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CDC Group plc

PRI reporting framework 2020

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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

Other description (1) CDC’s investment policy is laid out in “Investment Policy 2017-2021” (https://assets.cdcgroup.com/wp-content/uploads/2017/06/25150847/Investment-Policy-2017-2021.pdf). Our Code of Responsible Investing, which is part of the Policy, outlines our specific RI requirements for portfolio companies and funds. The Code recommends good corporate governance as part of recommended practices to deliver impact and reduce risks.
Other description (2) We have the following statements and policies on specific RI topics (https://www.cdcgroup.com/en/publications-library/): CDC Code of Responsible Investing, Climate Change Policy, Policy on Coal, Fired Power Generation, Whistleblowing and Complaints Policy, Modern Slavery Act statement and Gender Position statement

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.

As a DFI, CDC has a public commitment to responsible investment. We seek to support the economic stability in growth of businesses throughout Africa and South Asia, create jobs, and make a lasting difference to people's lives in some of the world's poorest places. CDC believes that operating to high business integrity, environmental, social, and governance standards is a key part of long-term business success. Our strategic priorities are to be developmental, responsible, innovative, and enduring; and include a commitment to set high ESG standards and provide practical assistance.

CDC has invested through direct equity and debt since 2012, offering a high degree of engagement and support to companies. In addition, we have developed a strong reputation for helping fund managers in geographies underserved by private equity and their underlying investee companies improve their ESG performance. The fund-of-funds model allows CDC to indirectly support a large number of companies, including in difficult-to-reach regions and with smaller ticket sizes than might otherwise be possible. Our presence and strong ESG standards cascade down and impact a wider market. 

Investments across all business lines are selected based on alignment with our responsible investment strategy and potential to motivate positive developmental impact.

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]

CDC has a dual mandate, which requires it to meet both a financial returns hurdle for its shareholder, DFID, and to ensure that its investments have sufficient development impact (DI) both individually and at a portfolio level. All businesses that receive CDC capital must adhere to its Code of Responsible Investing ("the Code"), which stipulates CDC's ESG requirements. The Code was updated in 2017 to reflect lessons learned in the previous 5 years, as well as emerging legislation and informal norms / good practice in relation to ESG performance in CDC's markets (for example UNGP on Human Rights and Modern Slavery Act). These requirements are based on international best practice. The Code is publicly available on CDC's website and is structured to reflect our ESG requirements, recommended good practices and the components of management systems that CDC legally requires in all its investments. The Code sets out a hierarchy of ESG requirements, including an 'exclusion list' of industry sectors and / or activities where CDC's capital cannot be invested, specifying minimum ESG requirements of all businesses, and additional requirements for industries where the levels of ESG risk requires it (e.g. complex health and safety issues). Based on its Code, CDC works over time with intermediaries and companies in an approach that builds from compliance with certain basic standards and works towards the adoption of internationally recognised standards of good industry practice and areas of ESG value add to the business.

The Code consists of six schedules. Schedule 1 outlines the responsible investment management system that CDC will itself maintain. Schedule 2 specifies the management systems required of financial institutions and fund managers to manage portfolios which potentially contain complex assets from an ESG perspective. Schedule 3 of the Code sets out minimum ESG requirements for all businesses where CDC's capital is deployed. Meanwhile, Schedule 4 outlines additional requirements triggered by specific activities of the business. Schedule 5 lists the recommended ESG practices endorsed and promoted by CDC. Finally, Schedule 6 lists all industry sectors and activities where CDC's capital may not be deployed (the 'exclusion list'). CDC regularly reviews its Code of Responsible Investing to ensure that its investment standards reflect emerging good practices.

The Development Impact Grid is our investment screening tool, which scores every investment we plan based on two factors: the difficulty of investing in the country where the investment is to be made and the propensity of investments in the relevant business sector to generate employment. We prioritise sectors where growth leads to jobs – our decision-making process ranks sectors based on their likelihood of creating jobs. Our investment teams include product and sector specialists who look for businesses with the greatest potential for impact, whether through their ability to grow and create jobs, to address a lack of enabling infrastructure, to increase efficiency, or to increase opportunities for the poorer parts of society.

CDC is also committed to developing and promoting good practice guides and materials for investors, also reported here. In 2014, CDC developed a Climate Change Policy which seeks to assess climate change risks and opportunities in its investments. The policy has a specific focus on energy use efficiency, carbon intensity and on-site renewable; water-use efficiency and water-conservation measures; adaptation and resilience, and disaster risk management, especially in large infrastructure projects vulnerable to climate-related impacts. In 2016, CDC published its first Modern Slavery Act Statement, which sets out policies within CDC's own operations and through investment activities. CDC also launched its first web-based ESG Toolkit for Fund Managers in June 2015, which was updated in 2018 and is being further updated in 2020 to include resources for financial institutions and to enhance guidance on Business Integrity. The freely available Toolkit provides a wide range of guidance to fund managers on developing their own management systems and assessing risks and opportunities in their portfolio, among other advice.

CDC recognises that many businesses in Africa and Asia will not be in full compliance with its Code at the date of investment. In such cases, CDC, or those managing its capital, work with the business during due diligence to develop an action plan that seeks to achieve compliance within a reasonable timeframe, with clear deliverables and responsibilities. An action plan will take into consideration the risks and opportunities specific to the business and its current size and resources, and will typically be included in legal agreements.

