Partnering for 
ESG & Sustainability
Report 2021/22
Sustainable Growth

1       ESG & Sustainability Report 2021/22
        2
As a control investor with a hands-on approach to driving sustainable, long-
term growth at our portfolio companies, we are naturally focused on the 
environmental, social and governance aspects of our businesses. We seek to work 
collaboratively with our portfolio company management teams to embed ESG & 
Sustainability principles and goals in their business strategies and operations and 
monitor performance to ensure that progress is being made. Our annual ESG & 
Sustainability report is one of the principal ways in which we seek to communicate 
to our stakeholders on the progress that has been made across a number of ESG 
initiatives both at TDR and our portfolio. 
The last twelve months have brought new challenges in Europe as the impact of 
the pandemic largely subsided to be rapidly replaced by supply chain constraints, 
inflationary and interest rate pressures and a cost of living crisis for many consumers. 
The environment has meant that our businesses have needed to remain nimble 
and innovative in order to mitigate the financial impacts of these challenges while 
importantly, needing to focus on supporting their employees, customers and the 
communities in which they operate in an attempt to alleviate some of the more 
acute pressures on household budgets. 
Separately, we have continued to focus on climate change, working on further 
understanding the risks and opportunities within our portfolio companies, building 
on the groundwork undertaken with a  specialist climate change consultancy 
last year. We have also worked closely with our portfolio companies to help them 
add ESG & Sustainability talent including at the most senior level. For the first time, 
we are happy to report that all our portfolio companies have a dedicated Head 
of ESG & Sustainability in place which should help ensure even greater focus and 
progress in the future. 
One of the key areas of focus in our industry at the moment is ensuring reliable and 
consistent ESG data collection. We have recently rolled out the Worldfavor reporting 
platform to all of our portfolio companies which we believe will further improve the 
collection and analysis of ESG data. Furthermore, we believe we can leverage our 
in-house data science expertise to analyse the complex data that we will now be 
able to systematically collect and use this analysis to drive positive ESG outcomes. 
Finally, we continue to encourage equality, diversity and inclusion (ED&I) initiatives 
across the portfolio and our own activities as well as supporting a number of 
industry-wide initiatives to improve diversity in the investment industry. We firmly 
believe that diversity of perspective leads to better decision-making and are 
pleased to have made significant progress in recent years on improving gender 
diversity within the TDR team such that 50% of the investment team below Partner 
level is now female.
This report provides more insights into these and many more initiatives across our 
portfolio and at TDR to drive our ESG & Sustainability efforts. Whilst there is good 
progress, we recognise there is still further work to do. Our focus areas for the 
coming year include extending the coverage of carbon reporting and working 
with portfolio companies to set carbon reduction targets, the ongoing promotion 
of inclusive working practices across the portfolio and our own activities, whilst 
continuing to provide firm-level support to a range of industry and charitable 
initiatives.  
We hope you enjoy reading our 2021/2022 ESG & Sustainability report.
The TDR Partners
WELCOME
Welcome
CONTENTS
WELCOME
01-02
WHO WE ARE
03-08
ESG AT TDR
09-10
ENVIRONMENT
11-20
SOCIAL
21-28
GOVERNANCE
29-36

