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Vision Capital LLP

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.

Vision Capital is a leading international investor in mature mid-market companies spanning a broad range of sectors. We set out to achieve the long-term goals and aspirations of our clients by responsibly delivering superior investment returns. We are mindful that our opportunities arise because others trust us and respect our capabilities and that without our reputation for honesty, integrity and good practice we could not operate as we do.

We believe that integrating Environmental, Social and Governance (“ESG”) considerations into the way we operate is an important part of delivering superior returns and playing a responsible role in the wider business community. Our Responsible Investment Policy sets out the guiding principles that we commit to in order to achieve such an integration, and to make it a fundamental part of the way that we do 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]

We regard these principles as long term commitments which will guide both our ethos and our practice as an investment house. They are:

1. We will integrate ESG considerations into our investment analysis and decision-making processes in order to build and protect value through our business transactions while preventing avoidable harm to people, society and the environment.

2. We will seek appropriate disclosure of ESG matters by the companies we invest in so that we have a clear understanding of what we are investing into.

3. We will exercise our influence as active owners to encourage responsible business practices within our portfolio companies.

4. We will seek to provide meaningful and transparent reporting of our responsible investment performance, spanning our own activities and those of our portfolio companies to those who have a material interest.

5. We will welcome dialogue with our Limited Partners and other significant stakeholders to further the practice of responsible investment within our own business and more widely in the investment community.

We will aim to align our operational practice to the United Nations-supported Principles for Responsible Investment as far as is practical within our resources. Our whole team will be expected proactively to participate in the promotion of our Principles within the firm and externally.

Investment Objectives

Overarching objectives:
1. To maximize commercial success through our investment activity, while avoiding or minimising negative ESG impacts.
2. To comply proactively and consistently with all relevant laws.

ESG-specific objectives:
Our bespoke Responsible Investment Framework puts Governance (G) to the fore, as we strongly believe that it is necessary to get that right in order to maximize our efforts in matters under the Social (S) and Environment (E) headings.

To ensure that our portfolio businesses are run in an exemplary way with a strong governance focus on:

- Risk management and compliance, including protecting value and avoiding risk
- Transparency and accountability, especially in matters of material relevance to stakeholders
- Business efficiency and ethics, creating value and a culture of ethical business behaviour

To ensure that our portfolio businesses understand and respond to the interests that are of paramount importance to their stakeholders, paying particular attention to those of:

- Employees, including their safety and wellbeing, equality of opportunity and development
- Customers, and wider society affected by products and service put into the market place
- Supply chain, including those working in overseas jurisdictions as well as close to home
- Community and wider society, including impact on local and wider economies

To ensure that our portfolio businesses are aware of the actual and potential impacts they may have on the environment, are committed and equipped to prevent unnecessary and lasting harm, and where possible can effect active protection and enhancement, including in the areas of:
- Consumption - avoiding or minimising consumption of non-renewable and scarce resources in favour of better efficiency and adoption of sustainable resource use
- Waste, pollution and impact on the local environment – careful management of operations to avoid and minimise any direct or local negative impacts to the environment
- Wider environment – having care and consideration about operations, and what goes into the marketplace, in terms of impact on the wider and global environment.

Caution zones
We will take a precautionary approach to investment decisions when we consider an investment or investment situation seems likely to contravene any of our Principles or Investment Objectives as set out above, and which cannot be addressed within the foreseeable lifetime of our proposed investment or business relationship.

We have opted not to create a list of absolute exclusion areas for investment in favour of the more flexible method of adopting the precautionary approach, which we believe can respond readily to trends and changes in ESG risks as they arise in the marketplace.

Management commitment
We will commit to providing sufficient and appropriate resources and support for our team to pro-actively implement our Principles and Investment Objectives in-house and to cascade the implementation into our portfolio and other significant business relationships.

Endorsed by the Vision Capital Partner Group

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].

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.

Vision Capital's policy on managing conflicts of interest in the investment process requires the firm and its employees to abide by the FCA rules on identifying and managing conflicts of interest. In particular:

1) Members of the investment team consider on an ongoing basis whether potential conflicts of interest have arisen and ensure they are managed properly with reference to the fund limited partnership agreements. If a conflict of interest cannot be managed properly by reference to the limited partnership agreements, the investment team is responsible for bringing conflicts of interest to the formal attention of the Investment Committee for prompt resolution. To the extent the Investment Committee cannot resolve a conflict of interest then the conflict of interest will be referred to the relevant investor Advisory Committee for resolution.

2) Any and all related party transactions are fully disclosed in quarterly reports to investors and any required consents sought.

3) In the event of an actual or potential conflict of interest involving personnel, Vision Capital will take appropriate or necessary steps to separate roles and responsibilities so that decisions are made by different personnel and the conflicted personnel are removed from the position of conflict as far as possible.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)