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Framework & Regulation
At White Oak Capital (“White Oak”, “White Oak Group” or “The Group”), sustainability of returns and corporate governance form the core of our investment philosophy. We believe that Environmental, Social, and Governance (ESG) principles are crucial to developing resilient companies and assets that deliver long-term value for investors.
White Oak values businesses with industry-leading environmental practices and those that demonstrate ethical business conduct and fair dealings with all its stakeholders. We seek to derive returns for our clients by investing in high-quality businesses. We assess business quality by determining the long-term sustainability of return on capital, potential scalability of the business, execution capability of the management and Environment, Social and Governance practices of the company.
The Firm uses an internally developed framework called ABLEx™ (Assessment of business longevity and excellence) for ESG risk assessment. The framework contains a list of sectors specific ESG risks and opportunities against which a company’s performance is measured and rated. The result of this assessment is integrated into our valuation of a business.
Identification and Screening
We believe in a holistic sustainability framework driven by the Firm’s Guiding Principles. The following five principles are intended to be the guiding axioms under which the Firm’s investment management and investment advisory activities are conducted:
As part of the Firm’s commitment to responsible investing, White Oak is a signatory to The United Nations-backed Principles for Responsible Investment Initiative (PRI). Moreover, we support the recommendations of the TCFD (Task Force on Climate-related Financial Disclosures) and continue to promote increased transparency, encourage the development of tools and methods to manage climate-related risks and opportunities and contribute to the best practices in the industry. We also refer to the frameworks provided under the United Nations Sustainable Development Goals and the UN principles on Business and Human Rights in assessing the impact of our portfolio companies’ products, policies, and operations on sustainability outcomes.
Entity level disclosures in respect of Acorn Asset Management Ltd (“AAML”) under EU Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the “EU Sustainable Finance Disclosure Regulation”).
Article 3(1) – Entity Level Sustainability Risk Disclosure
A “Sustainability Risk” means an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of an investment.AAML is part of the White Oak Capital Group (the “Group“). Sustainability risks are integrated into AAML’s investment decision-making process, as outlined in the Group’s ESG Policy.
The Policy further outlines the Group’s approach to the assessment and management of environmental, social and governance (ESG) issues during the investment process. The Group deploys a proprietary bottom-up framework called ABLEx (Assessment of Business Longevity and Excellence) for ESG risk assessment. The framework consists of sector-specific key ESG factors.
The Group integrates Sustainability Risks into its investment decision-making process through the consideration of certain ESG indicators. Sustainability Risks are considered as part of the investment process as appropriate to assess their potential impact on the quality of a particular investment. While doing so, the Group utilises proprietary and/or third-party data and research to assess and monitor Sustainability Risks that are relevant to the funds it manages. Where the Sustainability Risk associated with a particular investment has increased beyond the appropriate ESG risk appetite, it considers selling or reducing the relevant funds’ exposure to the relevant investment, taking into account the best interests of investors.
All Investment Professionals within the Group are required to follow the Policy and to consider relevant ESG factors as part of their pre-investment and portfolio monitoring responsibilities. Investment Professionals receive regular training on the Policy, accompanying ESG tools and relevant ESG topics.
Article 4(1)(b) – Principal Adverse Impacts (PAI) Disclosure
No consideration of adverse impacts of investment decisions on sustainability factorsThe EU Sustainable Finance Disclosure Regulation requires AAML to make a “comply or explain” decision whether to consider the principal adverse impacts of its investment decisions on sustainability factors, in accordance with a specific regime outlined in the regulation.
AAML has opted not to consider the adverse impacts of its investment decisions on sustainability factors within the meaning of Article 4(1)(a) of the EU Sustainable Finance Disclosure Regulation. AAML does not currently do so because, among other reasons, it considers its existing ESG policies and procedures to be appropriate, proportional and tailored to the investment strategy of the funds it manages.
AAML will keep its decision not to comply with the principal adverse impacts regime under regular review.
Article 5(1) – Entity Level Remuneration Policy Disclosure
The Group’s remuneration policies are consistent with the integration of Sustainability Risks. While there is currently no specific reference to “Sustainability Risk” in the Group’s remuneration policies, those policies are intended to promote sound and effective risk management linked to risk-adjusted performance and do not incentivise behaviour or performance that results in unacceptable risk (including Sustainability Risk).
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