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Since our establishment in 2002, TDR 
Capital has focused on acquiring 
majority stakes in market-leading 
European companies with potential 
for robust growth and resilience 
through economic cycles. We work 
collaboratively with our portfolio 
company management teams to 
deliver on a shared vision for growth 
and value creation, leveraging 
our investment, operational and 
data science expertise. In addition 
to the capital we invest in our 
portfolio companies, we provide 
expertise and resources to help 
bring about sustainable, positive 
and transformational change. It 
is an investment strategy driven 
by a focus on sustainable growth, 
and we know that as a key 
stakeholder we have a significant 
role to play in setting the agenda 
for our portfolio companies.
TDR is the largest investor in our 
funds, demonstrating a clear 
alignment of interests with our 
investors and our management 
teams, and underpinning the 
‘one-team’ culture of our firm. 
We believe that incorporating 
environmental, social 
and governance (ESG) 
considerations into our 
business and investment 
decisions is key to developing 
a more sustainable long-
term growth strategy for 
our portfolio companies, 
thereby creating value 
for our investors.
Our Head of ESG & Sustainability 
oversees our ESG related activities 
to ensure we are incorporating ESG 
considerations within our portfolio 
companies and leading by example 
as a firm. Progress and ongoing 
actions are reviewed quarterly by our 
Responsible Investment Committee, 
which is made up of senior-level 
representatives from the Management 
Committee of the firm, Investment 
Team and Operating Team. This helps 
to ensure we have input from all parts 
of the firm and the mechanism to 
communicate any resulting actions to 
the relevant teams. 
Working alongside our portfolio 
companies, we place significant 
emphasis on the identification of 
key material risks and opportunities, 
which ultimately will help to define 
the core areas of focus and provide 
the building blocks for ESG strategy 
development. In addition, with the 
support of TDR, all portfolio companies 
have now appointed a dedicated 
Head of ESG & Sustainability. 
49%
51%
WHO WE ARE
WHO WE ARE
OUR CURRENT PORTFOLIO AT A GLANCE1
TDR AT A GLANCE2
Who we are
Our approach
Portfolio
companies
14
Total headcount
79
Head office
London
Average portfolio 
sales growth3
>2x
Average portfolio 
employee growth3
>2x
Nationalities
15
Investments  
to date
24
Average portfolio  
EBITDA growth3
>3x
Number of 
employees
280,000
Male vs Female
AUM
c. €13  
billion
1	
Reflects the portfolio as of September 2022
2	
Reflects TDR Capital as of September 2022
3	
Average growth across the TDR portfolio during TDR period of ownership (or, in relation to unrealised companies, 
from date of initial ownership to September 2022)
Through this structure we can assist 
companies in setting appropriate 
key performance indicators, data 
collection protocols and ESG-related 
improvement targets.
Our ESG Policy outlines how we 
approach ESG management as a firm 
throughout the investment lifecycle. 
We look to continuously evolve and 
shape our approach through ongoing 
stakeholder engagement and 
involvement in industry-wide initiatives, 
events and informal discussions. We 
update our policy annually in line with 
these interactions and broader ESG 
developments. 
Throughout the year we also provide 
opportunities for collaboration across 
our portfolio companies. We believe 
there are opportunities for co-
generation of solutions to a range of 
ESG challenges and we have helped 
facilitate this throughout the year by 
holding ESG forums and delivering 
specialist webinars in partnership with 
industry experts.

6
5       ESG & Sustainability Report 2021/22
Our commitment to ESG & Sustainability is integrated throughout 
the investment lifecycle, from origination to preparing for exit. 
This includes:
Due Diligence: Incorporating ESG as 
a core due diligence workstream, 
identifying material risks and 
opportunities for consideration 
by our Investment Committee. 
This is initially completed in-house, 
with external expertise brought 
in when a specialist review and 
opinion are deemed necessary.
Ownership: We work operationally 
with each portfolio company to 
ensure key ESG issues have been 
identified, along with a plan to 
mitigate risks and/or deliver potential 
value enhancing opportunities. 
Reporting mechanisms (quarterly 
materiality reports and annual 
KPIs) are established within the 
first month of ownership, with 
progress reviewed quarterly by our 
Responsible Investment Committee.
Exit: By working closely with 
management teams, and 
through regular reporting, we 
are able to identify the ESG-
related improvements made 
throughout the ownership period. 
We then aim to include this 
within vendor due diligence. 
Integrating ESG throughout  
the investment lifecycle 
Case study:
Modulaire Group
We supported Modulaire Group in the introduction of a circular ‘Loops within 
Loops’ business model, which sets a framework for creating smart spaces 
for people to work, learn and live, whilst positively impacting people, the 
planet and wider society. This initiative saw the group reduce residual waste 
through a focus on sustainable design, refurbishment, redeployment and 
upgrade and reuse of its modular construction solutions. It also included 
the calculation of scope 1 & 2 carbon emissions with a commitment 
to set Science Based Targets, that also cover scope 3 emissions. Within 
this framework, Modulaire’s Lost Time Frequency Rate reduced and the 
company introduced a Group Zero Harm Strategy, Group-wide Equality, 
Diversity & Inclusion strategy and a talent development programme. 
Modulaire also became a signatory to the UN Global Compact and TCFD.
These improvements, which resulted in the company moving from a laggard 
to strategic level of performance against our ESG framework (see p7) 
during our ownership period, were a key part of the presentation made to 
prospective purchasers as part of the vendor due diligence process when 
we came to market the business for sale. The successful sale of Modulaire 
was completed in December 2021.
SECTOR
Business Services
HEADQUARTERS
London, UK
WEBSITE
modulairegroup.com
20x
number of times a  
unit can be reused
>95%
of a modular unit
is recyclable
50%
lower carbon footprint
than a traditional
building
WHO WE ARE
1. Due Diligence
2. Ownership
3. Exit

