API Sustainability Policy

American Postal Infrastructure, LLC (“API”) has adopted an Environmental, Social and Governance Policy (“ESG”) to formalize our longstanding view of considering all stakeholders in our investment and management decisions. We hold ourselves to the highest business and ethical practices.


The purpose of this policy is to define API’s approach to integrating the consideration of environmental, social, and governance (“ESG”) risks and value creation opportunities into investments made through its infrastructure fund. API commits to improving the communities in which it invests, and to enhancing the role of the United States Postal Service in its communities. As such, API considers material ESG issues, as detailed in API’s Investment Committee Criteria, during its due diligence and in the monitoring of portfolio investments, to the extent reasonably practical under the circumstances, subject to the fiduciary responsibility of API. For the purposes of this policy, “material” ESG issues are defined as those issues that API, in its sole discretion, determines to have, or the potential to have, a direct substantial impact on an organization’s ability to create, preserve, or erode economic value, as well as environmental and social value for itself and its stakeholders.


This policy will apply to all infrastructure investments considered by the API Investment Committee following the date hereof and will be interpreted in accordance with local laws and regulations.

Roles and Responsibilities

API’s Investment Committee is responsible for ensuring that consideration of ESG issues is integrated into investment decisions. Where additional subject matter expertise is needed, API utilizes external resources as relevant and necessary.


Subject to the scope described in Section 2, API seeks to:

  1. Consider environmental, public health, safety, and social issues associated with target investments when evaluating whether to invest in a company or entity, as well as during the period of ownership.
  2. Be accessible to, and engage with, relevant stakeholders as appropriate.
  3. Use governance structures and committees of the Board of Directors that provide appropriate levels of oversight in the areas of audit, risk management, investment parameters, potential conflicts of interest, and compensation.
  4. Remain committed to compliance with applicable national, state, and local labor laws; support the payment of competitive wages and benefits to employees; and provide a safe and healthy workplace.
  5. Provide timely information to API’s limited partners on the matters addressed herein, and work to foster transparency about API’s activities.

ESG Integration in Infrastructure Investments

API will seek to integrate the consideration and thoughtful management of ESG issues throughout the investment cycle.


To ensure the integration of ESG considerations in the pre-investment phase of infrastructure investments, and subject to API’s determination of what is reasonable and appropriate, API will:

Undertake ESG Due Diligence:

API will conduct due diligence on ESG elements as are outlined in the Investment Committee Criteria; this due diligence may include third party assessments as deemed applicable.

Documentation: In cases where ESG-related issues are considered during the due diligence process, API will document, for internal use, the issues considered, findings, and next steps, if any.

During Investment:

To manage ESG risks and value creation opportunities in its infrastructure investments post-investment, and subject to our determination of what is reasonable and appropriate, API will:

Monitor Progress:

Where there are material issues identified during the diligence process, include the management of these issues in a 100-day plan post-close, or otherwise monitor ongoing progress on ESG issues, as applicable. Process improvement efforts will be initiated, as applicable.


In cases where material ESG-related risks and opportunities are being monitored or managed, API will document, for internal use, the issue, progress, and next steps, if any.

Transparency and Stakeholder Engagement

We will seek to be transparent in our approach to incorporating ESG considerations in our infrastructure investments by reporting annually on its progress and outcomes at the fund level. The format of this reporting may vary among written public reports, verbal informal reports, or confidential fund or asset-level reports to API investors. Where appropriate, throughout the investment cycle we will seek to actively engage relevant stakeholders to make informed decisions that may affect these stakeholders.

United Nations-Supported Principles for Responsible Investment (“PRI”)

API is a signatory to the United Nations-supported PRI. The PRI Initiative is an international network of investors working together to put the six following principles for responsible investment (the “Principles”) into practice:

  1. Incorporate ESG issues into investment analysis and decision-making processes.
  2. Be active owners and incorporate ESG issues into the firm’s ownership policies and practices.
  3. Seek appropriate disclosure on ESG issues by the entities in which the firm invests.
  4. Promote acceptance and implementation of the Principles within the investment industry.
  5. Work together to enhance the firm’s effectiveness in implementing the Principles.
  6. Report on the firm’s activities and progress towards implementing the Principles.

Policy Review

This policy will be reviewed and updated, as necessary, regularly at API’s Board of Director meetings.