Hellman & Friedman LLC (“H&F”) makes the following disclosures in accordance with Regulation 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (as amended, “SFDR”).
1. Integration of sustainability risks in investment decisions
“Sustainability Risk” is defined in SFDR as “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 the investment”.
Such Sustainability Risks are integrated into the investment process via H&F’s investment process (as described below) solely to the extent that H&F determines that they represent potential or actual material risks and/or opportunities to maximizing the long-term risk-adjusted returns of a sponsored fund.
Before making an investment decision on behalf of a sponsored fund, H&F assesses what it believes are the material risks associated with the proposed investment, including but not limited to Sustainability Risks that it believes to be material. The Sustainability Risks that will be considered will depend on the particular proposed investment to the extent it is determined by H&F to be practicable or appropriate. These risks form part of the overall investment analysis and the identified risks are assessed alongside other relevant considerations. Following such assessments, H&F makes investment decisions having regard to the respective fund’s investment policy and objectives, taking into account Sustainability Risks and H&F’s duties toward its investors as described in the sponsored fund’s partnership agreement.
In relation to integrating Sustainability Risk into its investment decision-making process, H&F will, where consistent with its fiduciary and other duties and otherwise commercially practicable, aim to consider environmental, social and governance (“ESG”) factors as one of many important data points, but the sponsored funds do not limit their investments to those that meet specific ESG criteria or standards. Such considerations typically (but without limitation) include governance, diversity and inclusion, environmental, social issues, information security and operational efficiency practices during the due diligence stage of the investment process. Further details on H&F’s approach to ESG integration are set out on the sustainability page.
2. Principal Adverse Impacts
At present, H&F does not consider the principal adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR. H&F does not currently do so because, among other reasons, it is not expected that its portfolio company investments will widely collect or report such data. While H&F believes that the value of its investments will be enhanced by considering ESG factors when investing, H&F is mindful of the evolving nature of the underlying SFDR rules as well as the availability of data and information required to adequately assess the principal adverse impacts of its investments on sustainability factors. H&F will keep its position under review on an annual basis as the industry approach to ESG data collection and regulatory guidance evolves.