Sustainable Investment Policy

STAR Capital Partnership LLP is a UK headquartered mid-market private equity firm specialising in building businesses in Western Europe with a focus on businesses that utilise strategic assets to provide essential services to end users.

We are committed to the integration of sustainability management practices into our business, recognising the potential for material Environment, Social and Governance (ESG) factors to affect the value, resilience and success of our investments and their associated assets, and their potential impacts on the environment, society and the economy.

This policy sets out our principles and objectives for how we will undertake this commitment, which we will apply across all of the funds which we manage or advise as well as our own business operations.

Our Principles

To seek to optimise positive impacts and minimise or negate actual or potential adverse impacts through the integration of ESG/sustainability factors across the lifecycle of our investments.
To promote the highest standards of business integrity and compliance with all applicable laws, both within our direct business undertakings and those of our portfolio companies.
To take account of the interests and perspectives of our stakeholders in making investment and business decisions.
To undertake timely, appropriate and transparent disclosure and reporting in relation to material ESG issues and impacts, using regular monitoring of ESG performance across our portfolio as the cornerstone of our approach.
To continuously develop and enhance our approach to ESG management and demonstrate leadership within our business community and with our portfolio companies.
To uphold and promote the principles of the PRI, which STAR has been a signatory to since 2017.

Our Objectives

To equip and empower our team to implement our principles above, through management support, training and the provision of tools and guidance that enable us to operate a robust and well-defined sustainable investment system.
To play our part in building awareness and action in relation to the net zero carbon agenda and resilience in the face of the potential impacts of climate change on our businesses and our wider stakeholders.
To seek to integrate consideration of the challenges that lie behind the UN Sustainable Development Goals and the principles of the UN Global Compact within our investment and stewardship processes.
To be a sustainable operator ourselves through the proactive management of our direct ESG impacts as a business.

Integration of ESG management into the investment lifecycle

During the pre-investment phase we:

Undertake exclusionary/negative screening of potential investments in accordance with the relevant fund’s investment policy and restrictions.
Develop awareness of potential material ESG risks in the deal-flow pipeline that may mitigate against investment.
Profile ESG risk to identify material adverse factors and value creation opportunities as part of our pre-deal assessment and due diligence, and provide well-considered analysis for the Investment Committee evaluation process.
Document our ESG profiling, decisions and agreed action plans to carry forward into the stewardship phase.

During the stewardship phase we:

Use our governance role to engage with the senior management teams and Boards of our portfolio companies to promote sustainable practices and outcomes, including focus on material ESG issues in the 100-day plan, and by setting a longer term agenda for sustainable value protection and creation throughout our hold period and beyond.
Undertake a review of the business to build a baseline ESG performance assessment with which to evaluate risks and opportunities, engage with the management team on setting objectives and performance standards and the creation of action plans to address the most material matters, and offering support where appropriate.
Seek ESG KPI data (including carbon footprint), and an update against the baseline ESG performance review, on an annual basis to document progress, identify any new issues and opportunities and report to our investors. We will also use this data to make an analysis of performance change during our stewardship and any remaining risk and opportunity at exit.

STAR Sustainable Investment Thematic Framework

We have adopted a thematic Sustainable Investment framework to ensure we consistently consider a wide ranging set of ESG topics for their relative materiality within any business or sector context. This is integrated into our investment lifecycle through our screening and profiling tools, performance assessment and improvement and reporting:

Enviroment	People and Society		Governance
Climate	Health, Safety & Wellbeing	Marketplace Responsibility	Governance & Business Ethics
Waste and pollution	Diversity & Inclusion	Supply chain ethics	Risk & Compliance
Natural Resources	Training & Development	Community Investment	Commitment to Sustainability

Policy Implementation and Review

The Board and senior management of STAR Capital are committed to the proactive implementation of this policy and to providing the support and resources necessary to do this. We will review our policy on an annual basis.