social impacts, but also because we believe that responsible business conduct de-risks projects in the long run and adds tangible economic value by unlocking potential for new investments and opportunities.

We choose to invest in companies and projects that have the potential to bring modern ESG solutions into the industries they operate in and those that have a lasting positive impact on the communities they neighbor with. At the same time, we believe in inclusion, engagement and continuous improvement in our own and our partners’ ESG conduct. It is a road, not an end point, and we are ready to partner in embarking on that road, as long as our partners, investors and investees commit to continuous improvement.

We recognize that the value of good ESG conduct does not rest with prioritizing one of the aspects of ESG at the expense of others, but rather with a subtle balance between environmental, social and good governance commitments, aimed at serving the best long-term interests of all stakeholders.

Brief Summary of the Main Objectives of Integrating Our ESG Vision Into Investment Processes

• As a Public Fund we aim at ensuring that our investments and joint projects have a lasting positive impact on Armenia and its citizens across all ESG factors
• By identifying material ESG-related risks we aim at preventing or lowering reputational risk for the Fund and its partners, as well as preventing long-term material negative impacts those risks may involve for our stakeholders
• By continuous engagement with our partners, we aim at ensuring that ESG performance across our portfolio improves consistently
• We comply, where applicable, with good international ESG practices, including those that our partners/donors/investors and investees may be adherent to. In so doing we ensure that those standards and procedures that are still not represented in the appropriate Armenian legislation are embraced by the Fund and unleash the potential for further legal and practical integration of those practices in Armenia.

Environmental

In ANIF we are committed to ensuring that throughout implementation of all our projects, and in our own organizational conduct, we thoroughly assess, avoid, mitigate, eliminate or offset, where applicable, any adverse environmental impacts.

We require from all our investees and partners to comply with all relevant legal requirements of performance and reporting on responsible environmental conduct implied by the Armenian legislation. This includes those requirements resulting from international and regional agreements that Armenia is signatory to. We expect our partners to apply relevant international good practices where viable.

Since most of our projects are in the inception or early stage, we have set 2022-23 to be a transitional period for all our projects/joint companies for the development of specific environmental management action plans, including reporting on environmental management related matters. This also includes setting specific performance criteria including but not limited to:

• Actions aimed at addressing climate change in line with Armenia’s commitment under the United Nations Framework Convention on Climate Change and its Paris Agreement
• Efficient water management plans
• Waste management plans aimed at pollution prevention and recycling where viable
• Biodiversity management aimed at no net loss

We aim to require from all our joint projects compliance with relevant environmental management good practices by 2024 including relevant international standards compliant reporting on environmental management matters.

Social

ANIF believes that good social performance through all realms of our operations is key to ensuring successful and smooth development of our projects, while building mutual trust and developing a shared vision of benefits with all our stakeholders. Inclusion, fair and equitable treatment, level employment opportunities, respect for human rights, livelihoods and cultural rights of our stakeholders are the basic principles we aim at adhering to, both inside the organization and in all the projects we engage in.

We believe that our commitment to good social performance starts from our employment practices. ANIF employs a diverse team of professionals, which includes citizens of Armenia, Diasporan Armenians from a number of countries, as well as foreign citizens. We are proud that 50% of ANIF staff are women. That is not just a statistical number for us, but a commitment to further integrate inclusion and diversity into our employment practices. We work towards making the decision making process in ANIF a collective exercise, where every employee’s voice is heard and input is appreciated. We trust that inclusion in decision making and assessment of our projects’ performance is not just a tick a box exercise on social performance, but an important tool for our own efficiency and functioning checks and balances in place.

Social and economic well-being of Armenia and its citizens is the axis of our performance objectives. We recognize that projects which unlock potential for economic growth may also bear social risks and adverse impacts for the communities they operate in or around. Thus, we expect our partners and investees to follow the basic social good practices standards that we plan to further develop in compliance with relevant international frameworks.