8
7        ESG & Sustainability Report 2021/22
2
1
3
4
Issue Identification  
and Prioritisation: Understanding 
the key material issues.
Strategy & Governance: 
Ensuring strong governance 
structures are in place to 
manage ESG risks and 
opportunities, whilst ensuring 
leadership in the creation 
of an ESG strategy which 
supports business growth.
Performance Management: 
Setting ambitious targets 
and commitments, which 
are based upon robust data 
collection processes. 
Reporting & Communications:  
Engaging with both internal 
and external stakeholders 
through reporting and 
communications, providing a 
continuous loop to improve and 
enhance ESG performance. 
Rating Company  
Performance
Working with our  
Portfolio Companies
We have developed a rating methodology to track portfolio 
company performance against our ESG assessment framework. 
This enables us to take a targeted approach and direct resources 
towards companies which require support to enhance their ESG 
framework. We understand levels of performance through regular 
company engagement, quarterly materiality reports and annual 
KPIs received from each company. 
The graph below provides an overview of these ratings, 
highlighting where companies have enhanced their performance 
from 2019 onwards.
WHO WE ARE
WHO WE ARE
2019
2020
2021
DAVID LLOYD
l
l
l
LEASEPLAN
l 
l
l
ILKE HOMES
l
l
l
STONEGATE
l
l
l
EG GROUP
l
l
l
HURTIGRUTEN
l
l
l
CONSTELLATION
l
l
l
NAPAQARO
l
l
l
NKD GROUP
l
l
l
ASDA1
 
 
l
ARROW GLOBAL1
 
 
l
BPP HOLDINGS1
 
 
l
AGGREKO1
 
 
l
KEY
l  1 - 2  LAGGARD
l  3 - 4  LEARNER
l  5 - 6  CHALLENGER
l  7 - 8  LEADER
We work with our portfolio companies to help define their purpose and to 
understand strategically how a focus on ESG and Sustainability can support 
business growth. This will be tailored and unique to each company, depending 
on the markets in which they operate and opportunities for differentiation 
and leadership. These company quotes are a selection to illustrate what ESG 
means to each company, showcasing the nuances across our portfolio. 
“When it comes to ESG and 
sustainability, if you want to do 
something that’s about more 
than ticking boxes and is actually 
about making an impact, you 
have to make choices and for 
us the choice was clear. We all 
know 20% of global emissions 
come from road transportation, 
which is why we made a 
commitment to transfer our whole 
fleet of around 2 million vehicles 
from ICE cars to electric vehicles. 
It’s been really helpful to us in 
terms of winning new business, 
attracting clients and also raising 
capital on the green markets.” 
Michael Lightfoot 
Chief Corporate Affairs & Sustainability 
Officer, LeasePlan
“At Asda, ESG is integral to how 
we plan to deliver our growth 
strategy. Our ESG programme 
focuses our work around three 
distinct pillars: Better Planet, Better 
Lives and Better Business, helping 
us to create a more sustainable 
world, remove barriers to fair 
opportunity, good health and 
wellbeing and hold ourselves 
accountable to the highest 
standards of responsible business.”
Jo Warner
Senior Director, Corporate  
Responsibility & ESG, Asda
“ESG for Aggreko really falls into 
two parts: you’ve got our own use 
of energy, but also our impact on 
behalf of our customers in terms 
of greenhouse gas emissions. By 
hybridising our fleet we have a 
tremendous opportunity to help 
our customers really drive through 
the energy transition piece.” 
Blair Illingworth
CEO, Aggreko
“At Stonegate Group, about 
half of our team are under the 
age of 25 and they have a real 
aspiration and determination 
to develop their careers. The 
S element of ESG, that social 
awareness, is really manifested in 
the opportunities that we provide. 
What we find is this provides 
real commercial benefit, we get 
very good team retention and 
we get this tremendous cultural 
alignment because people 
grow through the organisation.” 
Tim Painter
HR Director, Stonegate
“Hurtigruten Group has committed 
to several ambitious ESG goals. 
The most important one is 
becoming a zero emissions 
company throughout by 2050. 
The next major leap in that 
direction is getting the first zero 
emissions ship sailing by 2030.” 
Daniel Skjeldam
CEO, Hurtigruten
Our assessment framework
1	 Asda, Arrow Global, BPP Holdings and 
Aggreko were all acquired in 2021.

