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8 Miles

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

          ESG Committee Participation by LPs
          Investment Code and SEMS

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 invest in African businesses and sectors with high growth prospects, and we enhance performance by implementing our "active ownership" approach when partnering with entrepreneurs and working alongside management teams. We partner with entrepreneurs who demonstrate unwavering passion, and invest in dedicated managers and skilled on-ground teams.We believe that the combination of partnering with highly motivated individuals, careful selection of businesses, and hands-on involvement leads to better investment performance. We typically invest between US$15 million and US$45 million in each business we back. We develop strong relationships with our stakeholders and ensure that all interests are aligned.

Our responsibility is to deliver improved environmental, social and governance (ESG) outcomes in the creation of market leading African companies. We do this by working closely with our portfolio companies and their stakeholders to create value through implementing sustainable business practices. Our 8 Miles Investment Code and Social and Environmental Management System (SEMS) require coinsideration of material ESG factors in all phases of diligence, investment, management and divestment. With DFI limited partners, we have a strong relationship to deliver improved outcomes on livelihood and real economy impacts embedded into our mandate.

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]

Key elements of the responsible investment policy include:

1. Identification and management of material ESG risks in partnership with the target company

2. Impact identification, mitigation and management throughout the lifetime of the investment

3. Embedding of legally binding responsible business principles (E, S and G)  into the financial instrument to provide real weight

4. Agreement of a binding ESG action plan - for a defined period - and to be reviewed annually by all parties and the fund's ESG Committee

5. Identification of, and resourcing, of appropriate professionals within the fund and in each portfolio company to meet the obligations setout in items 1-4. 

6. Formal accountability for operational exposure and incidents by the target company

7. A formal Board committee (the ESG Committee) to monitor, manage and provide professional practioner input into the fund and target company progress/performance

8. Incorporation of ESG inputs throughout all investment stages, as setout in the Social and Environmental Management System (SEMS) of the fund

The Company shall not make Investments in any Investee Company that engages in any of the following activities (the “Excluded Activities”):
a) Production or trade in any product or activity deemed illegal under host country laws or
regulations or international conventions and agreements, or subject to international
bans, such as pharmaceuticals, pesticides/herbicides, ozone depleting substances and
polychlorinated biphenyls, and bans pursuant to the Convention on International Trade
in Endangered Species of Wild Fauna and Flora.
b) Production or trade in weapons and munitions.
c) Production or trade in tobacco.
d) Gambling, casinos and equivalent enterprises.
e) Production of or trade in radioactive materials save for the purchase of medical
equipment, quality control (measurement) equipment and any equipment where the
Special Subcommittee considers the radioactive source to be trivial and/or adequately
f) Production of or trade in unbounded asbestos fibers save for the purchase and use of
bonded asbestos cement sheeting where the asbestos content is less than twenty (20%).
g) Drift net fishing in the marine environment using nets in excess of 2.5 km. in length.
h) Production or activities involving Forced Labor or Harmful Child Labor.
i) Commercial logging operations for use in primary tropical moist forest.
j) Production or trade in wood or other forestry products other than from sustainably
managed forests.

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.





Other, specify (1) description

          ESG Committee Participation by LPs


Other, specify (2) description

          Investment Code and SEMS


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.

1. Annual COI checks and disclosures - Fund level and Portfolio Company Managerial Staff

2. Quarterly FCA and COI checks and disclosures - Fund Level

3. Deal specific COI checks and vetting for Fund Staff and Advisors

4. Deal specific  - Partner, Principal, Associate and ESG Director involvement in all aspects of each deal to provide over-sight and monitoring.

5. Investment Committee and Board - include external directors not involved with the deal (as the majority)

6. Annual review by the Compliance Director on potential conflicts

7. Disclosure of the investment process recommendations to LPs for approval at various stages of the process

8. Responsible Divestment Policy - assessing associated stakeholders, intentions and beneficial owners

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

1. 24hr and 48hr protocol for reporting to the Fund and then to LPs (templates, processes agreed to in SHA/SPA)

2. Dedicated management by the ESG Director

3. Disclosure to LPs via the ESG Committee or via an extra-ordinary memorandum to LPs and the ESG Committee (LPs)

4. Incorporation into Fund Weekly Portfolio Meetings / Portfolio Committee and daily Portfolio Management teams

5. Agreed Action Plan / Monitoring and Close-out

6. Annual Lessons Learnt Review for Annual Report and Operational Excellence Programme

7. Whistleblowing Hotline managed by an external agency - in progress