Congressional Bank

Responsible Investment Policy

Congressional Bank and its subsidiaries (collectively the “Bank”) have established a Responsible Investment Policy as a guiding document reflecting its philosophy and approach towards evaluating Environmental, Social, and Governance (“ESG”) factors within its lending platform. ESG is a term used to capture the overarching areas that characterize a sustainable, responsible or ethical investment. ESG factors are an important input into the Bank’s credit analysis and decision making, and the Bank believes that appropriate management of ESG matters reduces credit risk and enhances loan opportunities. Further, the Bank believes that growth cannot be achieved and maintained without a committed focus on sustainable value creation in light of diminishing resources, changing consumer demands, and increased regulation. The Bank elected to develop and maintain its policy to help manage the credit risk associated with ESG activities at the borrower level and contribute to ESG stewardship within the broader lending market. The Bank believes that its policy is aligned with the interests of all of its stakeholders, including its asset management clients, lending partners, private equity investors, and borrowers.