9       ESG & Sustainability Report 2021/22
        10
“Since I have been on the 
programme it has given me more 
independence. At the start of the 
programme, I was very nervous, 
but I feel much more confident, 
made new friends and I am 
excited about what the future 
holds.” 
London Futures participant
“I have been a mentor for three 
years, and it is a really enjoyable 
and valuable experience. The 
hope is that providing mentees 
with a sounding board outside of 
their respective firms helps bring 
objectivity and support to their 
career development. We cover a 
range of topics, everything from 
general private equity business 
advice to advice on specific 
firm issues, always with the aim 
of building key skills to progress 
within their respective firms.”
Jonathan Rosen 
TDR Partner and Level 20 Mentor
ESG at TDR
ESG AT TDR
ESG AT TDR
PRI SIGNATORY
INITIATIVE CLIMAT INTERNATIONAL
LONDON FUTURES
LEVEL 20
OUT INVESTORS
#10000 BLACK INTERNS
UNICEF
GAIN
MEASURING OUR CARBON FOOTPRINT
As a responsible investor we have an obligation not only to promote appropriate stewardship 
across our portfolio companies, but to implement responsible business practices within our own 
operations as well. This includes working collaboratively across industry-led initiatives, managing 
our carbon footprint, delivering positive social impact and initiatives to improve equality, diversity 
and inclusion within the firm and across our portfolio.
TDR is a firm supporter and a 
signatory of the Principles for 
Responsible Investment (PRI). We 
utilise the PRI’s network and thought 
leadership to support our responsible 
investment activities. We have 
also integrated the principles into 
our approach and throughout the 
investment lifecycle.
TDR has recently become a signatory 
to Initiative Climat International, 
joining a group committed to 
reducing the emissions of private 
market-backed companies and 
securing sustainable investment 
performance by recognising and 
incorporating the materiality of 
climate risk. Becoming a member of 
this global community of investors 
will help to better understand 
and manage the risks associated 
with climate change through 
collaborative activity.
TDR is a founding member of 
Level 20, an organisation created 
to promote greater female 
representation in the investment 
industry. Its goal is to raise the 
percentage of senior women in the 
European private equity industry to 
20%. Founded in 2015, it now has 
over 1,000 individual members from 
a wide range of GPs and other 
professionals within the private 
equity industry.
Level 20 activities include mentoring 
programmes (in which several of 
TDR’s Partners are actively involved), 
member forums and research groups.
In 2021, TDR became the corporate 
partner for the London Futures 
Disability Employability programme. 
This programme is designed for 
young Londoners (aged 18-25) with 
a learning disability, who are facing 
social isolation and loneliness. TDR 
has supported 20 young people 
through this programme, all 
graduating the programme with 
flying colours.
As one of the founding members of 
Out Investors, TDR stands alongside 
over 80 leading venture capital 
and private equity firms, hedge 
funds and pension funds globally. 
Our support is helping to deliver 
Out Investors’ mission of making 
the direct investing industry more 
welcoming for LGBT+ individuals and 
creating a lasting impact on the 
investment industry. 
TDR is a participating firm in the 
#10000 Black Interns’ initiative. The 
intention of this initiative is to transform 
the horizons and prospects of young 
black people in the United Kingdom. 
Luke Peters joined our Data Science 
team for an eight-week internship, 
working on a number of live projects 
to gain direct experience of how the 
team adds value through our portfolio 
company work. 
TDR has provided support to 
UNICEF’s humanitarian response to 
the war in Ukraine. This has been 
focused on supporting critical child 
protection services, helping UNICEF 
to establish 40 ‘Blue Dot’ hubs for 
women and children on the move 
and reach over 1.4 million children 
and caregivers with mental health 
and psychosocial support.
TDR is a corporate partner of GAIN 
(Girls Are Investors), a charity set 
up by investment professionals 
to improve gender diversity in 
investment management by building 
a talent pipeline of entry-level 
females and non-binary candidates. 
Over the coming year TDR will be 
offering at least one internship to 
help meet the goal of generating 
more and better prepared women 
for investment firms. 
Wherever possible we continue to 
identify opportunities to reduce the 
carbon emissions associated with the 
running of our office and business 
travel. Since June 2020, we have 
sourced 100% sustainable energy 
to offset our electricity usage and 
continue to introduce energy saving 
initiatives in our London office.  We 
compensate for the emissions we 
are unable to avoid by offsetting 425 
tCO2e through a reforestation project 
in Ayrshire, Scotland. 
“I am grateful for this internship 
with TDR and the opportunity to 
work alongside the data science 
team on a live portfolio company 
project. This experience will 
now be invaluable in helping 
me find full-time employment.”
Luke Peters
#10000 Black Interns

