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Pantheon Ventures

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.

Pantheon is a signatory of the Principles for Responsible Investment (“PRI”) and has used the following six principles as a framework to develop its ESG policy across all its investment activities.

  • We will incorporate ESG issues into investment analysis and decision-making processes.
  • We will be active owners and incorporate ESG issues into our ownership policies and practices.
  • We will seek appropriate disclosure on ESG issues by the entities in which we invest.
  • We will promote acceptance and implementation of the Principles within the investment industry.
  • We will work together to enhance our effectiveness in implementing the Principles.
  • We will each report on our activities and progress towards implementing the Principles.

We review our continued adherence to these principles on an annual basis through evaluating activities we have undertaken in each year and identifying ways in which we can enhance our ESG risk management.

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]

Pantheon is driven by the conviction that addressing ESG issues is a crucial part of investment risk management; and effective mitigation of these issues can have a material impact on value creation in private equity, infrastructure and real asset investments. We believe that mitigating ESG risks strengthens downside protection for investment returns and enhances investor reputations, which can also lead to value creation. When considering a new primary fund commitment, Pantheon is committed to understanding the manager’s willingness to adhere to sound ESG practices. Those managers that understand the nature of ESG risks and seek to minimize them are favoured. Pantheon’s primary due diligence process seeks to identify how the manager assesses ESG risks in their own analysis and the measures they take to mitigate them before and after investment.

01.6. Additional information [Optional].

          
        
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SG 01 CC. Climate risk (Not Applicable)


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.

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

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

URL/Attachment

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02.3. 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.

Pantheon manages multiple funds and segregated account mandates (each a “client”), and is responsible for allocating investment opportunities between clients in a fair and equitable manner. An allocation process has been put in place in order to manage any potential conflicts that may arise in the allocation of investments between clients.

  • Pantheon will allocate all investment opportunities in a fair and equitable manner consistent with and subject to the fiduciary and contractual duties of Pantheon to such clients.
  • Pantheon may in good faith determine that some or all of an investment opportunity is unsuitable for a client, or exceeds an appropriate amount for the client and therefore such client may not take up all of the offered investment opportunity.

Should an allocation decision require advisory board consent, then we would convene meetings of the relevant Pantheon Fund.

03.3. Additional information. [Optional]

Pantheon has a formal Conflicts of Interest policy which sets out conflicts which may arise in the course of its business and the procedures that Pantheon takes to mitigate such conflicts. Some of these conflicts are summarised below:

  • No transaction fees: No part of Pantheon's organization receives remuneration from managers of portfolio funds, mitigating fee driven conflicts of interest.
  • Pantheon has a strict Personal Securities Accounts/Trading Policy and a Gifts and Entertainment Policy which have been implemented to address conflicts of interest.
  • Cross-Fund Investments: Occasionally, managers of portfolio funds face conflicts of interest in relation to one portfolio fund (the predecessor portfolio fund) and another portfolio fund (the successor portfolio fund), for example in relation to an investment by the successor portfolio fund in a portfolio company of the predecessor portfolio fund.  Typically, the portfolio fund manager will seek to resolve such conflicts through operation of the advisory committees of each of the predecessor portfolio fund and the successor portfolio fund.  These conflicts can be replicated at the level of Pantheon clients, as Pantheon manages multiple pools of capital and may be represented on the advisory committee of either or both of the predecessor portfolio fund and the successor portfolio fund respectively.  Pantheon has procedures in place to mitigate these conflicts, involving separate deal teams, and annually reports to its own advisory committees on the resolution of conflicts through these procedures.

SG 04. Identifying incidents occurring within portfolios (Private)


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