Bluegem IV, SCSp
This section of the website sets out sustainability-related disclosures, for the purposes of Article 10 of the EU Sustainable Finance Disclosure Regulation (“SFDR”). The following website product disclosure has been prepared for a financial product which promotes environmental or social characteristics, but does not have a sustainable investment objective.
Product Name: Bluegem IV, SCSp (the “Fund”)
Legal Entity Identifier (LEI) : N/A
Date of publication: 15th October 2025
Summary
No sustainable investment objective
This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.
Environmental or social characteristics of the financial product
The Fund promotes the environmental and social characteristics of improving policies, procedures and processes in its portfolio companies across the following five pillars: workplace, community, environment, marketplace and governance. This is done by working with portfolio companies to improve their workplace score, as measured in accordance with Bluegem's proprietary ESG scoring system (the “Workplace Score”).
Investment strategy
Pre-investment: ESG due diligence is conducted using the Bluegem ESG Questionnaire and scoring model. Gaps in ESG or governance performance may lead to conditions or exclusions. Investments only proceed if good governance standards are met.
Post-investment: Ongoing engagement involves annual ESG questionnaires, goal-setting, and monitoring. Quarterly meetings are held with portfolio companies. If performance deteriorates, an enhanced review and Corrective Action Plan is triggered.
The exclusion policy continues to apply post-investment.
All investments are assessed for compliance with SFDR-aligned governance standards: management structures, employee relations, remuneration, tax compliance, and policies against corruption.
Proportion of investments
At least 67% of investments promote environmental and/or social characteristics. Up to 33% may be in other assets (e.g., cash, hedging instruments), which are still subject to good governance safeguards.
Monitoring of environmental or social characteristics
Performance is tracked using:
Percentage of portfolio companies meeting or exceeding the “good market practice” Workplace Score.
Compliance with the exclusion policy.
Methodologies
Each company completes the Bluegem ESG Questionnaire annually. ESG scores, and the compliance with the Exclusion Policy and the governance policies are evaluated against internal benchmarks using Bluegem’s proprietary methodology.
Data sources and processing
Data is collected primarily from portfolio companies through structured questionnaires and interviews, supported by third-party reviews and benchmarks. Bluegem uses an ESG data platform and follows a multi-step validation process to ensure data quality. Conservative assumptions are applied when data gaps arise.
Limitations to methodologies and data
Data quality depends on each company’s reporting capabilities. Some variability exists in data completeness and accuracy across ESG pillars.
Due diligence
Bluegem conducts ESG due diligence pre-investment using its proprietary scoring system and questionnaire, supported by external reviews where relevant. Gaps in ESG or governance may lead to conditions or action plans. Investments proceed only if minimum good governance standards are met.
Engagement policies
Engagement is driven by ESG scoring results. Underperformance leads to a formal review and remedial actions, including Corrective Action Plans and board-level oversight, as detailed under the “Investment strategy” section.
Designated reference benchmark
No specific index has been designated as a reference benchmark to determine whether the Fund is aligned with the environmental and social characteristics that it promotes.
Résumé
Sans objectif d’investissement durable
Ce produit financier promeut des caractéristiques environnementales ou sociales, mais n'a pas pour objectif l'investissement durable.
Caractéristiques environnementales ou sociales du produit financier
Le Fonds promeut des caractéristiques environnementales et sociales en favorisant l’amélioration des politiques, procédures et processus au sein de ses sociétés en portefeuille, selon les cinq piliers suivants : lieu de travail, communauté, environnement, marché et gouvernance. Cela se fait en collaboration avec les sociétés en portefeuille afin d’améliorer leur score sur le lieu de travail, mesuré conformément au système de notation ESG propriétaire de Bluegem (le « Workplace Score »).
Stratégie d’investissement
Pré-investissement : La diligence raisonnable ESG est effectuée à l'aide du questionnaire ESG de Bluegem et du modèle de notation. Les écarts en matière de performance ESG ou de gouvernance peuvent entraîner des conditions ou des exclusions. Les investissements ne sont réalisés que si les normes de bonne gouvernance sont respectées.
