Vitruvian Partners

Responsible Investment Policy

Published on 10/07/2025

This document outlines the approach of Vitruvian Partners LLP and its subsidiaries (together “Vitruvian”, “we”, or “our”) to the environmental, social and governance (“ESG”) aspects of its activities. This approach applies to the strategy and operations of Vitruvian itself and also to those of the portfolio companies in which Vitruvian invests on behalf of the funds it manages.

OUR PRINCIPLES

Our ESG practices operate in the service of making the highest standard of financial returns (and risk adjusted financial returns) for our limited partner investors. Since inception in 2006, Vitruvian has believed in the potential for a well-designed and well-implemented ESG approach to be of positive societal value generally, while equally being of positive economic value to any business through both the enhancement of revenues and reputation, and the reduction of risks and costs.

Vitruvian has been a signatory to the Principles of Responsible Investment (the “PRI”) since 2017. We maintain our ESG framework as an evolving work in progress which will continue to be developed and adapted over time.

GOVERNANCE AND STEWARDSHIP PRACTICES

Vitruvian recognises the importance and value of “good governance”. The governance arrangements of a prospective portfolio company are assessed as part of pre-investment due diligence and are monitored over the investment holding period. To the extent Vitruvian is able to exercise significant influence, we will seek to introduce measures, as appropriate, to ensure that good governance practices are observed on an ongoing basis. In other cases, including where Vitruvian is unable to exercise significant influence, Vitruvian will, to the extent feasible, seek to promote the tenets of good governance through active engagement.

Due Diligence

All prospective portfolio companies are required to undergo pre-investment due diligence encompassing ESG factors, alongside other due diligence workstreams. ESG due diligence is undertaken using both publicly available data and data shared by the respective company. It includes, but is not limited to:

  • Assessment of ESG risks and opportunities;
  • Materiality assessment of relevant topics;
  • Assessment of climate-related (physical and transitional) risks and opportunities; and
  • Controversy monitoring.

ESG due diligence is required to be submitted to the Investment Committee for consideration prior to any investment and is accordingly integrated into the investment decision-making process.

Continued Monitoring

Portfolio companies are monitored via both company-reported information (typically via our annual ESG data collection process) and via external sources (e.g. online controversy monitoring). Where relevant, Vitruvian board representation provides an additional layer of oversight.

Active Engagement

We seek to ensure that all new majority-owned, private portfolio companies undergo an ESG onboarding, which baselines our expectations for the ongoing relationship. We also ask these companies to appoint an ESG champion who is on or has direct access to the board. We seek to encourage minority-held private portfolio companies to embed ESG within their strategy to the extent possible, commensurate with Vitruvian’s level of ownership and influence.

We typically seek to engage with all portfolio companies annually, which includes our annual ESG data collection exercise. Other regular engagements could include events such as ESG forums.

We may engage further with portfolio companies as is necessary, for example, upon the discovery of a material ESG incident. ESG-related engagement can involve either the ESG Team, the Investment Team, or both.

Reporting

An annual ESG report to our limited partner investors is made available from April each year, which reports on the previous calendar year. A condensed version will typically be made publicly available on our website later in the year.

ESG Incidents

ESG-related incidents identified are assessed for materiality by Vitruvian’s ESG team, in conjunction with our Investment Team. Depending on the materiality involved, it may be determined that such incidents be reported directly to the relevant fund’s limited partner investors.

Stewardship

We seek to leverage our influence to achieve the optimal stewardship outcomes for our portfolio companies, consistent with our level of ownership and control.

At the point of investment, we seek to ensure appropriate information gateways in the underlying investment documentation regarding ongoing reporting on / visibility over stewardship matters.

Vitruvian maintains a separate listed equities' stewardship policy for our activities in the public markets.

ENVIRONMENT AND CLIMATE

We leverage our influence, to ensure that our business practices, and, commensurate with our ownership and control, those of our direct investments minimise their environmental impact to the extent reasonable.

Measurement of greenhouse gas emissions

An important element of any carbon reduction journey is the measurement of carbon emissions. We measure the Scope 1, 2 and material Scope 3[*] carbon emissions (in line with the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard) of both our operations and our portfolio, using reasonable proxies where data is not available.

Carbon Reduction

We strive to reduce our climate impact to the extent that is realistic and achievable. We reflect that there are challenges in achieving Net-Zero, including an inherent reliance upon external factors which are outside our control (such as national and/or international energy infrastructure). We further reflect that full-value chain emissions are complex and are often outside the control of our companies.

Nevertheless, consistent with our level of ownership and control, we seek to encourage our portfolio companies to undergo climate journeys, with carbon reduction plans where reasonably practicable.

We recognise that our portfolio companies often undergo significant growth during the respective holding periods. As a result, we anticipate that absolute carbon emissions may rise despite ongoing climate action by portfolio companies, which therefore should not be used as a standalone indicator of carbon reduction performance.

HUMAN RIGHTS

The human rights section of our ESG Policy reflects our commitment to respecting human rights across all our activities. Our understanding of human rights is based on the rights described in the International Bill of Human Rights[1] and the International Labour Organisation’s (“ILO”) Declaration on Fundamental Principles and Rights at Work[2], where not in conflict with local law. The UN Guiding Principles on Human Rights (“UNGPs”)[3] set out the responsibilities of businesses with respect to human and labour rights and we have based our approach on these principles. We use our influence and leverage to enact these principles to the extent reasonably practicable.

We recognise that the severity and likelihood of any human rights impacts (as well as our ability to exercise influence[†]) can vary due to multiple factors, which could include business sector and operating region.

Key Principles

  1. Vitruvian respects human rights, by taking appropriate measures to identify, prevent and mitigate any (potential) adverse human rights impacts within our scope of operations (regardless of whether Vitruvian contributed to these impacts).
  2. Regarding our GP-level operations, we:
    1. Maintain an ESG Policy which reflects our position regarding respecting human rights;
    2. Ensure that pre-investment due diligence includes an assessment of actual and potential human rights impacts for all companies. This should include consultation with external experts and stakeholders where necessary; and
    3. Remediate (through legitimate processes) any identified human rights impacts to which we have contributed.
  3. Whilst our portfolio companies fall outside the scope of our direct operations, human rights related matters fall within the purview of our stewardship practices. Vitruvian takes reasonable measures to monitor portfolio companies for actual and potential human rights abuses.
  4. Vitruvian will always comply with all applicable laws and will seek to honour the principles of internationally recognised human rights.

References

[1] International Bill of Human Rights, 1948, Office of the United Nations High Commissioner for Human Rights

[2] Declaration on Fundamental Principles and Rights at Work, 2022, International Labour Organisation

[3] United Nations Guiding Principles on Business and Human Rights, 2011, John Ruggie (as Special Representative of the United Nations Secretary General)

[*]With respect to our operations, we would typically include the following Scope 3 categories: Business Travel, Purchased goods and services, Employee commuting, and Fuel- and energy- related activities.

[†] Vitruvian’s ability to exercise influence in a company is affected by multiple factors, including but not limited to equity holding and the degree of board control.