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Oakley Capital Limited

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.

Oakley Capital is an independent, pan-European focussed private equity firm that specialises in control investments in high-potential, high-growth, mid-market companies operating in Western Europe.

Oakley has developed deep sector expertise and a wide network through successful investments in companies operating in technology, media and telecommunications (“TMT”), consumer and education sectors - sectors which we believe have a low inherent ESG risk.

Oakley is typically the first financial investor in its portfolio companies and supports them in the transition from entrepreneurial ownership to businesses with scaleable and sustainable operations.

Oakley invests in emerging leaders in high-growth sectors. These often involve successful businesses that have grown rapidly under the ownership of their founder(s) but need investment and support to achieve their next phase of organic growth. This may include building out the finance function and operational team, which are often weaker in younger companies, or investing in IT and head office functions to create a sustainable platform for growth.

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]


Promote compliance with relevant laws and regulations by portfolio companies;
Integrate ESG considerations into all stages of the deal cycle – from due diligence throughout the period of ownership, to exit;
Pursue alignment, in our RI approach, with the BVCA RI Guidelines, and other industry good practice as it develops;
Promote the respect, by Oakley and any fund investee companies, of fundamental human rights;
Avoid bribery or corruption in any of the Oakley and any fund investee companies’ dealings;
Encourage investee companies to consider and mitigate the ESG impacts of their operations;
Avoid investment in specific sectors which we, or our investors, consider especially sensitive from an ESG or ethical viewpoint;
Seek continuous improvement in RI techniques and ESG performance at Oakley and our investee companies; and
Report annually on Oakley's RI practices via the PRI reporting process and make information about our RI approach available on our website.  

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.


File Attachment


02.3. Additional information [Optional].

Oakley Capital believes that Responsible Investment (RI) is important to protect and create long-term investment value, beyond the standard drivers of compliance and risk management. Oakley recognises that our investee companies will have, to varying degrees, environmental, social and governance (ESG) impacts. Oakley will therefore work together with its investee companies (both pre- and post-investment) to identify and apply good practice with regard to managing ESG matters, so as to ensure that RI is at the core of Oakley’s activities.

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.

Oakley takes all reasonable steps to identify conflicts of interest between the Group (including Senior Management, Oakley Employees and any person directly or indirectly linked to us by control) and any Client, that arises or may arise in the course of providing any service to Clients and in the course of carrying on regulated activities or ancillary services.

The Compliance Team has identified and documented the key conflicts (actual and potential) faced by Oakley in its day-to-day business in the Conflicts Inventory as set out in the Conflicts of Interest policy below. This inventory is reviewed annually and updated when a new conflict is identified, with a report provided to the Board of Directors.

Oakley will take appropriate measures to mitigate and manage any realised conflict in a manner that seeks to ensure that the Group act in the best interests of the Client(s).

Oakley takes all reasonable steps to avoid conflicts of interest and, when they cannot be avoided, to identify, manage and monitor and, where applicable, disclose, those conflicts of interest in order to prevent them from adversely affecting the interests and to ensure that the Clients are fairly treated.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Not Completed)