Post-investissement : L'engagement continu comprend des questionnaires ESG annuels, la définition d'objectifs et le suivi. Des réunions trimestrielles sont organisées avec les entreprises du portefeuille. Si les performances se détériorent, un examen approfondi et un plan d'action correctif sont déclenchés.
La politique d’exclusion reste applicable post-investissement.
Tous les investissements sont évalués quant à leur conformité avec les normes de gouvernance alignées sur la SFDR : structures de gestion, relations avec les employés, rémunération, conformité fiscale et politiques de lutte contre la corruption. Cette évaluation fait partie intégrante du processus de diligence raisonnable et est mise à jour périodiquement avec l'aide éventuelle d'un conseiller externe.
Proportion des investissements
Au moins 67 % des investissements promeuvent des caractéristiques environnementales ou sociales. Jusqu’à 33 % peuvent être investis dans d’autres actifs (liquidités, instruments de couverture), soumis aux exigences de gouvernance.
Contrôles des caractéristiques environnementales ou sociales
La performance est suivie à l'aide de :
Pourcentage de sociétés atteignant ou dépassant le score sur le lieu de travail de « bonne pratique de marché ».
Conformité avec les critères d’exclusion
Méthodes
Chaque société complète le questionnaire ESG de Bluegem annuellement. Les scores ESG, la conformité à la Politique d’Exclusion et aux politiques de gouvernance sont évalués selon les référentiels internes de Bluegem.
Sources et traitement des données
Les données sont collectées principalement auprès des entreprises du portefeuille au travers de questionnaires et d'entretiens structurés, et sont appuyées par des examens effectués par des tiers et des référentiels. Bluegem utilise une plateforme de données ESG et suit un processus de validation en plusieurs étapes pour garantir la qualité des données. Des estimations modérées sont appliquées en cas d’écarts dans les données.
Limites aux méthodes et aux données
La qualité des données dépend des capacités de reporting de chaque entreprise. Il existe une certaine variabilité dans l'exhaustivité et la précision des données entre les piliers ESG.
Diligence raisonnable
Bluegem réalise une diligence raisonnable ESG investissement à l’aide de son propre système de notation et d’un questionnaire dédié, complétés par des analyses externes si nécessaire. Les écarts identifiés en matière d’ESG ou de gouvernance peuvent donner lieu à des conditions ou des plans d’action. Les investissements ne sont réalisés que si les standards minimaux de bonne gouvernance sont respectés.
Politiques d’engagement
L’engagement est déterminé par les résultats de la notation ESG. La sous-performance donne lieu à un examen formel et à des mesures correctives, y compris des plans d'action correctifs et une surveillance au niveau du conseil d'administration, comme indiqué dans la section « Stratégie d'investissement ».
Indice de référence désigné
Aucun indice spécifique n'a été désigné comme référence pour déterminer si le Fonds est aligné sur les caractéristiques environnementales et sociales qu'il promeut.
No sustainable investment objective
This financial product promotes environmental or social characteristics but does not have as its objective sustainable investment.
Environmental or social characteristics of the financial product
The Fund promotes the environmental and social characteristics of improving policies, procedures and processes in its in portfolio companies across the following five pillars: workplace, community, environment, marketplace and governance. This is done by working with portfolio companies to improve their workplace score, as measured in accordance with Bluegem's proprietary ESG scoring system (the “Workplace Score”). The Workplace Score applies a proprietary ESG scoring system based on the following five pillars:
Workplace
Employee training and development
Equality and diversity
Occupational health and safety
Employee wellbeing
Employee engagement
Grievance procedures
Community
Community investment
Stakeholder engagement
Environment
Waste/wastewater
Chemicals
Water use
Energy use
Climate change
Biodiversity
Marketplace
Responsible products
Sustainability within the supply chain
Resource use
Governance
Bribery and corruption
Board level responsibility for ESG
Board level review of ESG metrics and ESG performance
Governance of sustainability issues
Internal audit
Internal and external ESG reporting
Bluegem promotes such environmental and social characteristics by engaging with portfolio companies to improve their policies, procedures and processes with a view to each portfolio company demonstrating continuous improvement in its Workplace Score year-on-year until it reaches and maintains the “good market practice” level as defined by the Bluegem’s proprietary ESG scoring system.