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Environment
 ENVIRONMENT
Overview
The environmental footprint of our portfolio companies spans a 
range of impact areas, which include climate change, carbon 
management, resource efficiency, water and biodiversity. Our 
collaborative efforts, over the past years, have been focused 
on the threat posed by climate change to the global economy, 
society and ecosystems. As signatories to the Initiative Climat 
International (iC International), we have made a collective 
commitment to analyse and manage climate-related financial 
risk and emissions in our portfolio companies, in line with the 
recommendations of the FSB’s Taskforce for Climate-related 
Financial Disclosure (TCFD) in June 2017. 
Over the past year we continued to better understand and 
manage the risks and opportunities associated with climate 
change. This includes working with companies to identify where 
climate change poses a material risk and completing annual 
carbon footprinting measurements. We have also accelerated 
our engagement with management teams of portfolio 
companies to develop emissions reduction and climate change 
action plans. For several companies this has included setting a 
commitment to developing Science Based Targets to align with 
the 2015 Paris Agreement.
We also continue to implement a range of recommendations 
from the detailed climate analytics completed by our partners 
Pollination, a specialist climate change advisory firm. This has 
helped to identify untapped low carbon opportunities across our 
portfolio, to better understand the climate risks and opportunities 
within our portfolio and prioritise sizeable opportunities to 
accelerate the transition to net zero. 
TDR has an important role to play in accelerating this transition, 
unlocking value creation opportunities for companies and for 
some an opportunity to become a climate leader within their 
respective sectors – with the potential for positive outcomes 
for both investors and the climate. This aligns to our investment 
philosophy, which seeks to generate attractive returns by 
employing a transformational value creation approach.
ENVIRONMENT IN ACTION
ASDA 
Backing more sustainable  
farming in Britain
13-14
 
AGGREKO
Designing renewable  
power solutions
15-16
 
HURTIGRUTEN
Creating ocean  
science ambassadors
17-18
 
EG GROUP 
Going solar
19-20

13       ESG & Sustainability Report 2021/22
        14
As one of Britain’s top three grocers, Asda is committed to ensuring 
sustainable supply chains and promoting responsible farming 
practices. Throughout 2021, it continued to engage with more 
than 100 British farmers on a range of sustainability challenges and 
held collaborative sessions with dairy farmers as part of the Arla 
dairy farming development programme. It has also collected soil 
and biodiversity data from produce growers as part of ongoing 
trials. These aim to support healthy soils and high crop yield and 
quality, whilst reducing risks such as flooding and erosion and 
enhancing habitats for wildlife. Some of Asda’s long-standing 
potato and onion farmers have applied a tool developed for Asda 
by the National Institute of Agricultural Botany and the University 
of Cambridge Institute for Sustainability Leadership to assess 
chemical, physical and biological soil health and to highlight risk 
spots in individual fields. This will be rolled out by 2025 following 
further trials in 2022 to refine the tool based on focus group 
feedback. In 2021, 100% of Asda’s own-brand dairy (milk, cream, 
butter and cheddar), eggs, potatoes and primary and breaded 
chicken came from British farms. It also sourced 90% British beef by 
December 2021, with supply chain challenges preventing it from 
achieving its 100% target.
ENVIRONMENT
ASDA
SECTOR
Retail
HEADQUARTERS
Leeds, UK
WEBSITE
www.asda.com
100%
own-brand dairy, eggs 
and potatoes sourced  
from British farms
>100
farmers engaged on 
sustainability challenges
1,000
acres of biodiversity plots 
sown on headland 
“Our sourcing and farming practices aim to 
respect and restore, having a regenerative 
impact on nature. Working in partnership 
with our suppliers and experts helps us to 
better understand the challenges we face, 
and identify ways to improve our impact 
throughout the supply chain.” 
Chris Brown
Senior Director, Sustainable Supply Chains, Asda
Backing more 
sustainable farming  
in Britain

