Bluegem III, SCSp 

ANNEX I DISCLOSURE

The Fund:

☒ Promotes environmental or social characteristics, but does not have as its objective a sustainable investment 

☒    It does not invest in sustainable investments 

☐     It invests partially in sustainable investments

☐    Has sustainable investment as its objective. Sustainable investment means an investment in an economic activity that contributes to an environmental or social objective, provided that the investment does not significantly harm any environmental or social objective and that the investee companies follow good governance practices. 

Has a reference benchmark been designated for the purpose of attaining the environmental or social characteristics promoted by the Fund? 

☐Yes 

☒No

1. WHAT ENVIRONMENTAL AND/OR SOCIAL CHARACTERISTICS ARE PROMOTED BY THE FUND?

The Fund promotes social characteristics by working with portfolio companies to improve their "Workplace" rating as measured in accordance with Bluegem's proprietary ESG Rating system, developed together with a firm of internationally recognised accountants.

In Bluegem's proprietary ESG Rating system, the Workplace score measures factors such as fair treatment, non-discrimination, equal opportunity, health and safety, equality, grievance mechanisms, ESG training, career development and employee wellbeing.

If the portfolio company's Workplace score at the time of investment is assessed by Bluegem to be below "good market practice" level, Bluegem will engage with the portfolio company to improve its policies, procedures and processes with a view to the portfolio company improving its Workplace score by at least 5% every year over the previous year's score until "good market practice" level is achieved.

The Fund will also promote good governance by working similarly with portfolio companies to improve their "Governance" rating by at least 5% every year over the previous year's score until they achieve "good market practice" level.  In Bluegem's proprietary ESG Rating system, the Governance score measures factors such as board accountability, board level review of ESG metrics and ESG performance, anti-bribery and corruption, internal audit, and internal and external ESG reporting.

The Fund will not invest, guarantee or otherwise provide financial or other support, directly or indirectly, to companies or other entities which substantially focus on:

  1. the production of and trade in tobacco and distilled alcoholic beverages and related products

  2. the financing of the production of and trade in weapons and ammunition of any kind, it being understood that this restriction does not apply to the extent such activities are part of or accessory to explicit European Union policies

  3. casinos and equivalent enterprises, and

  4. the research, development or technical applications relating to electronic data programs or solutions, which:

      • aim specifically at supporting any activity referred to under items (i) to (iii) above, internet gambling and online casinos or pornography, or

      • are intended to enable to illegally enter into electronic data networks or download electronic data

  • What sustainability indicators are used to measure the attainment of the environmental or social characteristics promoted by this financial product?

Sustainability indicators measure how the environmental or social characteristics promoted by the fund are attained.

The primary sustainability indicator used to measure attainment of social characteristics will be the portfolio company's "Workplace" rating as measured in accordance with Bluegem's proprietary ESG Rating system.

2. WHAT INVESTMENT STRATEGY DOES THIS FINANCIAL PRODUCT FOLLOW?

Investment strategies guide investment decisions based on factors such as investment objectives and risk tolerance.

The Fund will invest predominantly in unlisted companies located in Western Europe.  Please refer to Section 4 of the Memorandum and Schedule 1 of the Partnership Agreement for further details. 

  • What are the binding elements of the investment strategy used to select the investments to attain each of the environmental or social characteristics promoted by this financial product?

The Fund will not invest in the Excluded Investments.  Please refer to Section 5(c) of the Memorandum for details of Bluegem's approach to ESG as part of the investment process.

  • How is that strategy implemented in the investment process on a continuous basis?

Please refer to Section 5(c) of the Memorandum for details of Bluegem's approach to ESG as part of the investment process.

  • What is the policy to assess good governance practices of the investee companies?

Good governance practices include sound management structures, employee relations, remuneration of staff and tax compliance.

 Please refer to Section 5(c) of the Memorandum for details of Bluegem's approach to ESG as part of the investment process.

  • Where can I find further details on the investment strategy?

Please refer to Section 4 of the Memorandum and Schedule 1 of the Partnership Agreement. 

3. WHAT IS THE ASSET ALLOCATION PLANNED FOR THIS FINANCIAL PRODUCT?

Asset allocation describes the share of investments in specific assets.

It is anticipated that a substantial proportion (being at least 67%) of the Fund's investments by value will promote social characteristics as described above.

 

4. DOES THIS FINANCIAL PRODUCT TAKE INTO ACCOUNT PRINCIPAL ADVERSE IMPACTS ON SUSTAINABILITY FACTORS?

☐Yes 

☒No

5. CAN I FIND MORE PRODUCT SPECIFIC INFORMATION ONLINE?

No additional product specific information is available online.  Further information regarding Bluegem's approach to ESG matters is available to prospective investors on request.

6. IS A SPECIFIC INDEX DESIGNATED AS A REFERENCE BENCHMARK TO DETERMINE WHETHER THE FUND IS ALIGNED WITH THE ENVIRONMENTAL OR SOCIAL CHARACTERISTICS THAT IT PROMOTES?

No.