+44 (0)203 961 1570


1, Hooper's Court, London, SW3 1AF, Greater London, England, United Kingdom

Responsible Investment Policy

Our Beliefs

Volpi Capital is a European specialist mid-market private equity investor backing tech-enabled services businesses. We are thesis-driven, collaborative and experienced in driving growth through international expansion and buy-and-build.

We seek to be responsible owners. We believe that understanding the operational aspects of a business, in addition to its financial profile, allows us to manage risk effectively and generate value. We take an active role in our companies, going beyond board participation and working in partnership with management to grow and develop the business and solve problems together.

Environmental, Social and Governance (ESG) considerations impact the way in which we manage the firm, our investment decisions, and our management of portfolio companies. As fiduciaries we recognise that by following a broad set of policy commitments relating to ESG factors, we will better align ourselves and our investors with the broader objectives of society.

Our Responsible Investment Policy

The purpose of this policy is to outline our commitment towards incorporating ESG considerations throughout the investment process. This recognises the importance of not only managing risk, but also identifying opportunities to deliver value through taking a proactive approach to ESG management. Our values provide the foundations to this approach and are integral to who we are and how we manage our portfolio companies:

  • We are no-nonsense - we are sensible, down-to-earth and keep things as simple as possible.
  • We champion our team - we collaborate and support each other and our partners, as we recognise the value of diversity of thought in problem solving and innovation.
  • We embrace change – we believe change is the only way forward and are willing to take one step back for two steps forward.
  • We are fair and transparent – we treat our partners and stakeholders with honesty, integrity, fairness and respect, contributing to strength and longevity of our relationships.

We strongly believe that, through effective management of our values through our investments, we can deliver long term sustainable value growth for our investor base. Our overall themes which we seek to evaluate across our portfolio include, but are not limited to: environmental management, health & safety, people management, suppliers & communities, and governance. Volpi Capital seeks an engaged approach and is committed to evaluating these areas within its portfolio, while also seeking improvement where possible and necessary.

Objectives & Commitments

This policy is in line with both local and international standards, including the United Nations Principles for Responsible Investment (UN PRI.) As a signatory to the UN PRI since 2021, Volpi is committed to integrating its principles into its investment lifecycle, from deal screening to due diligence, and post investment monitoring until the exit period.

As a UN PRI signatory, Volpi Capital has committed to following these expected principles:

  1. Incorporate ESG issues into our investment analysis and decision-making processes.
  2. Be active owners and incorporate ESG issues into our ownership policies and practices.
  3. Seek appropriate disclosure on ESG issues by our portfolio companies.
  4. Promote acceptance and implementation of the principles within the investment industry.
  5. Work together to enhance our effectiveness in implementing the principles.
  6. Report on our activities and progress towards implementing the principles.

We further accept and adopt the definition of stewardship, as meant by PRI, within our business. As such, we use our influence as investor to maximise overall long-term value, including the value of common economic, social and environmental assets. To do so, we engage with our portfolio companies at all stages of the investment cycle and during our role on investee boards and board committees. Being a majority shareholder, Volpi Capital has the strong capability to influence and guide senior leadership towards achieving its ESG goals. Where possible, Volpi provides recommendations directly to the board and constantly follows-up on these recommendations to ensure that stated objectives are reached as expected.

Volpi Capital has also aligned itself with the ILPA ESG Data Convergence Project since 2022, which includes tracking of six primary metrics across its portfolio, in order to increase availability and comparability of key environmental, social and governance related metrics. Additionally, Volpi is investigating whether to adopt the recommendations of the ‘Task Force on Climate-Related Disclosures (TCFD)’, to further incorporate climate-related disclosure.

Guiding Principles for Investment & Exclusions

Responsible investment is a key part of Volpi Capital’s strategy, and thus the business excludes companies within its fund which are directly engaged in the following activities:

  • · The exploitation of human rights, with child or forced labour directly or indirectly within the supply chain, or through other human rights abuses
  • The manufacture, marketing, and distribution of weapons, artillery, and/or ammunition
  • The manufacture, marketing, and distribution of tobacco, distilled alcoholic beverages, pornography, and related products
  • The creation and promotion of gambling such as in casinos, online gaming, or equivalent enterprises
  • The production of products which are illegal under local, UK, or international law
  • The exploration, extraction, and production of coal or crude oil, as well as any other activity which may cause serious environmental damage
  • The development or research of technical applications, such as electronic data programs or solutions, which support activities within our exclusion list

Volpi Capital will withhold investment in companies which conduct business with a person, entity, or country that is the target of UN trade sanctions, in violation of fundamental human rights, or taking part in any illegal activities under local or international law.

Integrating responsible investment principles across the investment lifecycle

We incorporate ESG factors across the investment lifecycle, alongside more traditional financial and business performance considerations. We not only view these activities as a way of managing business risk, but also to deliver opportunities to increase shareholder return and create long-term sustainable value. The process we follow to integrate ESG considerations in our investment activity is highlighted in the diagram below. This process complements the sustainability risk policy that is developed in line with the SFDR (https://www.volpicapital.com/volpi-capital-sustainability-risk-policy).

