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Orlando Management AG

Service Providers Framework 2020

You are in Strategy and Governance » Policy on ESG beliefs

Policy on ESG beliefs

SG 01. Responsible investment policy

01.1. Describe how your organisation’s philosophy incorporates environmental, social and governance factors, and the link to your business offerings.

RESPONSIBLE MANAGEMENT

1. Orlando Management AG shall adhere to and promote responsible management practices in its internal affairs as well as in all advisory activities at the level of the Portfolio Companies. Orlando Management AG shall thus periodically consider and appropriately manage ESG factors in undertaking any and all business activities.

Orlando Management AG shall exercise its influence in respect of the Portfolio Companies, such that they also adhere to and implement these ESG guidelines.

INTERNAL ORGANISATION

2. The members of the board, as well as the investment professionals shall be provided with adequate training in respect of ESG. The ESG performance and compliance shall form an appropriate part of each employee’s and partner’s individual appraisal.

3. Orlando Management AG shall strive to ensure that any persons employed or otherwise engaged by it adhere to these ESG guidelines. An undertaking to such effect will generally form a part of any corresponding contractual relationship.

4. Orlando Management AG shall create a comprehensive, internal compliance manual pertaining to ESG issues, as well as other compliance-related matters, such as anti-money laundering and the prevention of corruption and bribery, and shall ensure that all directors, employees, contractors and agents are contractually obliged to comply with such manual.

5. Orlando Management AG shall appoint a person responsible for compliance matters, who possesses the relevant capabilities and sufficient experience, to ensure Orlando Management AG’s compliance with this ESG policy and its other ESG-related obligations (the “Compliance Officer”). The Compliance Officer shall also serve as the point of contact for investors and Portfolio Companies with respect to ESG-related questions. The Compliance Officer shall promptly notify Orlando Management AG of any material ESG-related risks that manifest or any material ESG-related incidents that occur, whether such risks or incidents occur at the level of Orlando Management AG or in the Portfolio Companies. The Compliance Officer shall also act as the contact person for informants and shall accept the anonymous provision of compliance-related “tip-offs” from such persons. The Compliance Officer shall document the way in which such compliance-related information is dealt with and the actions taken with respect to breaches of ESG and other compliance-related obligations.

6. Orlando Management AG shall consider reasonable requests to alter and/or expand its compliance manual, whether such stems from Investors and/or is a result of the ongoing development of ESG matters. Orlando Management AG shall continuously monitor and optimise its internal organisation in view of ESG performance and compliance.

7. Orlando Management AG shall ensure that Orlando Management AG, as a company, is charitably and socially active both locally and globally, in a sustainable, conscientious and exemplary manner (“Good Citizen”) and encourages and incentivises its employees and business partners to do the same.

 

01.2. Indicate whether you have policies that formalise the incorporation of your ESG beliefs in your business offerings.

01.3. Indicate the components/types of your internal policy and provide the URL and/or an attachment of the document/s if they are publicly available.

Policy components/types

Public availability

Public availability

01.4. Indicate how these are put into practice internally across the organisation.

01.5. Additional information [OPTIONAL]


SG 02. Norms used to develop policies

02.1. Indicate what frameworks and guidelines you have used to develop your organisation’s policies. Tick all that apply.

02.2. Additional information. [OPTIONAL]


SG 03. Policy offerings to clients

03.1. Indicate whether you offer standard, off the shelf, policies to clients as part of your product offerings, and/or whether you create tailored versions for individual clients.

Off the shelf
Tailored
Asset class-specific RI guidelines
Sector-specific RI guidelines
Screening/exclusions policy
Engagement policy
(Proxy) voting policy
RI guidelines set out within the Investment Policy Statement (IPS)
RI guidelines set out in a freestanding RI policy
Multi-year RI implementation project plan
Conflict of interest management policy
Stockbroker allocation policy
Securities lending policy
Other, please specify (1)
Other, please specify (2)
Other, please specify (3)
None of the above

03.2. Provide a brief description of the key elements, any variations, or exceptions applying to these policies.

ESG factors and RI-considerations are taken into consideration throughout the business system of Orlando Management AG, i.e. Six Principles of our Investors are defined and consequently applied:

1. ESG topics are part of investment decisions: Due Diligence and investment recommendations supplied to Investors consider the ESG factors and quite regularly Environmental Studies are performed during Due Diligence.

2. Active management of ESG topics into the corporate policies of our portfolio companies during the holding period: Once the Funds/Investors have acquired a Portfolio Company (“Client”), Orlando Management AG creates awareness for ESG factors and RI-considerations early on

3. Full transparency of ESG problems as soon as they are identified in the portfolio companies

4. Effective implementation of ESG principles in portfolio companies: Orlando Management AG integrates major ESG KPIs in standard reporting of the Clients

5. Regular updates about activities to improve ESG guidelines: managers of the Clients are regularly not only tested on ESG factors and RI-considerations, but also on potential Compliance issues.