An additional part of CDC's role as a DFI is to support funds and companies as they develop policies and systems and actively engage with them to manage the ESG risks associated with their operations, and to identify and realise ESG opportunities that may be evident. In this way CDC actively looks to add value to its GPs' underlying businesses and its direct investments through ESG improvements that go beyond compliance.

01.6. Additional information [Optional].

          
        

SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

In 2019, CDC committed to make climate-related financial disclosures in line with the recommendations of the Taskforce on Climate-related Disclosures (TCFD) as soon as practical after the close of the 2020/2021 financial year. In the highest risk transactions, we have already identified and assessed physical climate-related risks and opportunities at each step of the investment decision process pre-investment during due-diligence, and then post-investment. These elements include: energy use efficiency, carbon intensity, renewable opportunities (i.e. solar, biomass, cogeneration etc.); water use efficiency and water conservation measures; adaptation and resilience needs and opportunities, and disaster risk management especially in large infrastructure projects and agricultural projects vulnerable to climate related impacts.

CDC’s sector investment strategies that are starting to consider physical and transition risks include infrastructure, food & agriculture, forestry, manufacturing, construction & real estate, financial institutions and trade finance.

Work is underway to further develop our approach to physical and transition at transaction and portfolio level.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe the associated timescales linked to these risks and opportunities.

Climate change risk assessments are integrated into potential direct debt and equity investments where relevant, and portfolio companies as needed. The ESG-I team assesses how material those risks might be and the time period over which to engage on them, and create a sensible prioritisation based on what is feasible and imperative for each deal.

When a climate change risk assessment is identified as necessary, or a clear opportunity exists, these will be integrated into the ESG Action Plan for a company, with a clear timeline and deliverables. 

CDC expects GPs to undertake similar assessments where relevant.

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.

Describe

In 2019 CDC developed a new Climate Change Strategy structured around the four pillars of the TCFD framework, including 1) Strategy, articulating CDC's approach to Paris alignment 2) Governance 3) Risk Management and 4) Metrics.

Under the strategy pillar, we have started to identify physical and transition risks in our priority sectors in infrastructure, food & agriculture, forestry, manufacturing, construction & real estate, financial institutions and trade finance. Our strategy also highlights climate opportunities by sector to support a transition to net zero economies and increase resilience both through investments and by adding value beyond capital.

Under the governance pillar, we strengthened the organisational structures to manage climate related risks and opportunities. For example, with regard to Board committees, responsibility for climate change has been extended beyond Development Committee, to also include the Risk Committee in addition to the full Board.

Under the risk management pillar, our strategy sets out how CDC wants to expand climate risk assessment at transition level and assess as climate related financial risk at portfolio level.

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.


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.

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

Other description (1) CDC’s investment policy is laid out in “Investment Policy 2017-2021” (https://assets.cdcgroup.com/wp-content/uploads/2017/06/25150847/Investment-Policy-2017-2021.pdf). Our Code of Responsible Investing, which is part of the Policy, outlines our specific RI requirements for portfolio companies and funds. The Code recommends good corporate governance as part of recommended practices to deliver impact and reduce risks.
Other description (2) We have the following statements and policies on specific RI topics (https://www.cdcgroup.com/en/publications-library/): CDC Code of Responsible Investing, Climate Change Policy, Policy on Coal, Fired Power Generation, Whistleblowing and Complaints Policy, Modern Slavery Act statement and Gender Position statement

URL/Attachment

02.3. Additional information [Optional].

The CDC Document library lists company policies and codes: https://www.cdcgroup.com/en/publications-library/


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.

CDC is regulated by the UK Financial Conduct Authority (FCA). As such, CDC is required to have measures in place to identify, prevent, manage, monitor and where relevant disclose any conflicts of interest which arise. The proper management of conflicts is important not only from a regulatory perspective but also to protect our counterparties and employees. CDC distinguishes between 1. staff personal conflicts, based on personal interests or the possession of sensitive information and 2. transactional conflicts which may arise in connection with CDC’s investments. Our approach to identifying and managing conflicts has been informed by the nature of our business and its structure.

Where a conflict is identified, CDC's policy requires such risks to be managed and or mitigated in accordance with procedures set out in our conflicts of interest policy and the policy on transactional conflicts management. Personal conflicts are managed by Compliance and transactional conflicts are managed by the Chief Legal Officer.

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

CDC legally requires immediate reporting of all serious incidents in its direct equity and debt portfolio, as well as in the portfolios of our fund managers. A serious incident is defined by CDC as any incident that results in loss of life, severe permanent injury or severe permanent damage to health, a material adverse environmental, social or business integrity matter. CDC takes each incident very seriously and follows up with each investee to ensure that the root causes of an accident are identified and that corrective actions are put in place to prevent a recurrence. CDC also provides training to its portfolio on occupational health and safety, and encourages investees to track lost-time incidents as a key performance indicator. CDC reports internally and externally on serious incidents. In 2014, CDC produced a good practice guidance document with lessons learnt from its perspective across a wide portfolio. Further guidance is also offered on CDC’s ESG Toolkit for Fund Managers. In November 2019, CDC hosted a workshop on accident investigation and occupational health and safety, and invited other DFIs and investors.


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