Sustainable Investment Policy

Effective Date: December 2025

 

Vista’s Commitment to Sustainable Investment Practices

As a General Partner, our goal is to deliver differentiated returns for our investors by driving growth and creating long-term value in enterprise software businesses. We believe sustainable investment and operating practices contribute to this goal. For this reason, and consistent with our fiduciary and legal obligations, we maintain programs and policies to address material sustainability risks and opportunities across our firm’s operations and investments.

Our Sustainable Investment Policy (the “Policy”) underpins our approach to managing investment risks and opportunities and reflects our commitment to creating value for our stakeholders. Consistent with our goal of maximizing risk-adjusted returns for our investors, Vista is a signatory to voluntary, industry-led initiatives, which help define and operationalize our sustainability engagement efforts.

• The Principles for Responsible Investment (PRI) is a UN-supported network of investors promoting sustainable investment practices through the incorporation of sustainability factors into the investment lifecycle.¹ Vista became a signatory in 2020.
• The ESG Data Convergence Initiative (EDCI) is an open partnership of private markets stakeholders committed to streamlining the private investment industry’s historically fragmented approach to collecting and reporting sustainability data. The goal of EDCI is to create a critical mass of meaningful, performance-based sustainability data from private companies by converging on a standardized set of sustainability metrics for private markets.² Vista became a signatory in 2021.

 

Scope and Limitations

The Policy intends to reflect a general framework guiding our approach to identifying and managing material³ sustainability risks and capturing sustainability opportunities across Vista’s internal operations and investment strategies, including our private equity, permanent capital and private credit strategies; in certain cases, this document draws distinctions between our sustainable investment approach within various investment strategies.

Given our focus on enterprise software, data and technology-enabled companies, we have identified certain material sustainability risks and opportunities that we believe to be important investment considerations. Our approach to incorporating these considerations is dependent on our influence over the management of each investment which may vary depending upon the fund, investment structure and terms, and our engagement will be tailored accordingly.

For the avoidance of doubt, fund-specific application of the Policy will be set out in our fund governing documents and in applicable regulatory disclosures (governing documentation). In the event of conflict between the Policy and fund documentation, the governing documentation should take precedence.

In cases where Vista determines it has limited ability to conduct due diligence or to influence and control the consideration of sustainability issues in connection with an investment, whether at the portfolio company-level or at the Fund-level, Vista will only apply those elements of the Policy that it determines to be practicable. Examples of such cases at the portfolio company level include where Vista is a minority shareholder, has limited governance rights or where other circumstances affect Vista’s ability to assess, set or monitor sustainability-related risks and opportunities. Examples of such cases at the Fund-level include a jointly managed fund, a separate account where the underlying investor maintains significant influence over investment decisions, where Vista is a lender with no indicia of influence or control, or where Vista holds a small, passive public equity interest.

 

Roles and Responsibilities

Vista understands the important role sustainable investment practices play in driving long-term value and success. As such, we strive for broad understanding and accountability in applying these principles across our organization.

• Our Executive Committee and Operating Committee are responsible for promoting Vista’s Sustainable Investment Policy and for ensuring that it is implemented at the firm and across each of our investment strategies (commensurate with Vista’s level of influence and control).
• Our investment committees oversee the integration of these principles into our investment processes and are accountable for ensuring sustainable investment practices across our private equity and permanent capital Funds and with our professionals.
• Vista has cross-functional Sustainability Committees for each of its platforms: Vista Equity Partners and Vista Credit Partners. These Committees typically meet quarterly to oversee integration of relevant sustainability matters into their respective platforms and implementation of Vista’s Sustainable Investment Policy.
• Our dedicated Sustainability team works cross-functionally with our investment teams, our Value Creation team, subject matter experts, external partners and private equity and permanent capital portfolio companies to drive our principles into action and to ensure alignment with the Policy. Additionally, our Sustainability team is responsible for coordinating with our external partners to conduct pre-investment due diligence, which may include an assessment of material sustainability risks and opportunities.
• Our investment teams are responsible for incorporating those findings into our investment decision-making process, when the considerations are material to achieving our investment thesis.
• Our Value Creation team works with our private equity and permanent capital portfolio companies’ management teams in implementing a value creation plan that may consider material sustainability risks and opportunities identified in diligence and continuing to monitor such sustainability risks during the ownership period.
• Our Legal & Compliance team provides oversight of sustainability-related fund formation, diligence, fund disclosure and exit processes and seeks to ensure that we meet our regulatory obligations and commitments to Fund investors.
• Board members at majority-owned private equity and permanent capital portfolio companies are familiarized with sustainability topics to encourage the discussion and appropriate prioritization of sustainability topics at quarterly board meetings.
• Our Capital & Partner Solutions team engages with our Fund investors on our sustainable investment practices and works with our Sustainability team to meet our reporting obligations to our Fund investors.

