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Pollen Street Capital

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.

Pollen Street seeks to invest in businesses with differentiated propositions in the financial and business services sector. These 'challengers' are able to offer alternatives to incumbents and often represent the next generation of market leaders. Pollen Street's strong track record has been built on its ability to identify companies with strong underlying attributes; namely those with modern and innovative offerings and extensive data capabilities. Pollen Street believes it can apply its sector expertise to these companies partnering with management teams, founders and other shareholders to create cost efficient, best-in-class operators.

Pollen Street strongly believes that a focus on responsible investing can lower risk and enhance financial returns for its Funds and underlying portfolio companies, while also generating a net benefit for society. As such, embedding ESG diligence and monitoring as part of Pollen Street’s investment activity, and improving ESG performance across its portfolio companies has been, and continues to be, a key focus of the business.

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]

Pollen Street is committed to maintaining and enhancing its focus on the societal impact of its actions in a way that generates enduring long-term returns for investors and society.

To do this, Pollen Street has embedded ESG as a core part of its investment process – from identifying ESG risks pre-acquisition, through to working with portfolio companies post-acquisition to embed Pollen Street’s ESG framework, drive value creation and monitor performance against key criteria - and operates on a continuous-improvement basis. ESG is multi-faceted and there are many ways to engage with it, so we try to focus on those ESG considerations that are most pertinent and where we feel we can have the most impact and these are outlined in our published ESG policy.

We are also cognisant of the ESG priorities of our investors, and how they align with what we do. We therefore ensure that as a minimum our fund investment mandates meet those standards prescribed by our investors

During recent years, Pollen Street has sought to increase the prominence of ESG within its own business and as a signatory to the UN Principles of Responsible Investment seeks to drive continued improvement, including through:

  • Launching a business-wide philanthropy programme engaging employees to determine which charities we should support, and the most effective way to do so. Most recently, this has involved performing a strategic review of a charity that facilitates alumni mentoring of students;
  • Engaging Ten Years' Time (part of the Social Investment Consultancy) to assist in identifying areas where Pollen Street can leverage its existing skillset to have a greater impact on ESG issues going forward. As part of this, we are reviewing several ESG focussed enterprises with which to provide strategic support; and
  • Launching the Pollen Street Hub, providing dedicated resource to drive the ESG agenda both internally and throughout its portfolio companies. Across each of the portfolio companies, the Pollen Street Hub facilitates ESG best practice sharing, conducts workshops and materiality assessments, and assists with the practical implementation of ESG projects while ensuring suitable measures are in place to monitor performance.

Pollen Street’s ESG committee is responsible for setting the strategy, framework and processes for ESG integration across the investment process. The ESG committee monitors activity to ensure compliance with our ESG obligations, and to review improvement opportunities. The ESG committee is chaired by the Head of ESG and includes the Managing Partner and representatives from the investment teams, and other areas of the business such as compliance, operations and legal. Members of the committee were selected from volunteers across the organisation.

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.

Although PSC actively seeks to avoid conflicts of interest, nonetheless they may arise from time to time and so the firm has in place a group conflicts of interest policy and investment allocation principles, which outline the potential conflicts that may arise and how the firm looks to manage them.

With regards to the investment process, an early assessment of potential conflicts is undertaken by the relevant  deal team and Investment Committee with certain categories of potential conflicts being referred to the relevant Pollen Street Funds’ LP Advisory Board or other independent group, as required.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)