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Private Advisors, LLC

PRI reporting framework 2020

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.

Private Advisors sources, underwrites, structures, and manages investments in small to mid-sized managers and direct transactions across the liquidity spectrum. Private Advisors is a recognized leader in the Low Mid Market, which we define as private equity funds typcially below $500MM and companies with less than $150MM in enterprise value. We seek value-added private equity fund managers that typically provide the first institutional capital to founder owned business or corporate carve outs, with an emphasis on business building over financial engineering. Our hedge fund team focuses on short and intermediate duration strategies, including long/short equity and credit, with a focus on managers with less than $2.0 billion in capital.

The Firm’s ESG policy focuses on relevant environmental, social and governance factors alongside traditional financial metrics in diligencing, managing and monitoring investments. Private Advisors utilizes ESG considerations to identify risks, a practice consistent with the Firm’s focus on mistake avoidance, as well as to identify value drivers, which is consistent with our platform's focus on business building.

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]

Private Advisors has developed specialized due diligence tools to address the unique underwriting requirements in Low Mid Market private equity that include ESG considerations during the underlying private equity manager selection and monitoring processes. In addition to offering a screened investment vehicle, the Hedge Fund team is now adopting the application of ESG considerations in its investment activities, building on the process developed by the Private Equity team in 2012, as described below.

Private Advisors believes it is a leader among its peers in its development of a proprieraty Private Equity ESG Due Diligence Manual, an ESG Due Diligence Scorecard and an Operational Due Diligence program that address the unique underwriting requirements of lower middle market private equity managers in North America. This includes the identification of ESG risks considerations and value drivers at the underlying portfolio company level, governance practices at the underlying fund level that are underwritten by both the Private Advisor investment teams and ODD teams, and governance practices with our funds, including the use of third part reporting providers. This ESG Scorecard evaluates private equity fund investments on up to 35 different criteria and has been used programatically since 2015. In addition, the Operational Due Diligence Scorecard has been completed for every investment since 2012.

Private Advisors, as mentioned above, uses an ESG Scorecard as part of its investment due diligence, which is shared with all members of the Primaries Investment Team . In addition, Operational Due Diligence conducts separate checks on firms’ governance, regulatory compliance, and controls. The findings from the ESG Scorecard and ODD team are also summarized in the final investment memo for approval by the Investment Committee.

01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


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].

Private Advisors takes it regulatory responsbilities seriously and has a conservative approach to compliance. As such, we are limited in our ability to disclose any documents that may be construed as an investment offering. However, we typically provide clients and prospective investors with information on our ESG policy and approach, including the Private Advisors ESG Manual, examples of ESG Scorecards, and Investment Recommendation Memos with completed ESG Scorecards, on request.

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.

Private Advisors' compliance manual addresses conflicts of interest in several areas, including the firm’s Code of Ethics. Private Advisors has also been an SEC Registered Investment Advisor since 1998. 

Accordingly, Private Advisors has established a Conflicts Committee. The Conflicts Committee meets as needed but at least quarterly, and is responsible for: identifying potential conflicts of interests that may arise in our business and discussing ways to address and mitigate them; considering new or potential conflicts as they arise, that have not previously been addressed or that are otherwise not addressed in our standard policies; and reviewing the adequacy of disclosure to investors regarding potential conflicts of interests and the effectiveness of existing policies designed to address potential conflicts.  Additionally, Private Advisors monitors employee-level conflicts by requiring all employees to complete a “Conflicts of Interest” questionnaire Cordium’s online compliance reporting tool, “ELF”, within 30 days upon hire and a similar questionnaire through our parent company annually thereafter. Employees also have an ongoing obligation to report any possible conflicts as they arise during the year. Such notification may be made through ELF or notifying the Chief Compliance Officer.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)