SEAF Funds do not invest in any entities whose principal business involves the manufacture, supply of, or other activities in the following areas:

• Tobacco or tobacco products;
• Armament productions or where 25 percent or more of the total production output or turnover of the portfolio company is derived from military-related activity;
• Beverages with an alcoholic content exceeding 15 percent;
• Casino or companies where the principal source of income is gambling;
• Speculative investments in real estate or commodities;
  Immoral and illegal activities; and
• Investments that are harmful to the environment.

In addition to the above list, there might be other activities or businesses, investments which are restricted, limited or subject to special regulations, depending on specific investment policies, guidelines or other principles adopted by Investors in SEAF Funds.

SEAF has the following main investment objectives:

Business Objectives
Each SEAF Fund operates on a commercial basis. Therefore, the companies in which SEAF Funds invest must pass the most rigorous standards of business and risk assessment. Our Investment Officers focus strictly on businesses with attractive underlying fundamentals that derive competitive advantages from their location in, or association with, underserved communities. As SEAF's goal is to realize a good return for limited partners, businesses must also have visionary entrepreneurs and management teams that have the ambition to grow and succeed in an increasingly competitive global economy.

Private Enterprise Orientation
SEAF Funds focus on private enterprise investment . They will not participate in the internal political and governmental workings of countries including reform movements or demonstrations. SEAF is committed to the concept that the best way to help emerging market countries around the world achieve growth is  through successful investments into local private enterprises.

Local Enterprise Focus
SEAF Funds concentrate their investing in local businesses that have good prospects of being commercially viable and profitable. Moreover, SEAF Funds invest in businesses that are capable of meeting international competition while at the same time creating jobs, increasing exports and leveraging the comparative advantages of the particular countries.

Environmentally Responsible
The investments of each SEAF Fund are expected to leave the local physical environment in similar or better shape than existed prior to the investment. Funds will work diligently to encourage its portfolio companies to recognize that good environmental policies are also good business policies, particularly in the long run.

Socially Responsible
SEAF Funds will not invest in companies that do not operate in accordance with the best international standards of business ethics. Portfolio companies are expected to operate their enterprises in a transparent manner and in full compliance with all applicable laws, rules, regulations and decrees effective in the counties in which they do business.

Anti-Corruption
SEAF's mission as well as its duty to investors means that it must act to minimize corruption and to act as responsibly as possible in its investing decisions. In accomplishing this goal, SEAF follows the guidelines set by both the US government and multi-lateral organizations. As an entity based in the United States, SEAF is obligated by law to obey the Foreign Corrupt Practices Act. SEAF internal standards regarding any manifestation of corrupt practices, such as bribes, gifts, business courtesies or gratuities, form part of the Policy of Conflicts of Interest and Compliance with Law.

Conflicts of Interest & Compliance
SEAF expects the highest integrity from each of its directors, officers, employees and consultants and has created a detailed policy regarding conflicts of interest and issues of compliance. The policy is meant to guide all professional and business activities in which SEAF is engaged, particularly those actions relating to investments in portfolio companies. The Policy sets forth standards for business conduct at SEAF and is intended to guide the covered party in making business decisions to ensure that SEAF achieves its mission.

A formal process is used to regularly populate a pipeline with invest-able leads, with increasingly greater due diligence applied as potential portfolio companies candidates are 'distilled' through the analyses.

Search/ Screen and Lead Stages - Each SEAF Fund takes a proactive approach in identifying attractive investment opportunities by focusing on industries that predominate in underserved economies and intensively studying those industries to identify businesses and management teams in which to invest
Potential and Prospect Stages - Each SEAF Fund spends a considerable amount of time and resources investigating the finances, management, operations and market of each prospective portfolio company prior to consummating an investment. When an investment is first proposed, the Investment Officer will use a screening process to determine if the business and investment opportunity meet SEAF's social and financial return criteria.
Candidate Stage - With a thorough understanding of the business, and after having fully tested the investment thesis, Investment Officers will devise an investment structure affording the Fund with the opportunity to exert significant influence over the direction and management of its portfolio companies. Each SEAF Fund will attempt to limit downside risk in appropriate situations by obtaining a senior level or a secured position on an absolute return basis and deploying leverage prudentially through the use of conservative capital structures. The Investment Officer will work with management to devise aggressive growth and profitability goals in developing investment structures. In addition, the Investment Officer will predicate the financial analysis on conservative and credible operating and financing plans. Each Fund's legal documents will generally be structured to include the necessary provisions, such as, corporate covenants and controls which will allow SEAF to govern key strategic decisions regarding capitalization, acquisitions, divestitures, capital expenditures, remuneration, management changes and exits; protective features, etc.
Approval Stage - Consummating investments in small, privately held businesses is a complex process. Once the management and shareholders of a business accept an initial transaction proposal, the Fund will prepare, negotiate and execute legal documentation to evidence the investment. The fund's Investment Review Committee (IRC) will then review the proposal and provide a disposition. This could include the setting of milestones to drive the disbursement process.

Once the financing is completed, the Fund will set out to implement its investment thesis, centered on accelerating the growth and profitability of the business.