ESG Policy Summary

Oceanwood Capital Management is required by the Sustainable Finance Disclosure Regulation (Regulation 2019/2088), “SFDR” to make certain disclosures on its website, including information about policies on the integration of sustainability impacts, and the consistency of remuneration policies with the integration of sustainability risks. These disclosures are contained in the ESG Policy Summary below.

Oceanwood Capital Management LLP (the “Firm” or “Oceanwood”) is authorised and regulated by the FCA as a full-scope AIFM. Furthermore, it is registered with the Securities Exchange Commission (“SEC”) as an investment adviser under the U.S. Investment Advisers Act 1940.

Oceanwood acts as the alternative investment fund manager (“AIFM”) to a number of alternative investment funds (“AIFs”). It also acts as the delegated investment manager of third-party collective investment schemes registered to act as undertaking for collective investment in transferrable securities (“UCITS”, together with the AIFs, the “Funds”). Some of the Funds are categorised as Article 6 under Regulation (EU) 2019/2088 (“SFDR”) (“Art. 6 Funds”), whilst others are categorised as Article 8 under SFDR (“Art. 8 Funds”).

Some of the Funds are either at the end of their investment period, or the investment mandate of the Fund does not refer to integration of risks and sustainability factors. Therefore, these funds are out of scope of this policy.

ESG Oversight

Oceanwood has established an ESG Committee consisting of senior individuals representing a range of business areas, both investment and non-investment.

The ESG committee is responsible for Oceanwood’s ESG strategy across all business activities, at a firm and fund level. The ESG Committee meets at least quarterly and has oversight of ESG integration within the investment process and development of the ESG investment framework. The quarterly meetings include, but are not limited to a review of ESG Reports, oversight of ESG engagement with portfolio companies and oversight of proxy voting.

Policies on the integration of sustainability risks into the investment decision-making process (Article 3)

The ultimate objective of including ESG factors in investment analysis and decisions is to better manage risks and improve returns. This is in line with each of the funds’ overall investment objective and aligns with Oceanwood’s fiduciary duty to maximise value for its investors.

In addition, as it relates to Funds classified as Article 8 under the EU’s Sustainable Finance Disclosure Regulation, our objective is to achieve strong financial returns, whilst mitigating ESG risks.

The table below sets out the ESG integration tools used by Oceanwood. Details of how each tool is deployed are set out below.

ESG Integration Tool Co-investment vehicles Art. 6 Funds Art. 8 Funds
Negative ESG Screening Exclusion List
ESG Risk Assessment
Good Governance Assessment
Stewardship – Engagement and Proxy Voting where applicable1

Negative ESG Screening Exclusion List

For all investment vehicles, Oceanwood observes all legal requirements, such as those required by domestic/international law, bans, treaties or embargoes.

Whilst Oceanwood does not systematically apply an exclusion list at a manager level we do for the Art. 8 Funds.

ESG Research

Oceanwood has engaged Sustainalytics to provide unbiased ESG research and ratings.

Product Specific ESG Integration

Alma Platinum IV in respect of Oceanwood Opportunities (Article 8)

The Sub-Fund promotes certain minimal environmental and social standards and therefore applies exclusion criteria with regards to products and business practices that the Investment Manager believes are detrimental to society and the environment.

In addition to the exclusion list described above, the Sub-Fund promotes minimum environmental and social standards by investing in long securities issued by companies which have an ESG Risk Rating of: Medium; Low; or Negligible as measured by Sustainalytics.

Additional information on this product can be found in the product specific website disclosure and pre-contractual disclosure.

Article 6 Funds

For Article 6 funds, Oceanwood reviews Sustainalytics ratings which provide an input into the investment process. The investment team reviews the drivers of high and severe ESG Risk Ratings to ensure that ESG risks identified are incorporated into investment decisions. The investment team documents this review in investment research notes.

No consideration of sustainability adverse impacts (Article 4)

Oceanwood does not currently consider the adverse impacts of investment decisions on sustainability factors as our funds do not have sustainable investment objectives.


Engagement Policy

The Investment Manager may engage with the management teams of portfolio companies from time to time, where relevant and appropriate. The primary objective of engagement on ESG issues is to help companies improve their long-term financial outlook.

The ESG Committee reviews any engagement activity each quarter. If a company fails to respond to engagement or does not take action as a result of the engagement, the Investment Manager may exit the position if the engagement was key to the investment thesis.

Oceanwood may participate in collaborative engagement through initiatives such as the Carbon Disclosure Project.

Proxy Voting

In addition to the direct engagement activities noted above, Oceanwood may also demonstrate active ownership through proxy voting. Oceanwood maintains a separate Proxy Voting Policy.

Industry Bodies

Oceanwood is affiliated with the following organisations:

Oceanwood’s commitment to both the CDP and Say On Climate initiatives is aligned to the PRI Principles 1-4 relating to ESG investment analysis, active ownership, corporate disclosure and investor collaboration.

Oceanwood Firm ESG Procedures

In addition to the ESG processes deployed within the investment process, Oceanwood believes it is vitally important to operate its own business in line with the standards it expects from portfolio companies. As such, Oceanwood has implemented a number of business initiatives across environmental, social and governance pillars, which the ESG Committee is responsible for.

Remuneration Policy (Article 5)

The annual review and remuneration process for employees takes into consideration all aspects of employee performance and development throughout the year, this includes assessing employee participation in developing and adhering to Oceanwood’s ESG Policy and responsible investing process.

Policy Review

The ESG Policy is reviewed at least annually.

Commitment to the UK Stewardship Code

Under Rule 2.2.3R of the FCA's Conduct of Business Sourcebook, Oceanwood Capital Management LLP ( “Oceanwood”) is required to disclose the nature of its commitment to the UK Financial Reporting Council's Stewardship Code (the "Code") or, where it does not commit to the Code, its alternative investment strategy. The Code is a voluntary code and sets out a number of principles relating to engagement by investors with UK equity issuers. Investors that commit to the Code can either comply with it in full or choose not to comply with aspects of the Code, in which case they are required to explain their non-compliance.

Oceanwood employs a European-focused event-driven investment strategy which involves, among others, investments in equities, including UK equities. The Code is therefore relevant to only certain aspects of Oceanwood's investment process. While Oceanwood generally supports the objectives that underlie the Code, Oceanwood has chosen not to commit to the Code. Oceanwood invests in a variety of asset classes and in a variety of jurisdictions and its approach in relation to the engagement with issuers and their management will vary on a case by case basis. Therefore, Oceanwood does not consider it appropriate to commit to any particular voluntary code of practice relating to any individual jurisdiction or asset class.

No consideration of sustainability adverse impacts

Oceanwood Capital Management LLP does not currently consider the principal adverse impacts of investment decisions on sustainability factors in accordance with Article 4 of the SFDR, as the detailed rules and guidance regarding such disclosure have not been finalised.


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