15       ESG & Sustainability Report 2021/22
        16
Aggreko is working alongside customers to provide tailored 
solutions, at different stages of the energy transition, driven by a 
commitment to create better energy solutions to secure a more 
sustainable future.  This includes end-to-end solutions to accelerate 
the deployment of affordable and cleaner energy, as well as 
sustainable infrastructure. 
Aggreko is supporting the Salares Norte Mine, an open-pit 
gold mine in northern Chile, in meeting the challenges of 
supplying consistent power to an off-grid project. In addition to 
physical challenges, the Chilean government applies stringent 
environmental regulations to such projects, and gold fields require 
a minimum 20% renewable power generation for all mining 
operations. The PV solution, designed by Aggreko, will be tailor-
made to meet the project’s needs and will lead to an estimated 
saving of $700,000 per year in energy costs and a further $1.1m 
in carbon tax offset over the project’s lifetime. It is estimated to 
offset 104,000 tonnes of carbon emissions. The hybrid solution will 
allow the site to run completely off-grid, delivering sustainable and 
reliable power 24 hours a day. 
ENVIRONMENT
AGGREKO
SECTOR
Business Services
HEADQUARTERS
Dumbarton, Scotland
WEBSITE
www.aggreko.com
SALARES NORTE PROJECT:
$1.1m 
estimated cost saving in 
carbon tax offset 
104,000 
estimated tonnes of carbon 
emissions offset by PV
100% 
off-grid solution 
provides sustainable 
power 24 hours a day
“The drive for businesses, governments and 
individuals to transition to a greener, cleaner 
world is accelerating. The energy crisis 
is reaching all corners of the globe and 
is increasing the demand for alternative 
energy solutions. Aggreko is guiding our 
customers through this energy transition, 
partnering with them to provide sustainable, 
resilient energy solutions.”
Blair Illingworth
CEO, Aggreko
Designing renewable  
power solutions

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        18
Founded in 1893, Hurtigruten is a leading provider of cruise-based 
adventure tourism, visiting destinations in Norway, Antarctica, 
the Arctic circle, Galapagos and many places in between. 
Hurtigruten operates 15 ships, seven of which provide year-
round coastal sailings along the Norwegian coast. Scientific 
research is conducted onboard its ships via partnerships with 
world-leading institutions and the Hurtigruten Expeditions Science 
Programme invites guests to take part in these scientific activities. 
The programme aims to increase the knowledge and interest 
of its guests in the areas it visits. It allows guests to develop a 
greater understanding of the regions they visit and become true 
ambassadors championing the protection of the planet’s most 
fragile ecosystems. 
Examples of onboard projects are seabird distribution with 
the Antarctic Site Inventory, Cloud Observations with the 
Globe Programme and the monitoring of penguin colonies, 
phytoplankton and algae blooms. Hurtigruten’s Young Explorers’ 
Programme, for children between the ages of six and 12, helps 
them to learn about other cultures, the importance of nature in 
their daily lives and the impact humans have on the planet.  
The goal of the programme is to offer children a deeper 
understanding of nature, climate and culture.
ENVIRONMENT
HURTIGRUTEN
SECTOR
Leisure
HEADQUARTERS
Oslo, Norway
WEBSITE
www.hurtigruten.com
1930s 
the decade Hurtigruten 
ships started collecting 
data for scientists
10
citizen science projects
15%
of guests participated in 
citizen science projects in 2021
“We invite our guests to participate in 
science activities, developing a greater 
understanding of the region in which they 
travel, becoming true ambassadors and 
returning home to champion the protection  
of our planet’s most fragile ecosystems.”
Daniel Skjeldam
CEO, Hurtigruten
Creating ocean  
science ambassadors

