Seneca Partners Limited (“Seneca” or the “Company”) ESG Policy 2021
The Board’s decision-making process incorporates, as part of the Company’s investment policy and investment objectives, considerations for supporting the Company’s business relationships with investors, third-party advisers, independent financial advisers, and the impact of the Company’s operations on the community and the environment, which by nature of the business, primarily extends to the holdings in portfolio companies and investment properties.
Outside of general meetings or investor presentations, the Company engages with investors directly through regular updates, interim and annual reports and through day-to-day correspondence to address any queries that arise.
The Company undertakes regular investor/adviser presentations to engage directly with investors. The investor presentations are a fantastic opportunity to engage directly with investors or their advisers and enable the Company to subsequently make changes to address any queries or concerns raised, particularly around improving investor communications. Any queries or concerns which may arise, are discussed by the Board, factored into any decision-making, and disclosed in annual and interim reports where applicable.
The Company holds minority investments in its portfolio companies. Whilst the Board has little direct contact with portfolio companies on a day-to-day basis, the investment managers provide updates at least quarterly and several investment managers hold board positions, which whilst limited in scope, afford the Company a more hands on approach.
Environment and Community
The Company seeks to ensure that its business is conducted in a manner that is responsible to the environment as far as is practicable given the nature of the business. The management and administration of the Company is undertaken in recognition of the importance of its environmental responsibilities, monitoring its impact on the environment and implementing policies to reduce any negative environmental impact and which promote environmental sustainability. Initiatives of the Company are designed to minimise its impact on the environment include recycling and reducing energy consumption. More details of the work undertaken by the Company in this area are set out below.
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 and signing up to major external bodies who are leading influencers in the formation of industry best practice. The following is an outline of the kinds of ESG considerations that the Investment Manager is considering as part of its investment process.
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. In-house, Seneca has taken a number of measures as a business to implement environmental policies, such as the introduction of a recycling program and have recently gone largely ‘paperless’ as a business. As a matter of policy, the Company seeks to reduce energy consumption using heat loss mitigation within its office, the installation of smart meters and encourages the reduction of its carbon footprint throughout the organisation.
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. Investment managers actively engage with portfolio companies and their boards to discuss material risks, ranging from business and operational risks to environmental and social risks.
The Company also regularly holds charity fundraising events throughout the year and maintains close partnerships with both UK charitable organisations and overseas who are committed to local community initiatives and development programmes.
The Company’s in-house compliance teams examine and maintain robust policies in relation to executive remuneration, conflicts of interest, equality and diversity, business leadership and culture as well as adherence to anti-money laundering, insider dealing and anti-bribery regulations and to Financial Conduct Authority Rules and Guidance. In addition, the Company, as a matter of course, exercises its voting rights in portfolio companies whenever possible.
Approved by the Board November 21