1.4 Monitor pay equity and address any disparities
Onboarding
2.1 Unconscious Bias Training
2.2 Workplace Violence Prevention
2.3 Accessible Ontario Disability Act
2.4 Americans with Disabilities Act
2.5 Civil Rights Act
Training and Education
3.1 Paradigm Reach online platform
3.2 Operating Locations Specific Training
3.2.1 Texas
3.2.2 Miami
Partnerships and Community Engagement
4.1 Current partnerships
4.1.1 Gord Downie & Chanie Wenjack Fund
4.1.2 Out Investors
4.1.3 Institutional Limited Partners Association
Accommodations and Accessibility
5.1 Disability Accommodation
Reporting and Accountability
6.1 Annual Engagement Survey
6.2 Reporting Violations
6.3 Annual
Purpose and Intent
Oversight of Our EBID Commitment
Fengate Asset Management (“Fengate”) is committed to creating and continuously growing and sustaining an inclusive culture that respects and connects the diversity of our team, our clients, our partners, and the communities in which we operate. This Equity, Belonging, Inclusion and Diversity (EBID) Policy applies to all Fengate employees. It is our expectation that Fengate’s vendors will adhere to this EBID Policy as well. This EBID Policy is overseen by Fengate’s HR Department with oversight and guidance by EBID Think Tank Chairs, Jaime McKenna, and Daryl Sam.
Our EBID Mission and Vision
Fengate’s mission is to deliver excellent investment results while fulfilling lives through the impact of our work, and our commitment to equity, belonging, inclusivity and diversity plays a foundational role in this mission. It is Fengate’s core belief that having diverse perspectives and experiences enhances the value to our firm, our investors, our stakeholders, and the communities in which we work; therefore, it is our moral imperative to continuously grow and sustain a culture of inclusivity.
Our vision is to ensure EBID is enriching our client service, our investments, and our team, and is foundational to every aspect of business and every interaction at Fengate. It is our responsibility to always be listening to and learning from each other, and consistently improving. We are committed to ensuring all backgrounds and perspectives — including race, ethnicity, culture, nationality, faith, spiritual beliefs, sex, gender identity, sexual orientation, age, and abilities are valued, sought after, and celebrated at our firm. We believe an environment where every team member can be their authentic self is fundamental to the happiness of our people which directly impacts the success of our business.
Our EBID Think Tank is comprised of twenty employees from across the organization and includes four executive sponsors from our executive leadership team. Meetings are held on a quarterly basis and are led by EBID Champions. These are individuals whose roles have accountability to completing the objectives set forth by the EBID Think Tank.
Principles and Objectives
Our efforts to increase EBID within our team are focused on four key objectives:
Enhancing EBID program strategies Increasing transparency on human capital management Enhancing EBID resources for employees
Program and Policy Implementation
Fengate’s EBID program is used to define, track, and lead our approaches to implementing our DEI commitments across the organization.
Supporting our communities’ EBID initiatives
01 | Equitable Opportunities
Fengate believes that by increasing our diversity, we also increase our ability to attract, retain, sustain, and promote our existing talent. We strive to identify and include historically underrepresented candidates in our hiring practices by expanding the reach of our job postings and talent pipelines. We make the effort to remove bias from the recruitment process by making sure that any characteristic protected by law is not and will never be the basis for recruitment and hiring decisions.
1.1 Equal Employment Opportunity
Fengate does not discriminate in employment opportunities or practices based on age, race, color, religion, gender, gender identity, gender expression, genetic information, marital status, ancestry, sexual orientation, national origin, disability, veteran status, or any other characteristic protected by U.S. or Canadian law.
Fengate practices equal opportunities and fair hiring processes when filling positions. We have adopted this policy to ensure all employees and potential candidates are considered through a consistent and fair recruitment process. All parties involved in the recruitment process are committed to identifying and overcome bias in the recruitment process.
1.2 Interview Guides
Interviews are an opportunity to gather helpful knowledge about a potential candidate that cannot be gained from their resume. The key to a good interview is a clear structure. Having a clear framework for interviewing will ensure a reduced bias by focusing on the factors that have a direct impact on performance.
We also ensure that multiple people within our organization either sit in on the interview or conduct their own formal individual interviews so that candidate success is evaluated from different perspectives.
1.3 Annual Self-Identification survey
During our annual engagement survey, Fengate has committed to including a voluntary self-identification survey to have up to date data on the firm’s demographics. The data collected by this survey is a central piece of Fengate’s commitment to EBID. The survey provides completely anonymous information to Fengate that will help us identify areas of opportunity and improvement. The survey results also enable us to benchmark ourselves and monitor our progress with EBID year over year.