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        20
EG Group, one of the world’s leading independent convenience 
retailers, continues to invest in producing electricity for its own 
needs through renewable resources such as solar photovoltaics 
and solar thermal. It now benefits from power generated by 
solar panels installed at more than 280 sites across the UK, as well 
as several sites in the Netherlands and France. It started taking 
advantage of the feed-in tariffs the UK government was offering 
for supplying solar power to the grid in 2014. The tariff scheme 
ended in 2019, but continuing with the roll-out means the group 
continues to use solar to reduce overall energy consumption. 
It initially began retrofitting suitable sites and, from 2018, it has 
included solar panels as standard on all new petrol filling stations 
and selected foodservice sites. In October 2020, EG Group 
also installed more than 1,000 solar panels on its headquarters 
in the UK. In 2021, its solar panels in the UK generated more 
than 5.7million kWhs. The group has also rolled out LED lighting, 
decreasing the electricity required to light sites across the group 
by 65%.
ENVIRONMENT
EG GROUP
SECTOR
Consumer Services
HEADQUARTERS
Blackburn, UK
WEBSITE
www.eg.group
5.7m kWhs  
the energy generated by  
EG Group’s solar panels  
in the UK in 2021
>1,000  
the number of 
solar panels installed 
at the group’s HQ
65%  
the decrease in electricity 
required to light sites after 
switching to LED lighting
“We believe it is important to improve and 
evolve our operations through investments in 
renewable energy, including solar panels at 
our sites. At EG we have a target to reduce 
our operational carbon footprint by 50% 
by 2030 (from 2021). We are developing a 
roadmap for how we will achieve reductions, 
which offer both energy and emissions 
reductions, and also potential cost savings.” 
Amina Batool
Head of ESG & Sustainability, EG Group
Going solar

22
21        ESG & Sustainability Report 2021/22
Social
SOCIAL
Overview
Most of our companies are people businesses. Across the 
portfolio there are approximately 280,000 employed across 
numerous sectors and geographies and creating people-centric 
companies has been key to growing successful businesses. To 
help create this environment our portfolio companies have 
invested in a range of programmes and initiatives which support 
the development, wellbeing, diversity and expected behaviours 
of their employees. This activity includes:
	
●Creating award-winning career learning and  
development programmes
Investing in learning and development programmes has 
helped to both attract and retain talent across our portfolio 
companies. This has also been essential in creating highly 
skilled and competent teams focused on delivering success 
and high levels of customer service. 
	
●Investing in initiatives which support individual health  
and wellbeing
Creating a strong culture of health and wellbeing provides 
the environment for individuals to thrive and show their full 
potential. This includes providing both in-house and external 
support across the areas of mental, physical and financial 
wellbeing. Our companies provided support to employees 
throughout the pandemic and will now be conscious of how 
some employees will be impacted by cost of living challenges. 
SOCIAL IN ACTION
ARROW GLOBAL 
Empowering young people 
through financial education
23-24
BPP HOLDINGS
Creating the next 
generation of lawyers
25-26
COST OF LIVING CRISIS
ARROW, ASDA, ILKE
27-28
Outreach programmes
Our portfolio companies are in 
the position to offer a range of 
support through varying outreach 
programmes. This includes 
providing support to low income 
and community groups, young 
people about to enter the job 
market and numerous national 
and international charities. We 
have seen this level of activity 
increase, as society looks to 
businesses for leadership in 
helping address a range of 
challenges, such as the impact 
of rising costs on household 
budgets. The following case 
studies provide insights into 
how companies are providing 
innovative solutions to help 
meet these new challenges by 
delivering positive impact through 
their products and services. 
	
●Providing a workplace which promotes equality, diversity  
and inclusion
A key area of focus has been the promotion of equality, 
diversity and inclusion both within the portfolio and at the 
firm level. This includes reviewing recruitment practices, 
educating senior leaders, refreshing internal policies and 
celebrating different cultures with the aim of promoting 
greater diversity and inclusivity in the workplace. We also 
recognise the importance of diversity of perspectives and 
opinions in terms of optimising decision-making and promote 
this across our portfolio. 
	
●Operating with a clear code of conduct to promote the  
correct behaviours
All portfolio companies have now published their own  
stand-alone employee codes of conduct. This has helped to 
set a clear expectation on the behaviours and standards of all 
employees, contributing to a high standard of professionalism 
across our portfolio. This also links behaviours with the 
companies’ values, goals and mission to create a clear 
framework for success at the individual and company level.  
TDR supports and actively participates in several corporate schemes that 
are focused on promoting diversity within the industry as a whole. We are a 
founding member of Level 20 and Out Investors, two industry initiatives that 
encourage greater understanding and levels of diversity in the sector. We 
are also a participating firm in #10000 Black Interns and recently became a 
supporter of GAIN (Girls Are Investors).

