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.