ESG in our investment lifecycle

ESG Due Diligence

ESG post-investment

ESG upon exit

Due diligence exercise to identify and understand ESG risks and opportunities

External ESG assessment post-deal as required by the 100-day plan

Document ESG improvements during Volpi ownership

3rd party ESG specialists brought in where specific risks have been identified

Implementation plan to ensure key material risks and opportunities are addressed by management

Include ESG factors in vendor due diligence

ESG Due Diligence

Volpi Capital performs an ESG analysis pre-investment as part of the due diligence process to understand gaps and opportunities for investments. Where gaps are identified, we establish improvement areas and decide on risk mitigation strategies. Volpi Capital does employ positive selection criteria to seek out lead performers, but also seeks companies with strong improvement potential.

Any identified ESG issues will be reported to the investment team, and actions to minimise risk and/or realise potential opportunities are agreed with the senior management team of the investee company. We have committed to ensure each investee company receives an external ESG assessment post Volpi investment and implements any resulting recommendations which improve upon current performance. These recommendations will form the basis of a 100-day plan, which will be tracked by investment managers, as well as followed up on for each yearly assessment.

ESG post-investment

We apply an ESG assessment framework to understand the material risks and opportunities within our portfolio companies. As a minimum requirement we expect companies to comply with all applicable laws and regulations in the countries in which they operate. Our framework covers a broad range of impact areas, including but not limited to:

Environmental – As our investment strategy targets asset light businesses, supplying tech enabled services, we would not expect our portfolio companies to have any material environmental impacts. However, we still encourage companies to identify and implement measures to reduce their environmental impact. Key environmental indicators include the following: environmental management, energy management, waste management and water management.

Social – We require portfolio companies to be equal opportunities employers and provide learning and development opportunities for employees. We do not tolerate unfair, discriminatory, illegal or immoral work practices either in the portfolio company or within the supply chain. We also encourage open communication to ensure companies provide a safe working environment which promotes positive staff wellbeing. Key social indicators are categorized along the following areas: Health & Safety with policies, procedures and training; People with recruitment, retention, learning & development, diversity and inclusion; Community and charity with community engagement.

Governance – We view corporate governance as the combination of processes and structures implemented by the board in order to inform, direct, manage and monitor the activities of the organisation towards the achievement of its objectives. Our focus on governance is to ensure our portfolio companies have a board which delivers strong leadership, is effective and well balanced, accountable, awards sufficient levels of remuneration, behaves in an ethical manner and engages with shareholders. Key indicators within governance include the following: general governance, anti-bribery and corruption, whistleblowing, cyber/data security, and diversity & inclusion, alongside suppliers and customers.

Post investment we will strengthen the board by appointing an independent and experienced non-executive Chairman, an improved finance function and the addition of experienced non-executive support from Volpi. Following the investment process, we discuss the improvement plans’ successes and priorities, along with suggestions on how to continue to improve after full divestment. We actively integrate stewardship principles by ensuring continuity on the board and leadership of ESG aspects upon departure from the investment phase.

ESG upon exit

We strive to grow our portfolio companies substantially during the holding period, while managing ESG risk and, where possible, capturing ESG opportunities. During the holding period, we document ESG improvements, to ensure that these improvements are explicit upon exit. In order to facilitate continuation of these ESG improvements upon exit, Volpi incorporates prioritized ESG aspects into the vendor due diligence process.

Implementation of the policy

We commit to communicating this policy to all investee company boards and will regularly discuss ESG management at our portfolio review meetings. We will report any relevant material ESG concerns to investors in our quarterly valuation reports on a case-by-case basis, as appropriate.

This revised policy has been discussed with and circulated to all Volpi staff. This document is an update to our December 2021 policy; reflecting how we have enhanced our approach to responsible investment. Volpi partners will be responsible for the implementation of this policy and will complete a periodic review to ensure its continued relevance.

ESG at Volpi

Volpi Capital upholds itself to the same high standards which it requests for its investee companies. The internal governance of the firm prioritizes work-from-home schemes, along with low-carbon commuting and minimized business travel to reduce its environmental impact. Further, the firm is prioritising the utilisation of less paper and plastic, along with sustainable energy management in-office. As a people focused business, Volpi Capital invests in the personal development of its employees through training programs, along with offering private health insurance.

Information about the Sustainable Finance Disclosure Regulation (SFDR)

This Responsible Investment Policy is in accordance with regulatory requirements and applicable legislation such as the Sustainable Finance Disclosure Regulation (SFDR), which forms part of the EU’s Sustainable Finance Action Plan.

More information about Volpi Capital’s obligations under the Sustainable Finance Disclosure Regulation is available on the website at https://www.volpicapital.com/sustainability-related-disclosure.

Sustainability Risk Policy

Information about Volpi Capital’s consideration of sustainability risks is available on the website at https://www.volpicapital.com/volpi-capital-sustainability-risk-policy.

Principal Adverse Impact Statement

Information about Volpi Capital’s consideration of principal adverse impacts is available on the website at https://www.volpicapital.com/principal-adverse-impact-statement

June 2022