6. Active advertising of principles of responsible investment in the Private Equity environment

03.3. Additional information. [OPTIONAL]


SG 04. ESG/RI in business offerings

04.1. Briefly describe how you include ESG/RI factors as part of your business offerings.

Business area

Investment Consultancy

How you include ESG/RI factors

see 4.02

04.2. Indicate the roles in your organisation, and indicate for each whether they have oversight and/or implementation responsibilities for ESG/RI within the organisation.

Roles present in your organisation
Oversight/accountability for ESG/RI
Implementation of ESG/RI
Board
Directors
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Chief Operating Officer (COO), Chief Information Officer (CIO)
Other chief-level staff
Other heads of department
Dedicated ESG/RI staff
Other role, specify (1)
Other role, specify (2)
Other role, specify (3)
None of the above

04.3. Indicate how you ensure ESG/RI expertise for the roles where there are RI oversight/accountability or implementation responsibilities.

04.4. Indicate whether your organisation has any ESG/RI linked incentives for its employees.

04.6. Describe how you ensure that your employees incorporate ESG/RI into services through other mechanisms than ESG/RI linked incentives.

ESG/RI principles are actively managed into the corporate policies of the portfolio companies. Adherence to these polices is supervised on a regular basis.

04.7. Additional information [OPTIONAL]


SG 05. Outsourcing of services (Private)


SG 06. Providing training/education

06.1. Indicate whether you provide training/educational services on ESG/RI. Tick all that apply.

06.4. Additional information. [OPTIONAL]


SG 07. Applying, advancing and promoting the PRI principles

07.1. Describe how your organisation applies, advances and promotes the PRI Principles.

ESG issues are part of our advisory work (see the Six Principles of our Investors as described under SG 03.2). We try to advance PRI principles through a KPI based reporting process in the Fund´s portfolio companies after having considered ESG principles in the initial investment recommendation. Further promotion of PRI principles and ESG practices come with experience and over time.

07.2. Highlight whether there are any ways that your organisation would like to engage further with the PRI. [OPTIONAL]


SG 08. Actions taken to promote responsible investment

08.1. Indicate which of the following actions your organisation has taken to promote responsible investments during the reporting year, independently of collaborative initiatives.

08.2. Additional information. [OPTIONAL]


SG 09. Long term trends

09.1. Indicate which of the following long-term trends are addressed in your product outputs.

09.3. If none of the above are applicable, please explain why not.

Orlando Management as the investment advisor of two PE Funds is too small to dedicate resources to analyze such long-term trends.


SG 10. Interaction with asset owners

10.1. Indicate whether you interact with asset owner clients.

10.2. Indicate the typical frequency and type of interactions with your asset owner clients.

Type of interaction

Frequency

Frequency

Frequency

10.3. Additional information. [OPTIONAL]


SG 11. Aligning approach with investor goals

11.1. Describe how you typically align your organisation’s philosophy and approach to ESG/RI with your investor clients’ goals.

All of our investors have rather individual ESG/RI goals and awareness, however our Investors have agreed upon the Six Principles as described under SG 03.2. To understand if Orlando Management ESG/RI policy covers all goals we discuss adherence to the Six Principles as well as individual goals with investors and check against the existing policy also in the context of regular questionaires that the General Partner of the funds advised by Orlando Management AG receives. Orlando Management AG supports the General Partner in returning completed questionaires. The questions alone are already good indicators of the Investors ESG/RI goals.

11.2. Additional information. [OPTIONAL]


SG 12. ESG recommendations not aligned with investor goals

12.1. Describe what steps you take, if any, when your ESG recommendations are not in line with your investor clients’ goals.

So far, ESG recommendations have been in line with investor goals. If this should not be the case, we might amend policy where necessary and possible.

12.2. Additional information. [OPTIONAL]


SG 13. Seeking feedback from clients

13.1. Indicate whether you seek feedback from clients on your RI/ESG services and product offerings

13.2. Describe how you use this feedback in your RI/ESG services and product offerings.

We check if their feedback is in line with existing policy and if not, evaluate potential amendments.


SG 14. Managing conflicts of interest

14.1. Indicate whether your organisation has a policy for managing potential conflicts of interest.

14.2. Describe how you manage potential conflicts of interest.

The General Partner of the Funds advised by Orlando Management AG might call for an advisory board meeting to discuss and help resolve potential conflicts of interest.

14.3. Describe how you ensure that company employees do not derive any personal gain from the use of information collected during your work process.

Orlando Management AG has a confidentiality and data protection agreement in place that is signed by each employee.

14.4. Additional information. [OPTIONAL]


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