Primary incorporates the evaluation and management of ESG issues into its analysis, due diligence and investment decision-making processes as follows:

Legal due diligence at the time of investment includes questions and evaluation of many ESG issues, including anti-corruption policies, anti-trust issues, labour relations, environmental issues (both relating to historic liabilities and current practice) and standards of corporate governance; and

Specific due diligence by appropriate external experts may be undertaken.  This frequently includes the engagement of Environmental Consultants to evaluate and report on historic environmental liabilities which may affect the business and current compliance with relevant environmental legislation.  In addition, commercial due diligence normally covers areas such as Supply Chain Management and the related social issues (e.g. child labour, quality standards).

Primary has developed an in house framework to asses risks and opportunities, which must be completed prior to any investment and forms part of the formal investment recommendation issued to the investment committee. Where there are specific areas which require more detailed or technical analysis, Primary engages external experts to undertake the work. The framework is made available to Primary's Advisory Board and other investors as part of their own due diligence process on an investment into funds managed by Primary.