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Bowmark Capital

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.

Bowmark’s investment strategy is to make active investments in UK mid-market companies, with the aim of generating superior investment returns through fundamental value creation, driven by sales and profit growth. The investment strategy has four key elements being

  • a focus on transformational growth;
  • proactive deal origination in target sectors;
  • high impact investing; and
  • a disciplined and conservative investment philosophy.

Underpinning this strategy, we carefully consider our fiduciary duties and the ESG credentials of any companies in which we invest, as outlined below.

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]

Bowmark has a ESG specific policy that sets out our approach to responsible investment. This policy is consistent with our overall investment policy which focuses on identifying the highest quality businesses and undertaking rigorous due diligence before completing a potential investment.

The objectives of Bowmark’s ESG policy are to ensure that the firm i) acts at all times as a good corporate citizen, ii) enhances the successful development of the businesses in which it invests, and iii) is a responsible custodian of its investors’ capital.

In particular, its objectives are to ensure that the firm:

  • fully explores environmental, public health, safety, social and governance issues associated with target companies when evaluating whether to invest;
  • monitors and continuously improves the ESG credentials of the companies in which it invests;
  •  uses governance structures to provide appropriate levels of oversight in the areas of audit, risk management, and potential conflicts of interest, and to ensure alignment with the interests of other investors and management;
  •  supports the employees of Bowmark portfolio companies through the provision of a safe and healthy workplace and the payment of competitive wages and benefits;
  • respects the human rights of those affected by Bowmark’s investment activities; and
  • provides timely information on ESG matters to Bowmark’s limited partners, and works to foster transparency about Bowmark’s activities in this field.

We recognise that strong governance and ethical business practices create shareholder value, as well as enabling a positive contribution to the wider community and society as a whole.

01.6. Additional information [Optional].


SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

Assessment of climate-related risks now forms part of our due diligence for new investments, and a review of the relevant risks regarding the current portfolio is underway. They key areas of risk identified are: 


  • Government policy and legal obligations
  • Technology and investment
  • Market disruption
  • Reputational


  • One-off extreme weather
  • Chronic long term climate changes

The Bowmark portfolio is principally comprised of service businesses and thus the more material risks relate to the transitional elements.

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

Describe the associated timescales linked to these risks and opportunities.

Each portfolio company has completed an informal assessment of climate-related risks and opportunities as part of their wider ESG planning. During 2020, these assessments are being formalised into a standard format.

Generally, the risks are long-term in nature, other than a small number of instances where company's operate properties that are exposed to flooding risks. Where this is the case, contingency plans have been developed.

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

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


Each portfolio company is in the process of completing a standardized assessment of climate related risks

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

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].

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.

The Compliance Officer acts as the central co-ordination point in relation to conflicts of interest. Accordingly, any actual or potential conflict of interest,  is reported to the Compliance Officer.

Upon receipt of a notification of potential or actual conflict, the Compliance Officer will manage the conflict by:

  • Logging the conflict on the Conflicts of Interest Register; and
  • Assessing the conflict to determine whether it is a perceived rather than actual conflict, and one in relation to which no further action is required or a conflict which does not have a commercial impact on the Firm, whereby, the Compliance Officer will resolve and manage such conflict in the client‘s best interests.

In most cases, conflicts will be resolved by the Compliance Officer in one of the following ways:

  • An acknowledgement that existing controls are sufficient to mitigate the conflict. An example here might be where established Chinese walls exist, or where the individuals concerned are subject to a policy of independence;
  • Implementation of additional control measures specific to the conflict concerned;
  • Declining to act for the client concerned; or
  • Disclosure of the conflict to the parties concerned and seeking their consent to continue with the transaction.


03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)