Seneca Partners Limited (“Seneca” or the “Company”) Environmental, Social and Governance (ESG) Statement 2026
The Board’s decision-making process incorporates, as part of Seneca’s investment policy and investment objectives, considerations for the identification and mitigation of sustainability risks, ensuring that ESG factors are integrated into our fiduciary duty to protect and enhance long-term investor value, and the impact of Seneca’s operations on the community and the environment.
By the nature of the Seneca’s business, this primarily extends to the holdings in portfolio companies and investment properties.
Environmental, Social and Governance (“ESG”) Practices
The Board recognises the importance of providing detailed information about environmental matters (including the impact of the Company’s business on the environment), employee and human rights, social and community issues, including information about any policies it has in relation to these matters and effectiveness of these policies.
The Company recognises that managing investments on behalf of clients involves considering a wide set of responsibilities in addition to seeking to maximise financial returns for investors. Industry practice in this area has been evolving rapidly and the Company seeks to be an active participant by working to define and strengthen its principles accordingly. This involves both integrating ESG considerations into the Company’s investment decision-making process as a matter of course by utilising a standardised approach as part of our considerations of all prospective investments. This ensures a consistent, data-led assessment of climate risk and social impact before capital is committed. The following is an outline of the kinds of ESG considerations that Seneca is considering as part of its investment process.
Environmental
Seneca, as part of its commercial due diligence practices and ongoing monitoring, examines potential issues which could arise from supply chains, climate change and environmental policy compliance. The Company looks for management teams who are aware of the issues and are proactive in responding to them.
At a corporate level, Seneca promotes environmental responsibility within our head office through energy-efficient LED lighting, smart climate control systems, and the provision of electric vehicle charging points. We aim to operate our business with a focus on resource efficiency, reducing our carbon footprint through paperless communication and waste reduction initiatives.
In addition to the steps that the Company is undertaking we also seek to encourage our customers and suppliers to look to reduce their impact on the environment where possible. For example, we encourage the use of paperless communication and digital signatures.
Social
Seneca seeks to avoid unequivocal social negatives, such as profiting from forced labour within its investment portfolio and to support positive impacts which will more likely find support from customers and see rising demand. Seneca does not tolerate modern slavery or human trafficking within its business operations and takes a risk-based approach in respect of our portfolio companies.
As appropriate the investment team actively engages with portfolio companies and their boards to discuss material risks, ranging from business and operational risks to environmental and social risks.
Where the relative size of our holding limits our ability to direct the day-to-day operations of portfolio companies, we use our pre-investment due diligence to ensure our capital is not supporting unethical practices. We monitor our portfolio through the regular reporting and updates provided to us as shareholders.
The Company is committed to engage with employees to provide a work environment which is challenging, dynamic, diverse and inclusive. We support the professional development of our colleagues and will seek to promote a good work life balance. During the year the Company will run a variety of social events which look to help team building and promoting a good corporate culture. Such social events are crafted to include a mixture of activities to ensure that they appeal to employees of all backgrounds.
Further the Company actively invests in supporting the mental health of its employees. All employees have access to an Employee Assistant Programme offered by Health Assured Ltd offering support in a variety of situations. The Company also runs a Mental Health First Aid programme in which a number of employees receive training to act as Mental Health First Aiders.
Finally, the Company engages with charitable causes, this includes holding fundraising events and maintaining close partnerships with charitable organisations. The Company works with both International and smaller local charities.
Ethical Governance
The Company’s board aims to set a good example for all employees in respect of demonstrating ethical governance. The focus is to promote transparency, strong oversight and appropriate risk management. This will help the Company achieve its goal of long-term preservation of value in the Company.
The Company’s in-house compliance team examine and maintain robust policies in relation to executive remuneration, conflicts of interest, equality and diversity, business leadership and culture. Further the compliance team ensure adherence to anti-money laundering, insider dealing, anti-bribery regulations and to Financial Conduct Authority Rules and Guidance.
Seneca exercises its voting rights where we believe it is in our clients’ best interests and where the size of our holding allows for meaningful participation. The Company’s investment team will consider the interests of Company clients and any wider concerns when exercising its voting rights.
Key stakeholders
Employees
We understand that employees are a key factor in ensuring ESG compliance. The Company aims to empower all of its employees to act in a manner which is consistent with our ESG aims. Colleagues are encouraged to consider how their actions could have an impact on the wider world.
In respect of environmental concerns, employees are encouraged to consider changes that can be made both large and small. In respect of small differences, Seneca actively encourages ways to reduce the impact of travel. This would include encouraging use of public transport, car sharing and virtual options for meetings as appropriate. In respect of larger investments into the environment. Seneca, as noted, has installed electric car charging points and looks to recycle waste where possible, including old ink cartridges. Employees are encouraged to make use of such facilities.