1.4 Monitor pay equity and address any disparities
For compliance purposes, Ontario’s Pay Equity Act requires that all public sector employers and all private sector employers with more than 10 employees achieve pay equity by eliminating sex-based wage discrimination and by continuing to maintain discriminationfree wages into the future.
The Chief Human Resources Officer is appointed as Review Officer for this process. The annual Pay Equity Audit (to be consistent with how it appears below) is completed every September by members of the Human Resources department. All findings are documented in the Summary tab of the Pay Equity file for the active year, for future reference and compliance purposes.
The purpose of the Pay Equity Audit is to:
Manage the pay equity process so that it is maintained 1
Alert leadership to potential retroactive liabilities 2
Reduce the risk of a complaint to the Commission 3
Prepare employer in the event that the organization is investigated by the Commission
02 | Onboarding
It is our mandate that all new hires have consistent experience and are provided with training to inform our expectations and values that surround DE&I and their experience at Fengate. We assign the following courses upon hire in accordance with the legislation of the jurisdiction within which the employee resides:
2.1 Unconscious Bias Training
This course tackles one of the most pervasive barriers to inclusion in the workplace: conscious and unconscious bias. In this training, we explore the sources and mechanics of bias, its impact and cyclicality. Employees are provided with strategies they can use to increase awareness and mitigate the impact of bias in the workplace.
2.2 Workplace Violence Prevention
Fengate will not tolerate conduct that threatens, intimidates, or coerces another employee, or a member of the public at any time, including off-duty periods. This includes all acts of harassment, including harassment that is based on an individual’s sex, race, age, or any characteristic protected by U.S. or Canadian laws.
2.3 Accessible Ontario Disability Act
Fengate provides training for its employees and volunteers regarding the Integrated Accessibility Standards Regulation (IASR) and the Ontario Human Rights Code as they pertain to individuals with disabilities. Training will be provided regularly to new employees and as changes to the company’s accessibility policies occur.
2.4 Americans with Disabilities Act
The Americans with Disabilities Act (ADA) is a civil rights law which prohibits discrimination against and ensures equal opportunities for individuals with disabilities. It covers employment, public services, public accommodations, telecommunications, and miscellaneous provisions as they relate to other laws.
2.5 Civil Rights Act
The Civil Rights Act prohibits discrimination based on race, color, religion, sex, or national origin. Title VII specifically addresses employment discrimination, ensuring all employees have equal opportunities in hiring, promotion, and other employment practices.
03 | Training and Education
To support employee development at Fengate, our employees are empowered to identify their strengths, career drivers, and key development areas through training programs and educational resources. Leadership, mentoring, and coaching opportunities are available through the education reimbursement program and special requirements are accommodated through an HR Business Partner.
Fengate will maintain detailed records on all training provided, including dates and the number of employees trained. We will assess engagement and effectiveness, and track improvement over time by collecting feedback from participants and leveraging learning analytics.
3.1 Paradigm Reach Online Platform
Paradigm Reach provides Unconscious Bias training for all employees and is also a hub for a wide array of other DE&I topics. It offers diversity training and micro-learnings for quick education while equipping every employee with relevant skills for fostering inclusion.
3.2 Operating Locations Specific Training
In the U.S., private institutions may implement DE&I programs as they see fit, provided they comply with the Civil Rights Act and the Americans with Disabilities Act (ADA). Accordingly, Fengate operates in adherence with these laws. Training is assigned to ensure compliance with the above legislation, as necessary. Therefore, State or County-specific training in our operating locations is assigned on an as-needed basis.
3.2.1 Texas
The Texas Workforce Commission (TWC) offers various training programs to promote disability awareness and inclusion in the workplace. Fengate’s CHRO may, at their discretion, assign employees DE&I training via the Texas Accessibility Academy (TAA) on topics related to architectural barriers.
3.2.2 Miami
Human Rights and Fair Employment Practices (HRFEP) Division promotes fairness and equal opportunity in employment, housing, public accommodations, credit and financing practices, family leave and domestic violence leave. The Fair Employment Practices (FEP) section oversees diversity management and fair employment programs in MiamiDade country, promoting bias-free work environments. FEP develops and implements policies to ensure diversity and inclusion, investigates discrimination complaints, mediates conflicts, and creates programs to support inclusive workplaces.
At the discretion of Fengate’s CHRO, employees in Miami may be assigned the HRFEPs Diversity Matters E-learning course to increase awareness and sensitivity to diversity issues and provide information on employee rights, responsibilities, appropriate workplace behaviors, and reporting procedures for complaints. Training covers topics for equal employment opportunities, harassment prevention, valuing diversity, and preventing workplace violence. Optional instructor-led training courses include Workplace Civility and Respect (CAR) and Preventing Sexual harassment (PSH).