In addition and according to Bluegem Exclusion Policy[1], the Fund will exclude investments in:
all companies that produce weapons for the arms industry;
all companies that produce weapons for retail purposes (i.e. for civilians) and related products, unless such activities are part of or accessory to explicit EU policies;
companies that derive a substantial portion of their revenues from manufacturing tobacco products such as cigarettes, cigars and even chewing tobacco;
all companies that derive any of their revenues from pornography;
all casinos and other gambling business models;
all investments in the research, development or technical applications relating to electronic data programs or solutions which aim specifically at supporting the activities listed above or are intended to enable to illegally enter into electronic data networks or download electronic data; andcompanies that violate the United Nations Global Compact Principles (UNGC) and International Labor Organizations (ILO) Conventions. This includes violations on human rights, labour, environment and strong corruption issues.
together the “Excluded Investments”.
Investment strategy
Pre-investment
Before Bluegem makes a new acquisition, each target company is required as part of the due diligence process to complete the “Bluegem ESG Questionnaire”. Based on the information provided in the ESG questionnaire, Bluegem applies its proprietary ESG scoring system to assign a score to each of the five pillars detailed in the “What environmental and/or social characteristics are promoted by this financial product?” section above. These scores are combined to provide the overall Workplace Score for each target company.
As part of its proprietary ESG system, Bluegem has developed internal scoring thresholds that in Bluegem’s view represent good market practice for each of the five pillars and for the overall Workplace Score. Bluegem reviews the output of the ESG questionnaire, the scoring across the five pillars and the Workplace scoring to understand how the company is currently performing against the Bluegem ESG metrics compared to good market practice.
Any gaps identified during the Workplace Score assessment, including with respect to good governance, are discussed with the management team of the target company and may result in pre-investment conditions, post-investment action plans, or engagement priorities. Investments will not proceed unless minimum good governance standards are met, in line with SFDR Article 8 requirements.
Following investment
Following investment, a meeting will be held between a member of the Bluegem sustainability team, the relevant member of the Investment Team and the responsible person at the portfolio company (typically the CFO). This will be the core team responsible for oversight, data gathering, goal setting and monitoring for each company. The portfolio company will be taken through a Bluegem presentation on why ESG is important, the annual timetable and initial goal setting for the company’s ESG progress for the coming year, based on the ESG questionnaire and the Workplace Score for the company.
The Company will be required to complete the ESG questionnaire annually in order to provide an annual Workplace Score.
The annual engagement process in relation to the Workplace scoring
The portfolio company will complete the Bluegem proprietary questionnaire which includes the provision of data and documentation in relation to its workplace practices, across the five pillars detailed in the “What environmental and/or social characteristics are promoted by this financial product?” section above. This will be conducted through a platform that facilitates the collection of data. The data gathering process will begin in November of and be completed for January.
The portfolio companies will conduct quarterly meetings with the Bluegem sustainability team. Where ongoing projects require more attention and support, this is likely to be more frequent as agreed with the company.
The steps followed if the Workplace Scoring fails to improve/decreases
Should the portfolio company fail to attain, or maintain, the required Workplace Score, this will trigger an enhanced review of the portfolio company’s current workplace-related practices. This review, will be carried out with the relevant member of the Bluegem investment team, a member of the Bluegem sustainability team and the designated Sustainability Lead from the portfolio company. The purpose of the enhanced review is to assess and understand the underlying reasons for the underperformance and to identify appropriate remedial actions. This review shall take place within two (2) weeks of the underperformance being identified.
Following the review, a formal Corrective Action Plan shall be developed within two (2) weeks of the review meeting. The plan shall include, at a minimum:
1) Remedial actions to address the areas of deficiency;
2) Roles and responsibilities, including:
Appointment of a member of the board of directors with overall accountability for delivery of the plan;
Appointment of a designated operational lead within the company responsible for implementation;
3) Defined timelines and deadlines for implementation of each action;
4) Progress reporting, which shall be a standing agenda item at subsequent board of directors’ meetings.
