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Freeman Spogli & Co

PRI reporting framework 2018

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

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, and how they consider ESG factors and real economy impact.

Freeman Spogli is committed to promoting an organizational culture that encourages responsible investment. In addition to complying with ESG criteria that are required by law, the Firm has implemented a fluid investment policy that balances the best interests of our investors as a whole, the particular objectives the Firm sets for each of its portfolio companies and applicable ESG factors that may arise in connection with our potential investments.

In evaluating a transaction, each member of the Firm is responsible for analyzing, evaluating and reviewing the potential ESG implications of an investment. When the Firm identifies that an investment may have aspects that may not meet its ESG standards, it will often hire a third party advisor to review and assess those aspects of the transaction. With regard to portfolio investments, the Firm seeks opportunities to promote ESG responsibility and awareness, including environmental stewardship, consumer protection, human rights and diversity.

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


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.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Indicate if your organisation’s investment principles, and overall investment strategy is publicly available

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.

Transactions shall be reviewed by the Investment Committee of Freeman Spogli Management Co., LLC, the general partner of Freeman Spogli.  The current members of the Investment Committee are the eleven partners of Freeman Spogli Management Co., LLC.  All investment transactions by the Funds must be approved by all of the members present at a meeting of the Investment Committee at which a quorum is present (a majority of members) after considering the applicable due diligence findings.  The Investment Committee may also approve investment transactions by written consent based on the same vote that would have been required to authorize such action at a meeting held in person.  Upon receipt of the Investment Committee’s approval to purchase, the Chief Compliance Officer or his designee will conduct a review to verify that the transaction is in the best interest of the applicable Fund and is consistent with that Fund’s investment strategy and restrictions.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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