Environment, Social, and Governance Policy

Strategic Overview
At Oberweis Asset Management (OAM), we employ fundamental analysis in making our investment decisions. Our process is designed to analyze businesses from several angles, providing us a well-rounded understanding of a company’s risks and opportunities. Ultimately, we aim to assess whether the business is durable and capable of sustaining high returns on capital over time. In this regard, we believe that environmental, social, and governance (ESG) issues can potentially affect the risk and return profiles of our investments and, therefore, we consider ESG issues in our fundamental analysis.

ESG Integration
OAM believes there are multiple dimensions to ESG integration. We consider a company’s exposure to and management of ESG risks and opportunities, rather than focusing on only the risks. For example, banks could mitigate risk by limiting their financing of companies facing scrutiny over their impact on the environment. However, they could also increase their opportunity by improving access to their products in under-penetrated segments and markets. By evaluating both the ESG risks and opportunities, OAM develops a deep understanding of a company’s ability to create long-term shareholder value.

OAM uses external ESG research providers and has also developed a proprietary ESG model that considers 20+ material ESG issues on a sector-by-sector basis. Integration varies by product and is bespoke to each strategy. Our developed market funds that usually have higher turnover rely more on external providers, while emerging market funds with longer investment horizons utilize our proprietary ESG model. Our ESG Specialist and Portfolio Managers work together to construct the most effective approach to ESG analysis for each product. We believe that ESG considerations should not limit the investable universe, but rather help us hone our assessment of a company’s sustainable competitive advantage.

Company Engagement
As active small-cap investors, we believe that engagement and dialogue with potential and current holdings is important in evaluating companies’ ESG profiles. ESG-related disclosure is often not robust in the small-cap universe, especially within the emerging markets. As such, when relevant, we interview management to assess the materiality of ESG issues to their businesses and, where feasible, discuss the adoption of improved ESG practices.

Proxy Voting
OAM has retained the services of an industry-leading proxy voting provider, who casts votes taking into consideration a range of factors material to share and stakeholder stewardship.

Policy Scope
ESG integration is overseen by an ESG Committee comprised of senior staff as well as a designated ESG Specialist. OAM is a signatory to the UN Principles of Responsible Investing, a broad international network of ESG-conscious investors.

OAM publicly supports The Paris Agreement, an international treaty on climate change adopted by 196 parties. Its goal is to limit global warming.

https://unfccc.int/

OAM publicly supports the Task Force on Climate-Related Financial Disclosures (TCFD), which seeks to improve and increase reporting of climate-related financial information.

https://www.fsb-tcfd.org/


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