 

Sustainable Business Practices

Vista is committed to implementing sustainable investment practices that are specific to our focus on enterprise software investing. In addition to our investment portfolio, our firm-level sustainability efforts encompass:

Internal Operations

• Vista maintains a Code of Ethics that requires employees to conduct their business dealings with honesty, integrity, fairness and respect for others.
• We understand our fiduciary duty to our clients and seek to mitigate conflicts of interest and encourage transparency in our business practices.
• Vista is committed to measuring and managing the greenhouse gas (GHG) footprint of its internal operations.

People

• Vista has a Diversity and Inclusion program and policy⁴ that seeks to foster an inclusive corporate culture, as well as attract and retain talent.
• Vista fosters community engagement by encouraging employees to support their communities through both charitable giving and volunteer support.

Technology

• Vista believes in the transformative power of technology and software to advance positive sustainability outcomes and seeks to leverage software solutions for internal sustainability measurement, management and reporting.
• Vista is committed to protecting the privacy and confidentiality of our stakeholders’ personal and corporate information in our operations and those of Vista’s portfolio companies.

 

Incorporating Sustainability in Our Investment Process

Vista seeks to integrate material sustainability considerations during the investment life cycle with engagement approaches designed to match Vista’s influence over the investment.

During pre-investment due diligence, Vista leverages a sustainability framework to analyze material sustainability risks and opportunities in potential platform private equity and permanent capital investments. For Vista Equity Partners (VEP), Value Creation team subject matter experts conduct an in-depth review of the company’s technology, cybersecurity and data privacy practices before platform private equity and permanent capital investments. Additionally, we may engage law firms and consultants to identify and assess material sustainability risks and opportunities relevant to the target. Significant findings are generally communicated to the investment committee and management teams and, where applicable, are included as part of the company’s 100 days list.

We seek to monitor material sustainability risks and opportunities and, when appropriate, engage with the boards of directors and management teams throughout our ownership period. We will strive to make material sustainability updates available to our Fund investors, in accordance with our fiduciary duty and contractual and regulatory reporting obligations.

 

Sustainability Focus Areas

To integrate sustainability considerations into Vista’s private equity and permanent capital investment processes, Vista has created a bespoke framework that encompasses specific sustainability focus areas important to enterprise software companies.

This framework draws upon global sustainability standards and serves to highlight material sustainability risks and opportunities throughout the investment life cycle.⁵ Vista aims to review these focus areas in light of current events and macrotrends. Areas include (but are not limited to):

Environmental

• Greenhouse gas emissions management
• Climate risk management
• Resource management
• Product innovation to support positive environmental outcomes

Social

• Diversity and Inclusion
• People, culture and community
• Employee engagement and safety
• Human rights
• Customer well-being and safety
• Philanthropy and community engagement
• Product innovation to support positive social outcomes

Governance

• Data privacy
• Cybersecurity
• Responsible AI
• Ethics and compliance
• Anti-bribery and corruption
• Sustainable supply chain management
• Reporting and transparency
• External board membership
• Product innovation to support positive governance outcomes

 

Private Equity and Permanent Capital Investments

We seek to systematically engage with our majority-owned⁶ portfolio companies to encourage sustainability integration within the business. Our engagement tactics, in collaboration with investment teams, the Value Creation team, company management and board members, may include the following:

• Identification of material sustainability risks and opportunities during investment diligence for platform acquisitions and, when deemed appropriate by Vista, substantial add-on acquisitions.
• Annual Sustainability Assessment to determine current sustainability practices and program maturity.
• Greenhouse gas measurement and management.
• Individual meetings with company management to build a sustainability work plan.
• Providing appropriate resources to support the achievement of sustainability milestones in furtherance of strong business practices.
• Convening of portfolio company leaders in a “Sustainability Leadership Council” to share best practices and encourage peer discussion.
• Hands-on support for sustainability value creation projects where appropriate and requested by the company, such as to support a company on the creation of a sustainability policy or a work plan for compliance with a sustainability regulation.
• Monitoring of sustainability progress and, to the extent deemed appropriate by Vista, support for companies wishing to communicate such progression during their IPO, exit and/or recapitalization processes.
• Resources to facilitate the discussion of sustainability initiatives during board meetings.

