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Dalmore 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]

Dalmore is determined to protect and enhance its reputation, to build brand value and to promote high standards of business ethics and integrity. As a result of this commitment, Dalmore adopted an ESG policy in November 2013 that applies to all employees. Specifically, Dalmore is committed to promote within its day-to-day activity human rights, labour/workplace ethics, the environment and anti-corruption.
The ESG policy sets out procedures to be followed by Dalmore deal teams. Some principles are laid out below:
i) Each deal should have a named deal sponsor with lead responsibility for supervising the relevant deal team and for implementing the CR policy in individual cases;
ii) Deal teams must first of all apply a "materiality test". Even though, in any given case many CR issues will not be material, Dalmore's role means that all social and environmental issues are potentially material and might have an impact on the company's reputation. It is therefore imperative they are given regular consideration in the investment process, from initial appraisal through to exit. Deal teams should regularly consult the policy and seek appropriate guidance.
1. Material CR issues (red) - directly affecting value-chain activities, making it mandatory to consult with Dalmore partners on ESG issues at each stage of the investment process.
2. Potentially Material CR Issues (amber) - affecting the background climate or competitive environment for doing business. Issues should be highlighted to Dalmore partners.
3. CR Issues Not Material Commercially or Reputationally (green) - no flagging required to Dalmore partners though deal teams must continue to operate with reference to ESG policies where these are relevant and complete the standard declaration (see below).
iii) Initial and further investments, as well as divestments, categorised as "red" or "amber" must be reviewed by Dalmore's chief executive before proceeding to final approval. In some cases, deal teams may judge that CR issues are more material than the matrix suggests (e.g. by treating them as red, rather than amber) but they should never treat them as less material (e.g. green rather than amber).
iv) Initial and further investments must be approved by the deal sponsor.
v) Deal team members should maintain a clear audit trail of accountability and evidence-based decision-making on the CR aspects of deals in order to develop corporate and good practice and minimise errors of judgement.


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].


SG 03. Conflicts of interest

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

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Dalmore is organised so as to minimise potential conflicts of interest.  We are an independent fund manager, which focuses solely on making and managing investments in lower volality infrastructure assets for institutional investors. 

In addition to our fiduciary duties to our funds, any potential conflicts of interest are referred to the relevant Advisory Committee for determination

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Not Completed)


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