Policy & Regulation
At White Oak Capital (“White Oak”, “White Oak Group” or “The Group”), sustainability of returns and corporate governance form an important element of our investment philosophy. Thus, our investment approach naturally integrates Environment, Social, and Governance (“ESG”) factors in our decision-making process. The Group values businesses that follow industry-leading environmental compliance practices and that demonstrate ethical business conduct and fair dealings with stakeholders. White Oak believes that a sustainable investment strategy preserves long-term shareholder and stakeholder value by balancing financial and commercial analysis with sound ESG practices serving a wider community.
As part of the Group’s commitment to responsible investing, White Oak is a signatory to The United Nations-backed Principles for Responsible Investment Initiative (PRI).
ESG Investment Approach at White Oak
We believe in a holistic sustainable framework driven by the Group’s guiding principles, which help us define our approach to integrating the tenets of sustainable business practices into our investment approach:
White Oak’s ESG framework is designed to evaluate ESG issues through three fundamental facets: Policy, Risk Management and Strategy. We evaluate the underlying businesses on their commitment to manage ESG issues effectively as well as integrating ESG into their risk management process and on their approach to making ESG a strategic priority.
Appropriate policies assist shaping and defining corporate culture which is required to address pertinent issues. We expect business we own to have stated policies towards environmental protections, safeguarding social interests and ethical business conduct
Integrated risk management frameworks assist in identification of potential future risk, thereby improving resilience and enabling stronger future growth and value creation. We encourage businesses to integrate ESG aspects in there overall risk management processes as relevent
We encourage businesses we own to integrate ESG into their core business strategy so that they factor in the ESG considerations in all key decisions and capitalize on growth opportunities emanating from an ESG focus
ESG Integration and Engagement
The assessment of ESG aspects is integrated into our investment research and valuation processes. The Investment Team focuses on identifying the relevant ESG aspects in each of the underlying businesses, understanding key ESG risks, evaluating systems and controls for monitoring such ESG risks, and assessing performance against the ESG parameters. We have developed an ESG framework that is applied to identifying topics relevant to the specific sectors which we invest in.
As part of the overall process, we combine the perspectives of our investment analysts, management team, and third-party discussions to form a holistic view of businesses and the issues they face. This process helps us understand the ESG data to identify relevant information in order to address the key issues identified through our framework and forms the basis of our engagement with underlying businesses on ESG topics.
Our Approach to Climate Change
The implications of climate change are creating rapidly changing regulations and consumer demands around the world. Mitigating climate change and reducing greenhouse gas emissions are major global challenges. We believe that governments, businesses, and investors have a responsibility towards facilitating a transition to a climate-resilient economy.
We support the recommendations of Task Force on Climate-related Financial Disclosures and we shall 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 closely monitor the businesses which have a greater exposure to climate change related risks and their progress towards a low-carbon transition.
We support the goals of the Paris Agreement and through our engagements encourage target setting for emissions reduction and enhancement in the level of disclosures.
We believe that businesses and investors play a crucial role in shaping outcomes related to sustainability. We refer to the frameworks provided under the UNITED Nations Sustainable Development Goals (UNSDG) and the UN principles on Business and Human Rights in assessing the impact of our portfolio companies’ products, policies, and operations on sustainability outcomes.
Policies and actions of businesses in our investment coverage towards the desired sustainability outcomes play a role in the overall ESG evaluation.
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”), which is available at:
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).