04 | Partnerships and Community Engagement
Fengate is committed to actively partnering with community organizations that share our commitment to equity, belonging, inclusion, and diversity. We also ensure that our commitments to the community are spread across a variety of organizations servicing the needs of a broad array of individuals and initiatives. Fengate supports our employees in their effort to be involved with and give back to their communities.
4.1 Current partnerships
4.1.1 Gord Downie & Chanie Wenjack Fund: Legacy Space
As part of Fengate’s Legacy Spaces partnership with The Gord Downie & Chanie Wenjack Fund (DWF), an organization that aims to build cultural understanding and create a path toward reconciliation between Indigenous and non-Indigenous peoples, we have created a Legacy Space in our Toronto office’s Growth Boardroom that acts as a permanent physical space dedicated to promoting truth and reconciliation throughout the year.
Dedicated to heightening awareness and providing education about Indigenous history (repeated from above paragraph), our Legacy Space is one of many initiatives our EBID Think Tank has in place as part of our firm’s commitment to promote and advance diversity and inclusion, both within Fengate and the industry more broadly.
Legacy Spaces are safe, welcoming places where conversations and education about Indigenous history — and our collective journey towards reconciliation are encouraged and supported. They also serve as symbols and reminders of the important work each of us needs to undertake, particularly employers, in responding to the Truth and Reconciliation Commission’s 94 Calls to Action. Through an annual investment, this program is an opportunity for organizations such as Fengate to participate in their own reconciliACTIONs, which are simple acts with the power to bring us together in the spirit of reconciliation, sharing, and education.
The vibrant mural by Haudenosaunee artist, Kyle Joedicke, was commissioned through the Art Gallery of Hamilton, and adorns the Legacy Space with an illustration that represents two separate cultures and ways of life, flowing in harmony together, and respecting each other’s differences. With the intention to express a grander sense of community, Joedicke’s artwork incorporates artistic elements from The Seven Grandfather Teachings: Love, Honesty, Truth, Respect, Wisdom, Bravery, and Humility, considered guiding principles and core values of Indigenous people.
Within the room, also found is a didactic panel, and reading materials that act to encourage conversation and provide additional information about DWF and the Legacy Spaces program.
4.1.2 Out Investors
We have partnered with Out Investors, a global volunteer-run organization with a mission to foster connections and inclusiveness within the LGBT+ buyside industry. They achieve this through various programming and events tailored for LGBT+ investment professionals and their allies.
4.1.3 Institutional Limited Partners Association
Fengate is a signatory for the Institutional Limited Partners Association (ILPA) Diversity in Action initiative, and is part of a roster of other limited and general partners who share our commitment to advancing diversity, equity and inclusion in the private equity industry.
05 | Accommodations and Accessibility
We strive to host inclusive, accessible events that enable all individuals to participate. To request an accommodation or for inquiries about accessibility, please contact the Fengate HR team.
5.1 Disability Accommodation
Fengate is committed to complying fully to U.S and Canadian law regarding equal opportunity in employment for qualified persons with physical or mental disabilities. All employment practices and activities are conducted on a nondiscriminatory basis. Our hiring procedures provide persons with disabilities meaningful employment opportunities.
06 | Reporting and Accountability
Reporting and accountability are crucial for advancing diversity, equity, and inclusion (DE&I) within the organization. Regular reporting on DE&I metrics helps track progress, identify areas for improvement, and ensure Fengate’s commitments to DE&I are being met. Accountability mechanisms, such as setting annual objectives and appointing dedicated resources is essential to drive meaningful and sustained change.
6.1 Annual Engagement Survey
On an annual basis, we issue a firmwide inclusion survey to gather feedback regarding diversity and inclusion at Fengate. This is done to inform our ongoing strategy and reference industry benchmarks. This survey asks for employees to self-identify and allows our Human Resources department to monitor and track changes in employee demographics.
6.2 Reporting Violations
Any concerns about violations of or misconduct related to our EBID Policy may be reported in confidence to Human Resources without retaliation. The EBID Think Tank also offers an anonymous feedback form on our internal SharePoint site. Any manager who becomes aware of any possible harassment has a responsibility to escalate the incident to Human Resources. All complaints are investigated, and appropriate disciplinary actions, up to and including dismissal, are taken.
6.3 Annual Review and Governance
This policy has been prepared under the supervision of Fengate’s Chief Human Resources Officer. The policy will be reviewed on an annual basis by the EBID Committee for effectiveness and relevance.
