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Vinci Partners Investimentos Ltda.

PRI reporting framework 2020

Export Public Responses

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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

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.

The ESG-related policies are integrated throughout the investment cycle as summarized:

Pre-Investment Phase: Upon the initial screening and approval of the investment committee, the investment is subject to two due diligence steps, which take into account the ESG factors in order to evaluate the potential ESG material topics. The potential material ESG topic are included in discussion with the Investment Committee to defined how they will be assessed during the following phased – i.e., it can be either conducted internally or by external advisors, as appropriate. When issues or gaps are identified during the ESG due diligence, related actions and deadlines are included in the Environmental and Social Action Plan (ESAP) section for evaluation. For each action, the following will be defined: the responsible party, priority, complexity and the deliverable or indicator of completion.

Monitoring Phase: In addition to the due diligence and ESAP, some material ESG topics require frequent review during the project life cycle, such as compliance with related permits. Those questions will be monitored based on the period to be defined during the ESG due diligence

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]

VINCI has a formal ESG Policy which is applicable to its business, portfolio companies, their suppliers and business partners with the goal of improving performance and minimizing adverse impacts in these areas. The policy is based on the following principles:

  •         Environment Aspect:
  1. Conduct business and establish partnership with high levels of environmental performance;
  2. Comply with environmental laws and regulations;
  3. Reduce environmental impact; and
  4. Preserve natural resources.
  •         Social Aspect:
  1. Treat people with dignity and respect in a safe workplace;
  2. Respect the rights of workers, complying with relevant laws and regulations relating to compensation, working hours, rest periods, equal opportunity, diversity, anti-discrimination and other benefits and welfare;
  3. Respect the human rights preventing child and forced labor;
  4. Provide a safe and health workplace in conformance with national and local law;
  5. Improve employees’ knowledge and skills which may include internal and external training and courses offered by the firm;
  6. Manage social risks of the supply chain of portfolio companies; and
  7. Be accessible to, and engage with, relevant stakeholders either directly or through representatives of portfolio companies, as appropriate.
  •        Governance Aspect
  1. Conduct business and establish partnership in an ethical manner at all times;
  2. Establish independent annual audits and transparent disclosure of portfolio companies’ financial statements;
  3. Create effective board structures;
  4. Comply with relevant anti-corruption laws and regulations relating to bribery, extortion, fraud and money laundry; and
  5. Provide timely information to VINCI limited partners on the matters addressed herein, and work to foster transparency about VINCI activities

01.6. Additional information [Optional].

          In terms of Exclusion Policy, the Vinci Group complies with IFC´s Policy Requirements that excludes future investments described as "Category A". In addition, our Anti-Money Laundering and Counter-Terrorism Financing Policy (AML/CTF) states the following: 4.2. To the best of its knowledge, the Vinci Group will not establish or continue relationship with other individuals and legal entities engaged in or connected to the following: ✓ shell banks (financial institution not physically present in the relevant jurisdiction); ✓ organized crime groups and extorsion; ✓ terrorism, including terrorist financing; ✓ human beings and immigrant trafficking; ✓ child labour and slavery; ✓ sexual exploitation, including sexual exploitation of children; ✓ drugs and psychotropic substances traffic; ✓ gun traffic; ✓ trafficking of stolen property and others; ✓ currency counterfeiting; ✓ piracy; and ✓ smuggling; 4.3. To the best of its knowledge, the Vinci Group will not establish or continue a relationship with any individual or legal entity listed in the consolidated lists of targets by OFAC, UN, and the European Union or the Slavery list maintained by the Ministry of Labour.

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.

Yes, we do consider climate related risks and opportunities in our investment process.

In the case of the hydroelectric power plants, the most relevant ends up being the operational level of the national system as a whole (GSF - Generation Scaling Factor) than the specific flow of the river in which they are located, as these plants compulsorily adhere to the MRE (Energy Reallocation Mechanism). To mitigate this impact of a generation below the physical guarantee (GSF <100%), entrepreneurs usually leave a portion uncontracted and / or contract insurance for the renegotiation of hydrological risk (SP) in the ACR (Regulated Contracting Environment). In addition, projects also generally have bank or corporate guarantees that somewhat mitigate the project's performance risk. In the credit, we consider these and other aspects (Money Laundry Prevention scenarios, support and financial capacity of the sponsor) to support the climatic / hydrological risk and other risks related to the project

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.

In our investments in hydro power, typically, the auction notice for the auctioned plants is formulated based on a long term hydrographic study and the basic project of the plant and the regulator itself determines the so-called physical guarantee (expected amount of generation and maximum volume of energy sales)

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

Explain the rationale

Our organization has been evolving in ESG themes since we became a PRI signatory in 2012. In the begining our focus was on Governance aspects, than we incorporated the ESG factors into our investment process focused on Private Equity and than we expanded to other asset classes. We have been dealing with climate related issues through our ESG Policy and Management System and through our network of PRI signatories. In the future, we may support the TCFD, but to do that, we want to make sure we will be able to implement their recomendations both at the fund level and at the portfolio companies level - we believe we still need time to be prepared for that.

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

Describe how and over what time frame the organisation will implement an organisation-wide strategy that manages climate-related risks and opportunities.

We do assess climate related risks and opportunities on a case by case, mostly on our Infrastructure and Credit investment strategies that deal with long term utilities projects that can be highly affected by those factrs (e.g. wind power negeration, solar power generation and hydro power)

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.






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].

Our ESG Policy document (question SG 02.1) includes our investment policy components - that´s why the documnt attached is the same.

The Formalised guidelines on ESG are also included in our Investment Policy document that has been uploaded on SG 02.1


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.

On any other matter involving a conflict of interest, the General Partner and the Manager will be guided by its good faith judgment as to the best interests of the Fund and shall take the necessary or appropriate actions as determined by the GP or the Manager to mitigate such conflicts of interest.

In addition, Vinci Partners´ Compliance Manual has a specific clause on "Conflicts of Interest between Managed Funds" that aims to mitigate potential conflicts of interest in transactions involving two or more investment funds managed by the Vinci Group

Moreover, Vinci’s Private Equity Limited Partner Agreement (LPA) treats the following conflicts of interest:

(a) Transactions with Affiliates

(b) Devotion of Time

(c) Other Potential Conflicts of Interest

03.3. Additional information. [Optional]

If the GP or the manager notifies the limited partners with respect to a matter giving rise to a conflict of interest, and if a majority in interest waives such conflict of interest or the GP or the manager acts in a manner, or pursuant to standards or procedures, approved by a majority in interest with respect to such conflict of interest, then none of the other managed entities, the GP, the manager or any of their respective affiliates shall have any liability to the fund or any partner.

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

Our portfolio companies have anonymous whistle blower channels, and depending on the level of the incident, the deal team member responsible for that particular portfolio company is communicated. In addition, we are active investors and are in frequent contact with different levels of the portfolio company´s employees, having firsthand access to potential incidents. Key metrics (e.g. work-related accidents) are also discussed on the board meetings and appropriate measures are demanded by the board.