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Pathway Capital Management, LP

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.

Pathway is committed to giving proper consideration to ESG issues when implementing changes to internal policies, practices, and processes, while maintaining its fiduciary duty to its clients/investors, and to generally following the principles below:

  1. Incorporating ESG issues into its investment analysis and decision-making processes.
  2. Requesting that general partners (GPs) incorporate ESG issues into their policies and procedures.
  3. Requesting that GPs provide appropriate disclosures regarding ESG issues in the partnerships and portfolio companies in which the Company’s clients invest.
  4. Promoting acceptance and implementation of the Principles within the private equity industry.
  5. Working with stakeholders to enhance the Company’s effectiveness in implementing the Principles.
  6. Reporting on the Company’s activities and progress toward implementing the Principles.

Pathway believes that the consideration of ESG issues is critical in evaluating the potential attractiveness of a GP. GPs with well-constructed ESG policies are more likely to have a sustainable investment strategy that increases the potential for the GP to have a long-term existence.

In evaluating a GP’s ESG policies, Pathway considers the GP's operational capabilities, transparency, and sustainability; the governance practices of a fund or portfolio company; and the industry focus and geographic operation; as well as other social or environmental impacts of a fund’s investments. 

 

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]

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 (Not Completed)


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

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

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

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.

Since its inception, Pathway has managed its business to avoid potential conflicts of interest between the firm and its clients and investors. Pathway has developed a compliance program that implements stringent policies and procedures designed to mitigate and/or eliminate the potential for conflicts.

  1. Pathway’s Conflict of Interest Policy requires the written disclosure of any actual or potential conflicts of interest an employee may have with any private equity investment groups, placement agents, or other related third parties. Any relationship, whether direct or indirect, must be disclosed.
  2. Pathway’s Code of Ethics restricts employees from purchasing stocks or bonds of publicly traded companies or investing in privately traded companies (i.e., making private equity investments). Investments in mutual funds or similar investment vehicles are primarily the only investment opportunities permitted.

It is Pathway’s policy to keep its clients and investors fully informed of any information, including potential conflicts of interest, that could impact their portfolios.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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