Sustainability-related disclosures

In line with the EU's Sustainable Finance Disclosure Regulation (SFDR) requirements, at Bregal Unternehmerkapital we seek to provide transparency on our Responsible Investment approach.

Our strong commitment to ESG and Responsible Investing is integrated in all our investment decisions.  Through our ESG programme we aim to build resilient companies and create long-term sustainable value for our stakeholders.

Relevant Disclosures:

Status (of Fund III) under the EU Sustainable Finance Disclosure Regulation (SFDR)

The Fund has been categorised as meeting the provisions set out in Article 8 of SFDR for products which promote environmental and social characteristics.

Among other characteristics, the Fund promotes environmental and social characteristics. The environmental and social characteristics promoted by the Fund consist of:


  • Energy efficiency improvements
  • The use of renewable energy
  • Mitigation and/or reduction of greenhouse gas emissions
  • Mitigation of climate change


  • Fostering social cohesion
  • Protection and promotion of human rights
  • Promotion of good health through driving health & safety standards, good working practices and product standards

Article 10 (SFDR) Disclosures

Binding Investment Limitations

In order to meet the environmental and social characteristics promoted, Bregal Investments LLP and Bregal Unternehmerkapital GmbH (together, the “Advisors”) and Carne Global Fund Managers (Luxembourg) S.A. (the “AIFM”) apply binding criteria to the selection of underlying assets for recommendation to the General Partner as part of its exclusions based investment decision making process. The Fund will not (directly or indirectly) invest in companies which generate more than a de minimis proportion of its revenues from any of the following at the time the investment is made: (i) the manufacture or sale of weapons and armaments (to protect human rights and foster social cohesion); (ii) pornography or the sex industry (in respect of the prevention of exploitation of individuals and promote respect for human rights); (iii) the manufacture or sale of tobacco (to promote good health ); (iv) products or services that promote termination of human life (in respect of the avoidance of human rights abuses); (v) gambling activities (to tackle inequality and to protect economically or socially disadvantaged communities); or (vi) the production or sale of oil, gas or coal (to mitigate the risks of climate change, greenhouse gas emissions and the exploitation of fossil fuel energy resources, and to promote investments the use of renewable energy). For these purposes, a de minimis proportion is deemed to be 10%, which will be calculated at the time the investment is made. This screening and selection criteria may not be disapplied or overridden by the Advisors, General Partner or AIFM.


More broadly, the Advisors and AIFM will consider sustainability factors through considering the impact an investment might have on: i) local communities, stakeholders, and society, ii) the company’s strategy and performance, iii) long-term growth prospects of the business and the investment case. Detailed ESG assessments are completed for all portfolio companies, during the life-cycle of an investment, to identify their key material ESG areas. Through defining and focusing on company specific key material ESG aspects, the Advisors and AIFM seek to manage ESG-related risks and create additional value whenever possible. The Advisors and AIFM review materiality of focus areas on an annual basis, to ensure relevance in line with market, regulatory and company developments.


The companies in which investments are made follow good governance practices.


The good governance practices of investee companies are assessed prior to making an investment. Investee companies will be assessed and monitored by the Advisors and AIFM  prior to making an investment and on an ongoing basis. Such standards may include, but are not limited to: sound management structures, employee relations, remuneration of staff and tax compliance. Post-investment we actively support our investee companies to further improve the governance of their business.


Furthermore, Bregal Investments (which includes the Advisors and affiliated entities) is a signatory to the UN Principles for Responsible Investment (the “UNPRI”). As a signatory to the UNPRI the good governance practices of investee companies are assessed prior to making an investment and periodically thereafter.

Information on the methodologies used to assess, measure and monitor the environmental and social characteristics promoted by the Fund

The attainment of the environmental and social characteristics promoted by the Fund will be assessed by reference to the sustainability indicators which are also used as the “Binding Investment Limitations” described above.  Investee companies will be periodically monitored against the same sustainability indicators.


Prior to making an investment recommendation to the AIFM, the Advisors perform due diligence on any proposed investment and will assess the proposed investment against the screening criteria under Binding Investment Limitations above.


The Binding Investment Limitations require that at the time of investment the relevant company does not generate more than a de minimis proportion of its revenues, currently set at 10%, from, the screening criteria set out above. However, the investment philosophy is not to make investment in these types of businesses, but the de minimis threshold is simply present to avoid a breach should there be any incidental revenues generated from these sectors.


The data used for the Binding Investment Limitations is generally obtained directly from the portfolio companies and/or their advisors as part of our detailed due diligence prior to any investment. This data is then processed by the Advisor’s dedicated ESG team and integrated into the investment decision making process.

Periodic Reports

A description of the extent to which environmental and social characteristics are met will be available as part of the annual report. This information will also be published on this website once available.

Engagement policies

The Advisors prepare ESG roadmap reviews for all investee companies on an annual basis, which results in a dedicated ESG improvement plan to be adopted by the company’s Board. The Board is accountable for implementation and overall ESG oversight. The Advisors assess ESG performance periodically and adopt long term targets for the fund.


The Advisors support management teams of portfolio companies in the Fund to strive for continuous improvements in ESG and sustainability-related performance, to move beyond compliance and to embed ESG considerations in the companies’ strategy. Following investment in a company, management is encouraged to assess and prioritise company-specific ESG impacts usually as part of a 100-day plan and to formulate a long-term strategic direction.