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Blue Oceans 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.

Investment Principles and Strategy 

Fundamental, active, long-term investments in profitable companies whos business model is disrupting or creating an industry for the benefit of environment and people. The majority of our analysis is focused on the drivers of price and volume. 

- Concentrated portfolio

- Screen all investment opportunities manually, looking at the business model as a first filter

- Detailed analysis of financials, notes to financials, industry, and competitors. (Company must have earning from operations or we must be able to clearly establish a likely pathway to profitability)

- Calculate intrinsic value based on tangible value in the business (value of advertising, R&D, balance sheet) and value of distributable earnings (cash flow from operations) (We can only purchase a company where the stock price represents a fair or discounted value as compared to our valuation). 

- Detailed ESG analysis (Company must align with good ESG management practice). 

- Accounting manipulation checks (check on any evidence of accounting manipulation or embellishment). 



Our investors perceive us as sustainable. It is therefore our duty to to interpret what sustainability means and to enact it in our daily activities. 

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]

We only make investments that do not involve polluting commodities, weapons or defence, gambling, alcohol, or any media harmful to psychological well-being. We conduct ESG analysis and report on ESG factors for each of our investments as per the guide and case studies in “A practical guide to ESG integration for equity investing.”  We only invest in companies with good ESG alignment and have divested where there has been misalignment during the course of our holding. 

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].

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)