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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.

We require that Primary and investee companies

Provides safe, healthy working conditions for all and protects human rights;


Encourages efficient use of natural resources, promotes protection of the environment and introduces programmes to reduce waste and consumption of energy and water


Treats all employees fairly regarding recruitment, progression, remuneration and working conditions, irrespective of gender, race, colour, disability, age, religion or nationality;


Allows consultative work-place structures providing employees the opportunity to present their views;


Takes account of the impact of operations on the local community and ensures that potentially harmful health and safety, environmental and social effects are properly assessed, addressed, and monitored;


Upholds high standards of integrity, complies with local laws and international good practice and does not directly or indirectly offer, pay, solicit or accept bribes in any form;


Implements a management system which enables identification, management and monitoring of risks and provides a framework for action;


Provides reporting of any incident that results in loss of life or material effect on the environment;


Provides reporting ESG matters to the Board of Directors; 


Implements mechanisms in supply chain management to avoid sourcing of products manufactured by child or slave labour.

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]


Businesses must:

Take account of the environmental impact of their operations (through a formal "environmental assessment" in cases involving loss of biodiversity or habitat, climate change, water or air quality, substantial solid waste and other issues where the negative impact could be significant) and take steps to mitigate any risks;

Be designed and operated in compliance with local law;

Be designed and operated according to relevant World Bank standards for the activity concerned if these are more stringent than local legislation, unless there is a clear reason for accepting a different standard in which case this will be formally recorded; or

Take account of relevant international environmental agreements.

Ensure that for each investment the impact on climate change is taken into consideration by the Investment Committee pre-investment.

Health & Safety

In our investment decision we take into account whether businesses :

Comply with local health and safety law as a minimum;

In the absence of a local health and safety legal framework, act in accordance with the recommendations of the relevant World Bank Standards; and

Assess the specific risks arising from work activities and introduce measures to eliminate or reduce those risks


We seek to invest in businesses which uphold high standards of business integrity and honesty and operate in accordance with local and international laws and good practice, including those intended to prevent extortion, bribery and financial crime.


We seek to invest in businesses which:

Comply with local law (as a minimum);

Take account of their impact on employees, contractors, the local community and all others affected by their operations through appropriate consultation, and to take steps to mitigate any risks;

Do not employ forced labour of any kind;

Do not allow children to form part of their workforce;

Pay wages which meet or exceed industry or national minima and are sufficient to meet basic needs;

Treat their employees fairly in terms of recruitment, progression, terms and conditions of work and representation, without prejudice to and irrespective of gender, race, colour, disability, political opinion, and sexual orientation; and

Allow consultative work-place structures and associations which provide employees with an opportunity to present their views to management.


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.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Primary’s Investment Committee governance structure calls for unanimous decisions by all Partners.  As such, it is the responsibility of the Partner sponsoring a deal or other matter to convince all other Partners of the merits of a positive decision.  As a group, the Partners bring complementary skills to the table and have great respect for each other, which has enabled them to work effectively together for numerous years.  There have been no instances where conflicts arose that were not resolved to the satisfaction of all parties.


Primary also appoints an Advisory Board comprising key investors in Primary funds.  The principal role of the Advisory Board is to:    

Review the strategy and performance of the Fund.  Using the Funds 6 monthly report to investors the Advisory Board will confirm that investments made in the period are in accordance with the Fund’s strategy as laid down in the “Private Placement Memorandum”.

Review adherence by the General Partner to the relevant Limited Partnership agreements;

Review any potential or actual conflicts between the General Partner and the Limited Partnerships; and

Consult with the General Partner on the progress of the Fund generally in achieving its investment objectives.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)