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Roxbury Asset Management

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.

Roxbury Asset Management

Environmental, Social and Governance Policy

Drafted: October 2019

Implementation Date: January 1st 2020 (*approved by Roxbury Board of Directors).

The purpose of this policy is to provide guidance regarding integrating the analysis of environmental, social and corporate governance (“ESG”) risk factors into the review of portfolio investments by Roxbury Asset Management (“Roxbury” or the “Firm”).  Roxbury is authorised and regulated by the Financial Conduct Authority as a MiFID investment firm.

This policy is reviewed on a regular basis by the Firm’s Board of Directors and updated where necessary to reflect changes in circumstances and actual practice.

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]

ESG issues can have a material impact on financial performance and the communities in which both Roxbury and our portfolio companies operate.

Roxbury is cognizant of the UN’s Principles for Responsible Investment (“PRI”), a voluntary framework which promotes the integration of ESG considerations into investment management processes and ownership practices to better manage risk and generate sustainable long-term returns.

In listed equity, responsible investment is an approach to managing assets that sees investors include ESG factors in (1) their decisions about what to invest in; and (2) the role they play as shareholders of companies. It aims to combine better risk management with improved portfolio returns, and to reflect investor and beneficiary values in an investment strategy. It complements traditional financial analysis and portfolio construction techniques.  As a result, Roxbury incorporates consideration of ESG factors into its investment analysis, decision-making and ownership practices.

The purpose of this ESG policy is to define Roxbury’s approach to integrating the consideration of ESG risks and value creation opportunities into investments made through its funds. Roxbury commits to consider material ESG issues in the course of its due diligence and in the monitoring of portfolio investments to the extent reasonably practical under the circumstances, subject to the provisions of the prospectuses of the funds concerned, and to the duty of Roxbury to seek to maximize the returns on investment of its funds.

For the purposes of this policy, “material” ESG issues are defined as those issues that Roxbury in its sole discretion determines to have or have the potential to have a direct substantial impact on an organisation’s ability to create, preserve, or erode economic value, as well as environmental, social and governance value for itself and its stakeholders.

ESG Risk Factors

ESG risk factors could include, but are not limited to, a range of issues as set forth below. The range of ESG risk factors considered by Roxbury may also change over time.

Environmental - assessing whether environmental risks and associated costs, policy or management related to factors such as sustainability of use of natural resources, waste management, water or air pollution, climate change, protected environments, protecting water supplies, greenhouse gas emissions etc. could have a material effect on the investment.

Social - assessing whether social factors such as child or forced labor, discriminatory policies, relations with indigenous people, worker health and safety, public health issues, relations with unions and employees, managing product safety issues, protection of consumer rights, competitive wages and benefits, implementation of anti-bribery policies, etc. could have a material effect on the investment.

Corporate governance - assessing whether governance issues such as the composition and independence of the board of directors of a portfolio company, determination of executive compensation, shareholder rights, audit and accounting quality and controls, conflicts of interest, etc. could have a material effect on the investment.


Roxbury and the employees of the Firm, will to the best of our ability:

- Comply with relevant regulations governing the protection of human rights, occupational health and safety, and labor, environmental and business practices of the jurisdictions in which we conduct business.

- Adhere to the highest standards of conduct intended to avoid even the appearance of negligent, unfair or corrupt business practices.

- Appoint a Head of Sustainability.

- Instruct Roxbury investment professionals in the identification and management of ESG risks and opportunities, and provide them with appropriate training and support.

- Identify ESG risks and opportunities prior to the acquisition of portfolio companies, and manage ESG risks and opportunities following acquisition.

Regard implementation of our ESG initiative as an ongoing engagement. Our Head of Sustainability will review this ESG policy’s effectiveness and implementation on an annual basis, and will report relevant findings and recommendations to the Board.

Distribute this ESG policy to all Roxbury employees.

Be accessible to, and engage with, our investors and other stakeholders to encourage dialogue on how Roxbury can accommodate ESG issues in ways that are consistent with those of the stakeholders.

Provide timely information to Roxbury’s investors on the matters addressed herein, and work to foster transparency about Roxbury’s activities.

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.

Declarations of all personnel holdings and pre-compliance approvals for all PA holdings and trades.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)