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HPE Growth Capital

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

HPE wants to contribute to a higher and more stable return through the integration of responsible investment in its investment policy. We believe that sustainability pays off. This does not alter the fact that as an asset manager HPE must properly assess and control foreseeable risk factors and to mitigate these. If ESG factors have an impact on the financial risks and the return of the investments, or on our reputation and the confidence of our clients’ beneficiaries, then we must analyse these factors and integrate them in the investment decisions.

We have an interest in the quality and continuity of the global investment universe. We are independent on a well-functioning financial and social system. Risk and return of the investments are largely determined by well-functioning markets, economics, sectors and companies. Attention to and the encouragement of well-functioning markets is therefore part of our role.

At the same time HPE sees responsible investments as an important expression of this identity and that of our investors. In our policy and its implementation it must therefore be recognizable and verifiable that we focus on clear principles and criteria that reflect responsible investment. In concrete terms, this can mean that HPE will not invest in certain companies or do business with certain parties.

Actions for responsible investment

The translation of the goals of the responsibility has resulted that in our Fund documentation is incorporated explicitly that the portfolio companies shall not be engaged, directly or indirectly, in:

▪        production of and trade in weapons and ammunition

▪        casinos and equivalent enterprises

▪        production of and trade in tobacco and distilled alcoholic beverages and related products

▪        human cloning for reproduction purposes, or

▪        research, development or technical applications relating to electronic data programs or solutions, which

▪        aim specifically at:

(1)   supporting any activity included in the restricted sectors referred to above

(2)   internet gambling and online casinos, or

(3)   pornography, or which are intended to enable to illegally:

(1) enter into electronic data networks, or

(2) download electronic data

When providing financing to the research, development or technical applications relating to (i) human cloning for research or therapeutic purposes; or (ii) genetically modified organisms (“GMOs”), the Fund shall guarantee specific compliance with European Union legislation on GMOs and provide ethical guidelines and/or foresee appropriate monitoring procedures regarding such Investments.

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

02.4. Additional information [Optional].

Our policy is available upon request for our stakeholders.

We do mention ESG and UNPRI briefly on our website.

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.3. Additional information. [Optional]

There is no written policy on conflicts of interest only. Potential conflicts of interest in the investment process will be discussed firstly in the investment committee and thereafter with the Investors Advisory Committee. Also potential conflicts of interest can be discussed with our adviors.

HPE included in the procedures manual the following on general conflict of interests:

"There are various situations in which conflicts of interest could occur, amongst others, between;

Fund II and Fund I when allocating potential investments between the two funds
the GP and the investors of the respective Funds
the GP and the respective Funds itself, or
at the level of employees

Prior to discussing the situations in more detail, more in general, the CO and the CFO do periodical checks regarding the several interests involved (e.g. the interests of the different investors). Due thereto it is ensured, to the fullest extent possible, that all forms of conflicts of interests are detected and are processed in order to prevent any negative effect on the interests of the investors of the respective Fund.

Situations may arise where it is not possible to prevent a conflict of interest posing a risk to investors’ interests through the conflict of interest’s policies and tasks executed by the employees, CFO and the General Counsel of HPE. In such a situation, HPE shall disclose the general nature or the sources of the conflicts of interest to the investors and develop appropriate policies and procedures to mitigate the risk to investors’ interests prior to undertaking the business which has caused the conflict of interest to arise."


SG 04. Identifying incidents occurring within portfolios (Private)