Sustainability Policy

Background and Purpose

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.

STAR is 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.

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

Our Objectives

To equip and empower our team to implement our principles below, through management support, training and 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 stakeholder.
To seek to integrate consideration of the challengers that lie behind the UN Sustainable Development Goals and the principles of the UN Global Compact within our investment and stewardship.
To be a sustainable operator ourselves through the proactive management of our direct sustainability impacts as a business.
To support portfolio companies on the delivery of their sustainability strategies.

Sustainability Governance

STAR has structured its governance model to provide a solid foundation for implementing and overseeing sustainable priorities within the firm and its portfolio companies.

STARs ESG Committee is chaired by Jack Holmes who is the Sustainability & ESG Manager at STAR. Other members of the ESG committee include.

Paul Gough (Managing Partner)
Laura Carballo (Partner & Head of Portfolio Management)
Marco Conca (Principal Portfolio Team)
Kaytlin Hunter (Legal & Compliance Associate)
Louis Stevens (Head of Investor Relations & Fundraising)

STARs ESG Committee is responsible for.

Reviewing internal sustainability policies & procedures
Driving sustainable agendas and strategies within STARs portfolio and
Analysing & reviewing sustainability reporting

The Executive Board of STAR has overall responsibility for the sustainability strategy across the firm. The Executive Board receives relevant information regarding sustainability matters at each monthly board meeting.

Our Principles

STAR has a commitment to responsible investment and ownership principles and became signatory of the UN Principles for Responsible Investment (UN PRI) initiative in 2017. STAR’s sustainable investment policy and approach closely aligns with the firms sustainability strategy.

Environment Principles
STAR aims to manage the impact of climate risks in our investment decisions and portfolio management, seeking to improve the portfolio company’s climate performance over the ownership period to ensure future-proof business growth.

Social Principles
STAR aims to establish the right procedures and policies to ensure safe working environment and drive human capital development.

Governance Principles
STAR aims to ensure a future-proof system for data privacy, data security and ethical business conduct on both the group level and within the portfolio.

The main material sustainability topics for STAR are displayed below.

Enviroment	Social	Governance
Greenhouse gas emissions	Talent attraction, retention and development	Cyber security and data protection
Climate risk	Health and safety	Business ethics

Integration of Sustainability Management into the Investment Cycle

Throughout the investment lifecycle, STAR seeks to implement and consider sustainability through all stages. The investment team along with the Sustainability Manager has responsibility for assessing the ESG risks and opportunities for new investments.

During the pre-investment phase STAR:

Undertake exclusionary/ negative screening of potential investments in accordance with the relevant fund’s investment policy and restrictions.
Develop awareness of potential material sustainability issues in the deal-flow pipeline that may mitigate against investment.
Profile sustainability risks 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 sustainability profiling, decisions and agreed action plans to carry forward into the stewardship phase.

During the stewardship phase STAR:

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 sustainability issues in the 100-day plan, and by setting a longer term agenda for sustainable value protection and creation throughout STAR’s hold period and beyond.
Undertake a review of business to build a baseline sustainability performance assessment with which to evaluate risks and opportunities, engage with the management team on setting objectives and performance standards and the creation of actions plans to address the most material matters, and offering support where appropriate.
Seek to collect sustainability KPI data (including carbon footprint), and an update against the baseline sustainability 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.

Reporting

For more information regarding how sustainability is integrated into our investment process, please see our annual Sustainability Report.

Roles and Responsibilities

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 continue to review this policy on an annual basis.