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TowerBrook Capital Partners

PRI reporting framework 2019

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, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

TowerBrook's values stand at the core of our mission and are at the foundation of our belief in responsible ownership. The full text of our Purpose Statement, our Mission Statement, and our Responsible Ownership Statement are publicly available on our website (  Our Responsible Ownership Statement covers planet, people, partnership, performance, transparency, and the management of the responsible ownership program.

We identify and consider responsible ownership risks and opportunities throughout our investment process. We are prepared to invest in imperfect businesses in order to help build them into better businesses. There are some areas we specifically exclude: we will not invest in companies whose business involves tobacco, armaments or sexual exploitation: and we will not invest in companies that we know are involved in violations of internationally recognised human rights or exploitative, discriminatory or harmful practices without a plan for remediation. In addition to our commitment to comply with all applicable laws and regulations, we strive to achieve the highest standards of ethical conduct in our own firm and expect our portfolio companies to do the same.

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]

TowerBrook takes steps to ensure that our Responsible Ownership Statement and our corresponding practices are understood and shared across the TowerBrook team, our portfolio companies, key service providers and other stakeholders. As such, Responsible Ownership is an explicit component of the TowerBrook Playbook. The Responsible Ownership Statement is also shared with our limited partners and senior management of our portfolio companies and other investments. In addition, our Responsible Ownership Statement and strategy is captured in the Chair Welcome Pack provided to every portfolio chair. TowerBrook keeps the Responsible Ownership Statement, and our monitoring of the ways in which it is implemented, under continuous review. TowerBrook's Responsible Ownership Statement is reviewed at least once annually by the Responsible Ownership Committee and by the Risk and Compliance Committee.   TowerBrook revised our Responsible Ownership Statement in 2018.

This Responsible Ownership Statement applies to all private equity investments made by TowerBrook for which TowerBrook has control or significant influence ("portfolio companies"). In cases where TowerBrook is a minority investor, where other circumstances impact TowerBrook's ability to assess, set, or monitor ESG-related performance goals, or where we identify material ESG issues that cannot reasonably be addressed, we may not necessarily be able to fully implement the Responsible Ownership Statement, but will make reasonable efforts to encourage consideration of relevant ESG-related principles by the investee company.

01.6. Additional information [Optional].

I confirm I have read and understood the Accountability tab for SG 01 I confirm I have read and understood the Accountability tab for SG 01

SG 01 CC. Climate risk

01.6 CC. Indicate the climate-related risks and opportunities that have been identified and factored into the investment strategies and products, within the organisation's investment time horizon.

TowerBrook seeks to conduct robust reviews of potential climate-related issues early in the investment process.  Investment professionals reviewing potential opportunities which present climate-related issues, or which impact industries which could reasonably present climate-related issues, must discuss any such issues with TowerBrook's Transaction Committee at an early stage in the investment consideration process. Materiality of climate-related issues are evaluated on a case-by-case basis. TowerBrook also seeks to engage with its preferred ESG consultants at an early stage in the investment consideration process to identify climate-related risks and opportunities.  Teams also partner with the relevant portfolio companies to resolve any given climate-related issues and escalate to the executive team where needed.

TowerBrook is currently working to identify and track metrics across our portfolio to measure our carbon footprint.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

01.9 CC. Indicate whether the organisation publicly supports the TCFD?

Explain the rationale

While TowerBrook endorses the general principals behind the TCFD, we are still evaluating the initiative and considering whether we will publicly support it.  

01.10 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.

01.11 CC. Describe how and over what time frame the organisation will implement an organisation-wide strategy that manages climate-related risks and opportunities.


1.12 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.

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. Additional information [Optional].

TCP's Responsible Ownership Report was published in November 2018 and is available on our website. TCP intends to publish a Responsible Ownership Report going forward on an annual basis.

TowerBrook became a certified B Corp in February 2019.  All Certified B Corps share their B Impact Report publicly on The B Impact Report is the summary of a company's scores on the B Impact Assessment by category and contains no question-level information.  TowerBrook’s B Impact Report is available on: 

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.

It is TowerBrook's policy is to allocate investment opportunities between its private equity funds and structured opportunities funds in a manner that, over time, is fair and equitable. TowerBrook has implemented an Investment Allocation Policy which presents factors and circumstances that TowerBrook considers to be relevant to the allocation determination. Allocation is discussed by the deal teams during the preliminary stage of an investment during the weekly firmwide team meeting, and preliminary allocation is noted on the deal sheet summarizing each potential transaction.  Allocation is also considered by the relevant Investment Committee prior to the final approval of an investment. A summary of the factors supporting the ultimate allocation of an investment opportunity are summarized in a written addendum to the final IC memo for each transaction and presented the IC for discussion prior to approval.

03.3. Additional information. [Optional]

TowerBrook has an Allocation Committee (the "AC") to address potential conflicts of interest between the private equity investment strategy and the structured opportunities investment strategy. The AC determines the parameters of investment allocations between the two strategies, reviews the allocations and resolves any conflicts of interests that may arise and cannot be solved by the TSO Investment Committee and/or the PE Investment Committee. The AC also assesses the effectiveness of TCP's investment allocation policies and procedures. The AC is co-chaired by TowerBrook’s Co-CEOs, Ramez Sousou and Neal Moszkowski, and its other members include TowerBrook Managing Directors Filippo Cardini, Glenn Miller, Matthew Gerber and Abrielle Rosenthal. The AC meets at least once annually, and conducts a look-back analysis on the allocation of all transactions that have closed during the preceding year.

The Limited Partner Advisory Committee of each fund also reviews any matters involving a potential conflict of interest presented by the General Partner.

TowerBrook's also has put into place a written Conflicts Policy, which can be found in the Compliance Manual and Code of Ethics, which is certified by all team members on a quarterly basis. Conflicts of interest that may arise among the various individual and organizations comprising TowerBrook, the TowerBrook Funds and other affiliated entities are monitored on a continuous basis by the CCO and TowerBrook's legal department. A written conflicts register is maintained, which is reviewed annually on a formal basis by TowerBrook's legal department and assessed periodically by TowerBrook's Risk and Compliance Committee. Each team member is required to disclose upon joining, and as applicable thereafter, all outside commitments that involve a substantial time commitment, or which could otherwise present an actual or perceived conflict of interest. The CCO also holds a one-to-one discussion with each team member at least annually to discuss any conflicts of interests relating to such person's outside activities. A summary of such discussions, as well as a risk assessment of the outside activities of each partner and employee, is presented to TowerBrook's Risk and Compliance Committee periodically for review and approval.

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within portfolio companies.

04.2. Describe your process on managing incidents

TowerBrook’s controlled portfolio companies have board committees which are responsible for managing incidents that may arise. TowerBrook has representation on the boards of all of its controlled portfolio companies, and would therefore be aware of and input into this process. Material incidents would also be reported to TowerBrook by management as promptly as possible.