1. E&S Policy

Dolma Fund Management (DFM) is a fund manager based in the Republic of Mauritius. Dolma Fund Management (DFM) currently manages Dolma Impact Fund I (vintage 2014, USD 36MN, LPs: FMO, Finnfund, OeEB, DGGF and HNWI/family office investors) and Dolma Impact Fund II (2021, USD 50MN, LPs: FMO, CDC, Swedfund, IFC, DFC). Dolma Impact Fund I and II are a fixed life fund of 10 years that started on 14th September 2014. Fund I has invested in three hydropower projects, one solar project, a pharmaceutical manufacturer, a hospital, and three technology companies. Fund II has invested in a logistic-tech company

Dolma Impact Fund I and II provide capital and expertise to growth companies in Nepal. Executive management of the funds is provided by DFM Mauritius, with advice provided to DFM Mauritius by Dolma Advisors Private Limited (a Nepal-based investment advisor).

As an impact fund, we build positive environmental and social (E&S) impact into the core of investee company strategies. DFM believes that high standards in environmental and social management are fundamental to good business and that by working with investee companies to enhance their E&S processes and performance, we are creating value and positioning the companies for a place in an international market. DFM’s primary investment sectors are renewable energy, healthcare, and tech companies.

DFM is committed to working with companies to enhance E&S performance consistent with DFM’s Environmental and Social Management System (ESMS). This requires DFM to work with potential investee companies to identify the gaps between their environmental and social performance and good international industry practices. Once agreement is reached for DFM to invest, we will work with our investee partners to develop capacity for improved E&S management, invest inefficient technologies and achieve enhanced outcomes, meeting the applicable requirements within a reasonable period of time.

The investors in DFM include international development banks, which require that all investments meet the requirements of the IFC Performance Standards and the International Labour Organisation (ILO) and United Nations (UN) Guiding Principles of Business and Human Rights. In this respect, DFM’s ESMS is aligned with the requirements of these international standards. DFM provides important support to its investee companies to aid in the understanding of these requirements and the capacity to manage their activities accordingly. Accountability towards investors is maintained through regular monitoring and reporting mechanisms.

DFM will maintain, throughout the lifetime of all its investments, an External Communication Mechanism (ECM) to receive any public concerns related to the Fund and its investments. Through the ECM, DFM will work with relevant parties to address the cause of any valid complaints and inform the complainant of any such actions taken.

DFM’s CEO is ultimately responsible for the ESMS of the fund. The dedicated E&S Manager is responsible for the administration and oversight of the ESMS. We commit to ensuring that all DFM staff will have adequate training to perform their roles in the implementation of the procedures.  This policy will be communicated to the entire DFM team who will be expected to adhere to the policy.

The ESMS will be reviewed and revised accordingly on an annual basis or as needed.

2. External Communication Mechanism

FM’s External Communication Mechanism is intended to provide a channel to the public to submit queries, grievances and feedback regarding the fund and its portfolios environmental and social risks and impacts. The ECM is managed by the E&S Manager of the fund.

DFM accepts communications through email ([email protected] or the Feedback Form on its website and responds to all complaint inquiries that arise from the Fund’s activities. All individuals or entities reporting a complaint will receive responses and the complainant will be contacted through either letter or email.

In case of grievances related to the fund’s portfolios, interested or affected are encouraged to discuss the matter with the portfolio companies as per their grievance mechanism and resolve. If the grievances are not addressed satisfactorily or sufficiently at the portfolio level, the parties can submit their queries to the fund.

3. Child Labour and Forced Labour Policy

Dolma does not tolerate child labour or forced labour in its operations as well as in its investee companies. The fund follows IFC Performance Standard 2, ILO Declaration on Fundamental Principles and Rights at Work adopted in 1998 and covers the elimination of forced and compulsory labour and the abolition of child labour, and national legislations. To protect the workforce, the fund and its investee companies will not employ children in any manner that is economically exploitative or is likely to be hazardous or to interfere with the child’s education, or to be harmful to the child’s health or physical, mental, spiritual, moral, or social development. The fund will identify the presence of all persons under the age of 18. Children under the age of 18 will not be employed in hazardous work. All work of persons under the age of 18 will be subject to an appropriate risk assessment and regular monitoring of health, working conditions, and hours of work. The fund screens for child labour and forced labour for any of its vendors or contractors that the fund engages in. The fund and its investee companies will not employ forced labor, which consists of any work or service not voluntarily performed that is exacted from an individual under threat of force or penalty. This covers any kind of involuntary or compulsory labour, such as indentured labor, bonded labor, or similar labor-contracting arrangements.

4. Speak Up Policy

Dolma Speak Up program helps to build and maintain a strong ethical culture, integrity and transparency. It is one of the ways employees can all live valued behaviors and show that employees are Here for Good. It provides employees with a secure way to report, in confidence, genuine concerns about known or suspected misconduct that they have witnessed at work which they are uncomfortable about raising at work with senior management. These concerns could include, but are not limited to, Anti Bribery and Corruptions matters.

5. Anti Bribery and Corruption Policy

Dolma believes inefficient work of the Employee in an honest and ethical manner. The Company takes a zero-tolerance approach to bribery and any forms of “Corrupt Practice” in regard to the business dealings and any relationships of the Company. You are expected to be committed to act professionally fairly and with integrity during your employment with the Company.

“Corrupt Practice” means: (a) the promising, offering, giving, making, authorizing, insisting on, receiving, accepting or soliciting, directly or indirectly, any illegal or undue payment, gift, gratuity or advantage of any nature, to or by any person, with the intention to, or the knowledge that such payment or advantage may directly or indirectly influence, whether as inducement or reward, the actions or decisions of any person, including causing any person to refrain from any action or decision; (b) any action or omission which is prohibited in any applicable jurisdiction by law or regulation relating to bribery or corruption; or (c) any other act which improperly influences or aims improperly to influence the business of the Company.