Within the Vista Equity Partners (VEP) platform, Vista may possess active or passive public equity interests. As such, Vista maintains a proxy voting policy, under which Vista may consider, among other factors, the impact of certain environmental or social factors on overall investment performance, when voting a proxy. As a fiduciary, it is Vista’s policy to vote proxies in the best interests of its Fund investors.

 

Private Credit

For substantial private credit⁷ investments, where feasible, Vista’s Sustainability team collaborates with assigned points of contact for sustainability within Vista Credit Partners to incorporate sustainability considerations into pre-investment due diligence. Specifically, Vista applies a software tool that combines AI and advanced machine learning with human intelligence to identify material sustainability risks and incidents in target investments. Vista also integrates sustainability questions into the legal diligence process, where relevant and feasible. Material diligence findings are shared with investment professionals and may be considered within the investment decision-making process.

Post-investment, Vista leverages the software tool to monitor its full investment portfolio for material sustainability incidents. Material incidents may be escalated to the Vista Credit Partners Investment Committee for further discussion and remediation.

 

Transparency and Reporting

Through our commitment to the PRI, Vista plans to report on its sustainable investment approach and performance regularly. Since 2023, relevant disclosures have been made publicly available on the PRI website. Vista utilizes a software platform to track private equity and permanent capital portfolio company sustainability engagement. The Sustainability team seeks to report progress and other data gathered from this platform to leadership and relevant stakeholders where feasible and appropriate.

This Policy is subject to change and is intended to be reviewed periodically by Vista’s Sustainability Committees. Further, this Policy shall supersede and replace any prior Policy and shall cover on a going forward basis, subject to the limitations discussed herein, Vista’s existing and future investments.

 

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1. PRI website, www.unpri.org; 2. EDCI website, https://www.esgdc.org; 3. For the purposes of this Sustainable Investment Policy, “material” sustainability issues are defined as those issues that Vista determines have – or have the potential to have – a material impact on an organization’s going-forward ability to create, preserve or erode economic value of that organization and its stakeholders; 4. Vista Equity Partners Diversity Policy; 5. the Global Reporting Initiative (“GRI”), the Sustainable Accounting Standards Board (“SASB”) standards governed by the International Sustainability Standards Board, and the United Nations-supported Principles for Responsible Investment (“PRI”); 6. And when deemed appropriate by Vista’s Sustainability team, minority-owned investments; 7. “Substantial private credit” currently refers to FounderDirect and sponsor-backed credit opportunities pursued by Vista’s Credit Platform, where feasible. More information on Vista’s FounderDirect strategy can be found here: www.vistaequitypartners.com/credit. Not included within this category of investments are other forms of private debt, broadly syndicated loans, and other tradeable investments. The determination of whether an investment is “substantial” shall be made in the sole discretion of Vista and is subject to change.

Any sustainability or impact goals, commitments, incentives, and initiatives outlined in this Sustainable Investment Policy are purely voluntary, are not binding on investment decisions and/or Vista’s management of investments and do not constitute a guarantee, promise or commitment regarding any actual or potential positive impacts or outcomes associated with investments made by funds managed by Vista unless otherwise specified in the relevant fund documentation or regulatory disclosures made pursuant to Regulation (EU) 2019/2088 (SFDR). Any such goals, commitments, incentives, or initiatives referenced in any information, reporting or disclosures published by Vista are not being promoted and do not bind any investment decisions made in respect of, or stewardship of, any funds managed by Vista for the purposes of Article 8 of Regulation (EU) 2019/2088 on sustainability-related disclosures in the financial services sector unless otherwise specified in the relevant fund documentation or regulatory disclosures made pursuant to the SFDR.

This document is intended to provide general information regarding Vista’s sustainability strategy and not for the purpose of soliciting investors for any Vista Fund. Under no circumstances should the information provided be considered an offer to sell, or a solicitation to buy, any security. Such offer or solicitation may only be made to accredited investors and qualified purchasers pursuant to the current offering documents of the relevant Vista Fund. The information provided is strictly confidential and may not be reproduced or disseminated to any third parties without the written consent of Vista. Certain of the transactions listed above were signed and agreed to expected to close subject to customary closing conditions and regulatory approvals (such as a shareholder vote). The past performance of previous Vista Funds and portfolio companies is not necessarily indicative of future results. ©2025 Vista