We require all of our investees and partners to comply with all relevant legal requirements of performance and reporting on responsible social conduct implied by the Armenian legislation. We expect our partners to apply relevant international good practices where viable.

Considering that most of our projects are in the early inception stage, we have set a minimal set of requirements, including but not limited to:

• Basic assessment of possible social impacts and implementation of mitigation measures
• Local employment and local procurement, where applicable
• Functioning grievance mechanisms in place for employees and impacted communities
• Regular reporting on key social performance indicators where applicable
• Fair and equitable hiring and employment practices
• Thorough compliance with Armenian regulations on health and safety in the workplace, in line with international best practices where applicable

We aim to require from all our joint projects compliance with relevant social management good practices by 2024, including relevant international standards compliant reporting on social management matters.

Governance

In ANIF we believe that there is a positive relationship between good governance and investment value. Transparency, efficiency and full compliance with the Armenian legislation and applicable international standards is in the core of our definition of good governance. ANIF is governed by a Board of Directors which includes 6 independent directors. The selection of our Board members was based not only on professional credentials but on our commitment to diversity and independence of the Board, while maximizing its capacity to independently oversee our performance and ensure checks and balances throughout all our operations.

Reporting and accountability is of outmost importance for us as an organization as well as an investor. As a Public Fund we are subject to a number of reporting obligations such as but not limited to:

• Financial reporting to the Government of Armenia, subject to timely public disclosure
• Tax reporting, subject to public disclosure upon request

We are also legally obliged to respond to media inquiries but we prefer to go beyond the legal requirements and disclose any information of potential public interest as well as any material information, regardless of the inquiries.

Projects we implement in cooperation with international organizations are subject to relevant international governance and reporting frameworks compliance. An example is Environmental and Social Management Framework (ESMF) designed for the use by the staff of the Project Management Unit (PMU) and implementing agencies for the purposes of implementing the World Bank-financed Trade Promotion and Quality Infrastructure Project (TPQI). The ESMF outlines the main environmental and social principles, procedures, and guidelines for the implementation of TPQI Project financed by the World Bank’s proceeds to the Republic of Armenia (RA) by Loan Agreement.

ANIF is also committed to producing a Sustainability Report for the year of 2022, since the bulk of our projects started in 2021.

Our expectation and requirement from our investees and partners is full compliance to legal requirements of disclosure and reporting. Where applicable, we expect our partners and investees to provide regular reporting of all activities and ensure timely and relevant disclosure of material information. As a further development starting from 2022, ANIF will be expecting from all investees and joint companies to produce Annual Sustainability Reports, not yet under GRI standards, but containing any relevant material information on ESG performance.

Divestment and Excluded investments

ANIF believes in inclusion and engagement, as we trust that compliance is a road that both the Fund and its partners should take together in a mutually supportive and collaborative manner. We believe that any industry or business activity has room for improvement and so does the Fund’s own performance. Thus, as a first principle, we choose to actively engage and influence improvement in performance, where needed, and do it with patience and persistence. We may, however chose not to invest or maintain investments in certain cases, including but not limited to the following:

1. ANIF will not be investing in any activity, project or industry legally banned or prohibited in any other way under the Armenian legislation
2. Armenia is a signatory to a number of international conventions and treaties. Where ANIF determines that a project or a potential partnership may contravene such international obligations ratified by Armenia, it will choose not to pursue investment or any other partnership

3. Where it comes to the attention of ANIF that a partner or investee is engaged in any unlawful activity, ANIF may choose to divest
4. Where reputation and material considerations from ESG factors may generate risk impacts beyond expected risk-adjusted returns, ANIF may chose choose not to pursue investment or any other partnership

5. In cases where breaches of ESG standards have been identified, ANIF’s first choice will be engagement and working on the improvement of ongoing performance. However, ANIF reserves the option to exclude an investment where the entity is unwilling or unable to change its practices.

Code of Conduct