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PRI reporting framework 2020

You are in Direct – Private Equity » Overview


PE 01. Description of approach to RI (Private)

PE 02. Investment guidelines and RI

02.1. Indicate whether your organisation’s investment activities are guided by a responsible investment policy / follow responsible investment guidelines.

02.2. Describe how your organisation outlines expectations on staff and portfolio companies’ approach towards ESG issues in investment activities.

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


Depending on the nature of the business, specific pieces of 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 ESG legislation.  In addition, Primary would expect CDD to cover social areas such as Supply Chain Management and the related social issues (e.g. child labour, quality standards) where awareness and management of which both offer the opportunity to develop a more reliable, higher quality source of goods and governance areas (e.g. data protection / cyber-security, anti-bribery & corruption) where it is important to avoid breaches of confidential information and non-compliance with local regulations.