In respect of social concerns, employees are empowered to challenge any discriminatory behaviour with clear procedures for reporting any concerns. All staff receive Equality & Diversity training each year and this is regularly reviewed to ensure that it delivers the appropriate outcomes. All staff complete annual HR Compliance & Wellbeing Essentials training. This covers Equality, Diversity and Unconscious Bias;
Bullying and Harassment, including Sexual Harassment; Conflict Resolution; and Mental Health.
Seneca also undertakes a yearly risk assessment as part of its reasonable steps to prevent sexual harassment.
Seneca takes all reasonable steps to look to promote Equality and Diversity in all aspects of the Company’s work. We are committed to promoting equal opportunities in employment and creating a workplace culture in which diversity and inclusion is valued and everyone is treated with dignity and respect. As part of our zero-tolerance approach to discrimination in any form, our staff and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics). We are also committed to providing equitable treatment to all those we deal with as an organisation, including customers and suppliers.
In respect of ethical governance, the Board of Seneca take an active role in further the goals of ESG Compliance. As noted, Seneca has an independent Compliance department which is responsible for monitoring the Company’s activities and employees are required to seek their guidance as required. Seneca has clear policies to seek to prevent unethical and illegal behaviour such as bribery and insider trading. Employees will alert senior management to poor behaviour and are guided by these policies should they have any doubts on expected standards.
Investors
The Company engages with investors directly through regular updates, interim and annual reports and through ordinary correspondence, as required, to address any queries that arise.
The Company will seek to communicate with investors in the most appropriate method based on their investment. Where possible this will be via environmentally friendly methods. Seneca actively encourages investors to receive updates electronically and has undertaken projects to encourage investors to use this methodology. Nevertheless, Seneca does recognise that some investors may prefer or require paper based correspondence, such as where the investors are vulnerable and unable to access electronic updates.
In respect of social concerns, the Company ensures that all investors are treated fairly and in a manner that they would expect. There are no barriers to invest or engage with the Company which would directly or indirectly relate to personal characteristics including but not limited to gender, race, faith, medical conditions or age.
In respect of governance, dependent on the product, the Company will carry out regular presentations or seminars to engage directly with stakeholders such as investors and/or their advisers. This may either be on a large-scale basis such as the Seneca Growth Capital VCT investor presentations and the training seminars with advisors or a smaller scale in the case of meetings with individual advisers.
The Company will examine the best methodology of delivering such presentations and this may include using online facilities to reduce travel where it is appropriate to do so.
These presentations are a fantastic opportunity to understand stakeholder positions and enable the Company to subsequently make changes to address any queries or concerns raised. This may include improving communications and understanding. Any queries or concerns which may arise, are discussed by the Board, factored into any decision-making, and disclosed to investors in reports as appropriate.
Portfolio Companies
Prior to any investment, Seneca carries out a full review of the proposed Portfolio company. This will include consideration of any ESG concerns. Whilst not the only factor, a proposed Portfolio company’s commitment to ESG (or lack thereof) may determine whether an investment is made.
In respect of environmental and social concerns, the Company seeks to avoid investments which have a negative impact on the environment or a cavalier approach to social issues. Conversely Seneca has invested in companies which have focussed on renewable energy and/or which aim to provide a positive contribution to society such as medical research.
Further in respect of social concerns, the Company has taken proactive steps of tackling inequality within the investment scene by signing up to the “Investing in Women Code”. This is a government initiative to improve female entrepreneurs’ access to finance, tools, resources they need to grow their businesses.
In respect of governance, the Company will monitor the Portfolio Companies. Whilst the Board has little direct contact with portfolio companies on a day-to-day basis, the investment team provide updates which will be considered on at least a quarterly basis. Further in some Portfolio Companies, employees of the Company may hold board positions. Such positions whilst limited in scope, afford the Company additional visibility on the Portfolio Companies. It is noted that the Company holds minority investments in its portfolio companies and therefore cannot ordinarily force change. However, the Company will seek to raise any concerns through appropriate channels and by taking any appropriate action.
Regulatory Transparency, Anti-Greenwashing and Investment Labels
In accordance with FCA requirements, Seneca is committed to ensuring that all sustainability-related statements are fair, clear, and not misleading. This includes any statements made in the promotion of Seneca’s products.
At present, none of Seneca’s products have adopted any of the Investment Labels which were introduced by the FCA in PS23/16. As new products are launched, Seneca will consider whether the product meets any of the principles of the labelling regime and whether a label is appropriate. However, the absence of a label does not indicate that a product fails to follow ESG principles. Irrespective of labelling, Seneca ensures all investment activities align with the standards set out in this statement.
Regarding our portfolio companies, we monitor their sustainability-related promotional material on a proportional basis. If we identify concerns regarding the validity of any environmental or social claims, we will raise these with the relevant management team to mitigate potential greenwashing risks.
Conclusion
The Company understands that ESG is about achieving balance between many, sometimes conflicting interests. We view ESG as a continuous process of reviewing our operations and ensuring that they match with our values as a company.
Approved by the Board 11 August 2026