Where internal resources are deemed insufficient to address the identified issues, the use of external advisers or subject matter experts may be recommended or required by Bluegem. Failure to demonstrate progress on the Corrective Action Plan may result in further escalation measures at Bluegem’s discretion, including but not limited to increased monitoring and reporting and Board level escalation.
Excluded investments
In addition, the Fund will exclude investments in:
all companies that produce weapons for the arms industry;
all companies that produce weapons for retail purposes (i.e. for civilians) and related products, unless such activities are part of or accessory to explicit EU policies;
companies that derive a substantial portion of their revenues from manufacturing tobacco products such as cigarettes, cigars and even chewing tobacco;
all companies that derive any of their revenues from pornography;
all casinos and other gambling business models;
all investments in the research, development or technical applications relating to electronic data programs or solutions which aim specifically at supporting the activities listed above or are intended to enable to illegally enter into electronic data networks or download electronic data; and
companies that violate the United Nations Global Compact Principles (UNGC) and International Labor Organizations (ILO) Conventions. This includes violations on human rights, labour, environment and strong corruption issues.
Good Governance
The Bluegem Investment Team, with the support of the Bluegem Sustainability Team, conducts ESG due diligence on all potential investments to assess alignment with SFDR good governance criteria, which include sound management structures, employee relations, remuneration of staff, and tax compliance. This assessment is embedded in the investment process and may include the use of external advisors where technical, sector-specific, or sensitive matters arise (e.g. environmental liabilities, labour practices, or compliance risks). Specifically, this includes reviewing the company’s board and senior management structure, ESG governance arrangements, internal audit and control processes, and policies on anti-bribery and corruption. It also involves assessing employee-related practices such as equality and diversity, health and safety, training and development, grievance procedures, and worker engagement. Tax practices are reviewed to ensure compliance with relevant laws and to identify any evidence of non-compliance. Remuneration structures are evaluated to ensure alignment with long-term value creation and ESG objectives.
Proportion of investments
The Fund makes direct investments in portfolio companies. A minimum of 67% of the Fund's investments by value will promote environmental and social characteristics as described above. The Fund will keep up to 33% of its investments in cash, cash equivalents, and/or hedging instruments.
The Fund may indeed invest up to 33% of its assets in investments that do not qualify as aligned with the environmental and social characteristics promoted by the Fund (#2 Other). All investments, including those in #2 Other, will be subject to the minimum safeguard of the good governance assessment as detailed in the “Governance” paragraph above.
Monitoring of environmental or social characteristics
Bluegem uses the following sustainability indicators to measure the attainment of the environmental and social characteristics promoted by the Fund:
the percentage of portfolio companies with an annual Workplace Score that is at or above the “good market practice” level as defined by the Bluegem proprietary ESG scoring system.
Percentage of portfolio companies complying with the exclusion criteria.
Methodologies
To measure how the environmental and social characteristics promoted by the Fund are met, each portfolio company is required to complete the Bluegem ESG Questionnaire annually. Bluegem reviews the output of the ESG questionnaire, the scoring across the five pillars and the Workplace scoring to understand how the company is performing against the Bluegem ESG metrics compared to the “good market practice” level as defined by the Bluegem’s proprietary ESG scoring system. As part of this annual process, compliance with the with the Bluegem Exclusion Policy is also checked, along with a declaration from the portfolio company, with supporting documentation, to continued adherence to the good governance criteria.
Data sources and processing
Data sources used
Sustainability indicator data is sourced directly from portfolio companies annually via the Bluegem ESG Questionnaire.
Bluegem relies primarily on data obtained directly from portfolio companies, which is collected through structured ESG questionnaires, regular reporting templates, and management interviews. To enhance robustness and context, this data is supplemented by third-party advisers (e.g., ESG consultants, auditors), industry benchmarks and Bluegem’s own proprietary analysis tools and scoring systems.
