Introduction

Markham Rae is a firm which establishes and builds asset management processes which offer investors focused exposures to sources of return which are otherwise difficult to access.

Markham Rae aims to ensure its business is sustainable in the longer term. To achieve this, it is Markham Rae policy to give appropriate consideration to Environmental, Social and Governance (“ESG”) factors. Markham Rae recognises that the integration of ESG considerations into its business processes can have an impact on financial performance and sustainability.

Markham Rae has prepared this policy document after careful consideration of the various risks and issues affecting the sustainability of its business and investment strategies, and having taken into account relevant industry standards and guidelines, including, but not limited to:

  • The UN Global Compact
  • The UN Principles for Responsible Investment
  • The HFSB Standards
  • The ILPA Private Equity Principles
  • The International Financial Reporting Standards
  • The UK Financial Reporting Council’s Stewardship Code
  • The FCA Principles for Approved Persons

This ESG policy applies firmwide to all Markham Rae business activities and investment strategies. The policy is approved by the Board of Partners of Markham Rae LLP. Responsibility for maintaining and periodically reviewing the ESG policy is the responsibility of the ESG Officer.

The policy is set out in the format of six principles:

Principle I: Encourage a work environment which values and respects all employees

Markham Rae complies with relevant regulations governing the protection of human rights, occupational health and safety standards and labour, environmental and business practices of the jurisdictions in which we conduct business.

Principle II: Incorporate ESG considerations into all investment analysis and decision making processes where relevant

ESG criteria are to be taken into account during the analysis and decision making processes for all investments made by Markham Rae where relevant. The varied nature of some of Markham Rae’s strategies makes this more relevant to some strategies than others.

Principle III: Ensure firmwide awareness of ESG issues and compliance with the firm ESG policy

Markham Rae has a nominated ESG Officer who reports directly to the Board of Partners of Markham Rae LLP. The ESG Officer is responsible for maintaining and reviewing the ESG policy, and disseminating the ESG policy to all personnel of Markham Rae. The ESG Officer monitors adherence of all Markham Rae investment teams to the policy.

Principle IV: Adopt a responsible and ethical approach to governance

Markham Rae ensures the implementation of compliance policies and procedures, and of on-going monitoring of the group’s systems and controls. Markham Rae also ensures the implementation of rigourous risk controls throughout the business. Markham Rae complies with FCA compliance requirements for an FCA-authorised firm.

Principle V: Promote awareness and adoption of ESG considerations

Markham Rae undertakes, where appropriate, to share the outcome of any ESG investment analysis with the appropriate personnel at an investment target or counterparty firm, with a view to encouraging better management and communication of ESG concerns.

Principle VI: Inform our investors of this ESG policy and provide them with information on our approach to ESG issues

Markham Rae ensures the provision to investors of transparent and objective information on ESG policy, procedures, and analysis when available. Markham Rae seeks to encourage dialogue on how we can accommodate ESG issues in a way that is consistent with Markham Rae investors’ initiatives in these areas.