SFDR Disclosures



Sustainability risk management is embedded in the way Invision seeks to originate investments and make investment decisions, as well as in ongoing portfolio and asset management activities. As a firm, we believe that doing the right thing is consistent with creating value. By considering sustainability as a key component of Invision’s business model, we believe we can seize value creating opportunities whilst mitigating downside risk.

Invision recognises the importance of identifying, assessing and managing material sustainability risks as an integral part of conducting our business. We consider ESG factors throughout our decision-making process and apply these to all the funds that we raise and the assets we have under management.

Invision’s sustainability risk policy provides a comprehensive framework for integrating sustainability risk management into investment decision making.


How does this Sustainability Risk Policy work?

The Sustainability Risk Policy sets out how sustainability risks are integrated into Invision’s investment decision-making processes.

As an integral part of its business principles, Invision is committed to promoting responsible investment practices. Sustainability is a core component of Invision’s business strategy and underscores its approach as a long-term, value-adding investor.

The guidelines contained in this document outline the commitment to responsible and sustainable investing.

Environmental Issues

Invision is committed to sustainable, environmentally sound business practices and will encourage the Funds’ Portfolio Companies to consider the following environmental factors in pursuing their commercial objectives:

  • Air and water pollution should be minimised and monitored under appropriate regulatory standards
  • Biodiversity should be respected and supported

Climate change aspects of industrial operations should be monitored (including policies to mitigate climate change and the impacts of climate change)

  • Deforestation of native vegetation should be minimised
  • Energy efficiency can have direct economic benefits and should be promoted
  • Hazardous materials should be handled according to applicable regulations
  • Land degradation should be avoided or its long-term effects mitigated
  • The depletion of finite resources should be considered
  • Waste management practices should be optimised to maximise environmental benefits

Social Issues

Invision recognises that businesses and the Funds’ Portfolio Companies, can achieve substantial long-term benefits from being socially responsible and by participating as active members in their local communities. Accordingly, Invision aims to consider the following social issues in pursuing commercial objectives, and will encourage the Funds’ Portfolio Companies to do the same:

  • Customer satisfaction should be a day-to-day priority
  • Data protection and privacy principles should be respected
  • Diversity and equal opportunity should be promoted both within our own business and, to the extent appropriate, in our external supply chain and service providers
  • Employee attraction and retention aids the long-term success of our business and brand
  • Employee engagement can increase stakeholder satisfaction and improve profitability
  • Government and community relations are an important part of day-to-day operations
  • Human capital management (including training and education) promotes long-term success
  • Human rights and applicable legal frameworks should be respected at all times
  • Indigenous rights and applicable legal frameworks should be respected at all times
  • Labour standards (including freedom of association and collective bargaining, child labour, forced labour, occupational health and safety, living wage) should be considered and monitored regularly
  • Labour-management relations should be courteous, professional and productive
  • Marketing communications should be responsible and convey a positive approach
  • Product mis-selling should be avoided
  • Product safety and liability issues should be monitored and addressed appropriately
  • Supply chain management supports sustainable business operations
  • Water scarcity in affected regions should be considered

Governance Issues

Transparency and good governance are vital to maintaining Invision’s standing in the market and to attracting new customers, suppliers and investors. To support these principles, Invision strives to reflect the following governance factors in pursuing our commercial objectives, and will encourage the Funds’ Portfolio Companies to do the same:

  • Accounting standards should be observed
  • Anti-competitive behaviour should be avoided, including through the training of staff
  • Board composition should be carefully considered and appropriately suited to the tasks
  • Bribery and corruption practices should be implemented and staff should be educated
  • Business ethics should serve as the cornerstone for our day-to-day operations
  • Compliance (including fines and other sanctions) is to be taken seriously
  • Executive remuneration should be sustainable and focused on long-term achievements
  • Lobbying should be ethical and conform to applicable guidelines
  • Risk management should play an important role and can be vital to long-term success
  • Separation of chairman and CEO should be observed where possible
  • Stakeholder dialogue should be maintained to avoid conflict and share common goals
  • Succession planning should be addressed from the outset of any appointment


Integration of sustainability risks into investment decision-making processes

Sustainability risks are considered at all stages of each product’s investment process, in respect of each individual investment opportunity.

The investment team is required to complete an ESG Due Diligence checklist as part of the investment committee paper submitted to the Investment Committee for consideration.

The ESG Due Diligence checklist is a tool used to assess initial sustainability risks for a number of chosen areas relevant to the product or service in question, and to identify where additional investigation or due diligence into sustainability risks is required. This seeks to ensure sustainability risks are identified and mitigated during the investment process.



No consideration of adverse impacts

The SFDR requires Invision to make a „comply or explain“ decision whether to consider the principal adverse impacts („PAIs“) of its investment decisions on sustainability factors, in accordance with a specific regime outlined in SFDR. Invision has opted not to comply with that regime, both generally and in relation to the Fund.

Invision will keep its decision not to comply with the PAI regime under regular review.

Invision has carefully evaluated the requirements of the PAI regime in Article 4 of the SFDR, and in the draft Regulatory Technical Standards which were published in April 2020 (the „PAI regime“). Invision is supportive of the policy aims of the PAI regime, to improve transparency to clients, investors and the market, as to how financial market participants integrate consideration of the adverse impacts of investment decisions on sustainability factors. However, Invision is concerned about the lack of readily available data to comply with many of the reporting requirements of the PAI regime, as Invision believes that companies and market data providers are not yet ready to make available all necessary data for the PAI regime.

Notwithstanding Invision’s decision not to comply with the PAI regime, Invision has implemented positive ESG-related initiatives and policies, as part of its overall commitment to ESG matters, as summarised in this section. For the avoidance of doubt, none of the following information is intended to suggest that Invision complies with the PAI regime.



Invision (along with its subsidiaries and controlled affiliates, „Invision„) has established a remuneration policy (the „Policy“) applicable to all Invision entities. The Policy is developed, approved, implemented and monitored by a series of bodies within the Invision structure. The Policy applies to all employees of Invision, save for limited exceptions.

The Policy has been developed with the aim of supporting Invision’s business strategy, corporate values and long‐term interests, including by facilitating the identification, assessment and management of sustainability risks when determining individual remuneration packages. The key principles of the Policy include fostering appropriate risk culture (including with respect to the management of actual and potential conflicts of interest) and compliance with applicable law and regulation.

The performance management and rewards framework envisioned by the Policy has been designed to promote effective risk management, including in particular by:

  • Ensuring that assessment of performance takes full account of adherence to risk management requirements, covering all relevant types of current and future risks, including sustainability risks;
  • Implementing deferral arrangements using co‐investment and carried interest arrangements for senior personnel, facilitating alignment of interests between staff‐members and third-party investors. If the value of the relevant underlying investment portfolio should decrease (whether arising as a result of a sustainability risk or otherwise), the value of the employee’s holdings will be reduced accordingly; and
  • Providing for reduction of deferred variable remuneration awards to senior personnel in certain circumstances, such as in the event that the entity in which the relevant employee works suffers a significant failure of risk management, or experiences a significant downturn in its financial performance (as determined in the sole discretion of Invision), including in connection with a sustainability risk concerning an investment.
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