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PRI reporting framework 2020

You are in Strategy and Governance » Promoting responsible investment

Promoting responsible investment

SG 09. Collaborative organisations / initiatives

09.1. Select the collaborative organisation and/or initiatives of which your organisation is a member or in which it participated during the reporting year, and the role you played.

Select all that apply

Your organisation’s role in the initiative during the reporting period (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

Primary is still working to establish the most practical and effective way for an organisation of our size to engage and be involved.

SG 09.2. Assets managed by PRI signatories (Not Applicable)

SG 10. Promoting RI independently

10.1. Indicate if your organisation promotes responsible investment, independently of collaborative initiatives.

10.2. Indicate the actions your organisation has taken to promote responsible investment independently of collaborative initiatives. Provide a description of your role in contributing to the objectives of the selected action and the typical frequency of your participation/contribution.


          Primary provides annual training for entire company by external experts.  Primary also requires portfolio companies to provide appropriate training for staff, taking into account the specific risks and opportunities relevant to each company and its industry specific characteristics.

Frequency of contribution

10.3. Describe any additional actions and initiatives that your organisation has taken part in during the reporting year to promote responsible investment [Optional]

Pre-investment we commit to integrate ESG and ethical issues into our due diligence process by developing investment analysis criteria including an identification of the ESG risks and opportunities and any related financial impacts. We also adopt, based on our values and principles and those of our Limited Partners, an ESG-related exclusion policy with regard to certain industries; currently we will not invest in the armament and tobacco industries. In addition, we ensure through legal documentation that portfolio companies disclose any non-compliance with ESG-related laws and regulations of which they are aware and adopt appropriate external standards or codes.                  

Post-investment we engage with our investee companies and establish appropriate ESG policies and practices consistent with our RI policy, initially through the 100 day plan particularly where there is serious regulatory non-compliance that constitutes a significant immediate business risk. We expect all our investments to respond to a minimum set of ESG-related questions as part of the due diligence process. We assign accountability for ESG responsibilities to senior managers at the portfolio company who are responsible for compliance with those principles and must report at Board level monthly. We continue to monitor ESG issues in portfolio companies to provide any updates and report on whether any new significant or material issue have arisen and to encourage the managers of investee businesses to achieve continuous improvements in those areas. In this regard, we assist portfolio companies in maintaining awareness of trends in consumer and investor preferences, regulation, technology and environmental thinking.

We have also historically commissioned high level reviews of investments from Ethical Investment Research Services (EIRIS) Limited, an independent global provider of research and consultancy into ESG and ethical performance of companies. EIRIS identified the key ESG issues which relate to the investments and consulted with the investment team and management on how risks and opportunities are being identified and managed. 

SG 11. Dialogue with public policy makers or standard setters (Private)