E2 ESG Policy

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E2 Investment Advisors LLC (the “Firm”) and its affiliates understand that environmental, social, and governance-related issues can have a meaningful impact on our employees, the companies we associate with, our communities, and our investors. Therefore, it is our responsibility to strive to create both a policy and culture that reflect our commitment to safety and stewardship of environmentally and socially while maintaining good governance policies.

Accordingly, the Firm sets out below our environmental, social, and governance policy (the “ESG Policy”) regarding the decision-making process within our Firm and governance of the investment funds managed by the Adviser (the “Funds”). We believe the ESG Policy will help the Adviser and our Funds prosper through the coming energy transition while always keeping sight of our commitment to environmental stewardship.

We also believe that having the right “tone at the top” is a crucial factor in the overall success of any policy. As such, the Firm’s ESG Policy reflects our commitment to a high standard of integrity in our business conduct; our focus on workplace safety, diversity, equity, and inclusion; our emphasis on strong partnerships with the communities where we live and operate; and our efforts to act as custodians of the environment. The ESG Policy is based on guidelines consistent with the United Nations Principles of Responsible Investment and The American Investment Council Guidelines for Responsible Investment.

Overview of the Firm

The Firm is a high-conviction energy fund manager formed in 2020 and based in The Woodlands, Texas, near Houston. The Firm’s investment philosophy for the Funds aims to capture growth and build positions in traditional energy stocks during strengthening commodity cycles while maintaining a long-term focus to transition to renewable assets and services that create a more sustainable future. We believe there will be an ever-growing demand for renewable energy sources, as these sources are expected to be the world’s leading source of power within two decades and, based on our view of the markets, are establishing a foothold in the global energy system faster than any fuel in history. However, based on our market research, demand will remain strong for oil and other hydrocarbons as predominant energy sources for the near to medium term. Therefore, while the energy evolution is taking place and consistent with our overarching obligation to act in the best long-term interests of our investors, the Firm will continue to focus on investing in low-cost, environmentally responsible producers in the oil and gas space.

Investment Strategy and Approach

The Firm’s investment strategy seeks to focus on the inherent and fundamental value of the underlying assets of each investment and participate alongside responsible partners throughout the energy industry and with private management teams. To this end, the Firm has developed a responsible investor strategy (the “RI Strategy”) to ensure that the stocks and portfolio companies we purchase and associate with share our fundamental values. The basis of the RI Strategy is to review companies for the possible risk that their business practices could jeopardize or do not align with the ESG values of the Firm. One way the Firm monitors this is to review disclosures on ESG issues by the entities in which the Funds invest. With respect to our relationship with management teams, the Firm expects each portfolio company to have its own ESG policy, with ESG considerations addressed at each board meeting.

Environmental Issues

We take a precautionary approach to the environmental challenges within the energy industry. Prior to considering an investment, the Firm actively considers several factors that address the environment, which may include working with responsible partners who have a track record of adhering to environmental protection practices, laws, rules, and regulations, as well as reducing their environmental footprint.

Social Issues

The Firm’s ESG Policy includes a focus on our hiring and development practices as well as our policies on privacy and data security, human rights, and anti-corruption. As part of the Firm’s social responsibility, we seek to attract the best talent while embracing diverse backgrounds and perspectives. We actively promote a culture that embraces differences, honesty, and teamwork. We look to create an environment that respects and values each individual employee’s contribution to the Firm through fair compensation, annual bonuses, and participation in the Funds’ carried interest.

We acknowledge the obligations that we have to the communities in which we operate and realize that safe, reliable, and environmentally compliant operations and supply chains guide our daily work. In this regard, we expect our third-party service providers and vendors to respect their workers and communities and avoid conducting business in ways that  harm people. We strive to accomplish this goal by holding our vendorsto the same standards we expect of our own employees.

The Firm also understands that it is essential to give back to our community and recognizes the impact that our operations could have on local communities. We generally focus our philanthropic efforts on several key themes, including helping underprivileged youth and providing hunger relief in the Houston area. The Firm is proud of the volunteerism and willingness of our employees to give back to the communities where we work. The Firm participates in an annual day of volunteering to directly support these efforts in addition to each employee’s individual efforts.


To promote good governance and transparency, the Firm seeks to maintain an alignment of interests between the Firm’s management, partners, and other stakeholders through regular communication and openness. The Firm has a robust regulatory compliance program with quarterly reporting expectations for its employees. Moreover, the Firm has detailed financial reporting requirements, including monthly Net Asset Value statements and annual audited financial statements for the Funds that adhere to the Firm’s financial and valuation policies. Finally, the Firm’s executive team provides levels of oversight that we believe are appropriate in the areas of risk management and potential conflicts of interest and regularly monitors the ESG Policy for areas of improvement.

Employees or portfolio management company members who do not adhere to the Firm’s ESG Policy are subject to appropriate disciplinary action, including suspension or termination.

While the Firm intends to self-monitor its activities and progress toward implementing its ESG Policy, it also intends to solicit feedback on an annual basis from the Funds’ investors to have a constructive and transparent relationship on environmental, social, and governance activities of the Firm and its managed Funds.


This document has been prepared for the investors in the Funds managed by the Firm. It may not be published or disclosed, in whole or in part, to any other party. This document is for discussion purposes only. The information and opinions in this document constitute the judgment of the Firm at the time specified and may be subject to change without notice, and they are not to be relied upon as authoritative or taken in substitution for the exercise of judgment by any recipient. Under no circumstances is this document to be used or considered as an offer to sell securities or solicitation of any offer to buy securities, nor shall it form the basis of or be relied upon in connection with any contract or commitment whatsoever or be taken as investment advice.