Data quality
To ensure data quality, Bluegem will assess and analyse information received from portfolio companies with the goal of verifying its accuracy, reliability and consistency. We will request evidence, where available, to support data points submitted by the portfolio company. Bluegem will also make use of benchmarks available to them. Our proprietary ESG rating system and regular checkpoints help validate the integrity of the data used in our evaluations.
Data processing
Bluegem utilises an ESG data management platform which enables portfolio companies to collate and submit the required data points electronically.
Once the data is collected from portfolio companies, there is a multi-step validation and analysis process:
1. Initial Review: Data is checked for completeness and consistency.
2. Cross-Verification: Key metrics are cross-referenced with operational KPIs, and external benchmarks.
3. Scoring and Rating: ESG performance is scored using Bluegem’s proprietary ESG Rating system, which includes sector-specific weighting.
4. Feedback Loop: Results are shared with portfolio companies to clarify anomalies and refine future data submissions.
Data estimation
Data is taken directly from the responses from portfolio companies to the Blue ESG Questionnaire.
If a portfolio company does not provide all required information, Bluegem will first follow up with the portfolio company to clarify gaps. Where specific data points remain unavailable after the follow up, Bluegem may apply conservative assumptions or exclude the data point from scoring, depending on its relevance and materiality. Any such treatment will be clearly documented to ensure transparency. Bluegem places a strong emphasis on the integrity and accuracy of portfolio company disclosures to maintain consistency, continuity and comparability in its assessments over time.
Limitations to methodologies and data
At the point of investment, portfolio companies have a varying level of sophistication in their ability to report data across the five pillars of the Bluegem ESG scoring system (please refer to the “Environmental or social characteristics of the financial product” section above for further details in relation to the five pillars). Accordingly, the availability, completeness and accuracy of data is subject to delivery by portfolio companies. To the extent that data gaps are identified, Bluegem will follow up with the portfolio company to clarify these including, where relevant, as part of the enhanced review process described in the “Investment strategy” section above.
Due diligence
Due diligence undertaken
Bluegem applies its proprietary ESG scoring system pre-acquisition during the due diligence phase. Before Bluegem makes a new acquisition, each target company is required to complete the Bluegem ESG Questionnaire. The Bluegem ESG Questionnaire is conducted in parallel with external ESG due diligence, which is carried out at the discretion of the Bluegem Investment Team based on material topics and issues relevant to the target company. As part of the due diligence process the output of the Bluegem ESG Questionnaire and any external due diligence is reviewed and the proprietary ESG scoring system applied to assess how the company is performing against the Bluegem ESG metrics compared to good market practice. Upon completion of preliminary due diligence, the Bluegem team will meet in order to discuss the merits of the investment. At that time, the Bluegem investment team will review the investment and any outstanding due diligence issues. Any gaps identified as part of the ESG scoring assessment, including with respect to good governance, are discussed with the management team of the target company and may result in pre-investment conditions, post-investment action plans, or engagement priorities. Investments will not proceed unless minimum good governance standards are met, in line with SFDR Article 8 requirements.
In terms of internal and external controls on diligence, the core team responsible for oversight, data gathering, goal setting and monitoring for each company is the Bluegem sustainability team, the relevant member of the Investment Team and the responsible person at the portfolio company (typically the CFO).
Please see the “Investment strategy” section above for further details.
Engagement policies
Bluegem’s engagement policy is based on the output of its proprietary ESG scoring system. If a portfolio company fails to attain, or maintain, the required Workplace Score, this will trigger an enhanced review of the portfolio company’s workplace-related practices to identify appropriate remedial actions as detailed further in the “Investment strategy” section above.
Designated reference benchmark
No specific index has been designated as a reference benchmark to determine whether the Fund is aligned with the environmental and social characteristics that it promotes.
Where can more product-specific information be found?
More product-specific information can be found in the precontractual disclosure.
More product-specific information can be found in the periodic reports.
[1] https://www.bluegemcp.com/exclusion-policy