The Fund promotes environmental and/or social characteristics but does not have as its objective sustainable investment. The environmental and/or social characteristics promoted by the Fund are protecting our environment, improving our society, growing our economy and valuing our people.
To promote these characteristics, the Fund applies two core elements:
- Exclusion: avoiding companies whose activities or practices the Investment Manager determines are incompatible with its investment screening process
- Inclusion: investing in companies that the Investment Manager believes can support or enhance the Fund’s promoted environmental and/or social characteristics
The Investment Manager uses a qualitative, judgement‑based approach to assess companies before investment and to monitor them during ownership. Information used for this assessment is drawn from:
- Publicly available sources, including financial statements, statutory filings, industry publications, and other materials the Investment Manager considers relevant;
- Direct engagement with portfolio companies, including discussions with management teams to obtain additional information where public data is limited; and
- Supplementary third‑party data, where available and relevant.
Because the Fund invests in small and growth‑stage UK companies, sustainability information is often limited or inconsistently reported. The Investment Manager therefore places significant emphasis on direct engagement with management to understand operational practices and progress against environmental or social objectives.
Throughout the life of the investment, the Investment Manager monitors whether companies continue to align with the Fund’s promoted characteristics and engages proactively with management teams to encourage improvements in identified sustainability areas.
The Investment Manager will only invest in companies it believes follow good governance practices, including sound management structures, strong employee relations, responsible remuneration arrangements, and appropriate tax compliance. The Investment Manager may exclude companies from the portfolio where it believes governance practices are materially lacking or inconsistent with these expectations.
A minimum of 90% of the Fund’s investments will align with the binding elements of the Fund’s environmental or social characteristics. These investments consist entirely of unlisted UK private companies. The remaining proportion may consist of cash or cash‑equivalent holdings for liquidity and portfolio management purposes.
To measure how the environmental and social characteristics of the Fund are met, the Investment Manager applies a structured methodology that combines screening, qualitative assessment and ongoing monitoring. This approach is adapted for size, scale and nature of the companies in which we invest, where sustainability-related information is often more limited.
Due to the nature of UK private markets, sustainability data availability is often limited. Most UK private companies are not subject to mandatory sustainability reporting frameworks and choose for themselves which sustainability factors to disclose. As a result:
- Publicly available sustainability reporting is often incomplete or inconsistent;
- Small and growth‑stage companies may have limited internal resources to produce detailed ESG information; and
- Third‑party data providers may rely on estimated or modelled data, which can vary due to differing methodologies.
While the Investment Manager prefers reported data where available, the limited and sporadic nature of issuer disclosures means estimated data may be required in certain cases. Where third‑party data is used, the Investment Manager assesses the provider’s methodology and treats the information as an input into its own independent judgement rather than a determinative source.
Sustainability factors form a holistic and embedded part of the Investment Manager’s due‑diligence approach. These factors are considered alongside commercial, operational, and financial considerations where the Investment Manager believes they may influence risk‑adjusted returns. This integrated approach ensures sustainability issues are evaluated as part of investment selection, risk management, and value‑creation planning.
No reference benchmark has been designated for the purpose of attaining the environmental or social characteristics promoted by the Fund.