23       ESG & Sustainability Report 2021/22
        24
Arrow Global is proud to support Junior Achievement Europe, 
part of the Junior Achievement Worldwide network that was 
nominated for the Nobel Peace Prize 2022. The partnership 
supports financial education across Europe, providing classroom-
based learning and online activities to almost 10,000 young people 
every year. Through its flagship ‘learn to earn’ programme, Arrow 
employees volunteer their help to equip students with the tools 
and knowledge to make good financial choices, providing them 
with information on career opportunities for life after education. 
In addition, Arrow’s team of more than 630 volunteers engaged 
through activities such as mentoring, financial boot camps, 
support for business planning and innovation and virtual job 
shadowing. The programme’s online educational videos, known 
as ‘Talking Heads’, see volunteers talk about a range of topics, 
such as interview and presentation skills and CV writing, as well as 
broader topics covering leadership and entrepreneurship. These 
are shared across schools, helping thousands of young people 
develop important life skills. Taking this concept one step further, 
Arrow’s Portuguese volunteers delivered an online financial literacy 
webinar in support of International Student Day that focused on 
building responsible financial futures. The event reached 65 schools 
and 1,500 students, and this live tuition has been replicated in Italy, 
with volunteers tutoring seven schools in the final quarter of 2021.
SOCIAL
ARROW GLOBAL
SECTOR
Financial Services
HEADQUARTERS
Manchester, UK
WEBSITE
www.arrowglobal.net 
10,000
young people reached 
by the financial education  
programme every year
630
Arrow volunteers took 
part in the programme
2018
the year the partnership 
with Junior Achievement began
“This continued partnership represents a great 
opportunity for the Arrow group to once again 
give back to the communities it works with. We 
are proud to be part of the effort to encourage 
financial literacy and a career in finance 
among young people. We have partnered 
with Junior Achievement Europe since 2018, 
and we look forward to continuing to work 
with them to support young people across 
Europe and fulfil our social responsibilities.” 
Paul Woods
Group Director of Sustainability & ESG, Arrow Global
Empowering young 
people through  
financial education

25       ESG & Sustainability Report 2021/22
        26
The BPP Pro Bono Centre provides free legal advice and support 
services to the public, delivered by volunteer BPP University 
students under the guidance of the Pro Bono Centre and BPP 
University. Through Streetlaw and the Law Ambassador Programme 
(LAP), BPP has been partnering with leading law firms to provide 
young people with knowledge of the law and the legal profession, 
as well as a connection to people working in it. The LAP focuses 
on improving access to the legal profession to young people 
from lower socioeconomic areas, working with mentor lawyers to 
speak to young people and guide them through the realities of a 
career in law. Through working with law firms, BPP has helped to 
send mentors to schools in lower socioeconomic areas in the UK 
over the past five years. BPP’s aim is to improve employability by 
increasing confidence, developing transferable skills and providing 
practical experience of the working world. The BPP LAP has won 
several awards in recent years, including the 2022 LawWorks & 
Attorney General Student Pro Bono Award for best contribution by 
a Law School, the 2018 Yorkshire Legal Award and was shortlisted 
for the 2019 Leadership Award at the UK Social Mobility Awards. 
SOCIAL
BPP HOLDINGS
SECTOR
Education
HEADQUARTERS
London, UK
WEBSITE
www.bpp.com
145
Law Ambassadors currently 
taking part in the programme  
(as of June 2022)
2022
LawWorks & Attorney General  
Student Pro Bono Award for best  
contribution by a Law School
5 
law firms provide mentors as  
part of the programme
“The Law Ambassador Course has allowed 
me to become a lot more confident. The 
workshops have really helped to improve my 
public speaking”
Participant 
“Taking part in this programme has given me 
a real opportunity to explore the realities of a 
career in law.”
Participant 
Creating the next  
generation of lawyers

27       ESG & Sustainability Report 2021/22
        28
SOCIAL
ARROW GLOBAL
ASDA
ILKE
We recognise that our 
portfolio companies can 
play an important role in 
supporting their customers, 
communities and employees 
in helping to alleviate the 
increasing financial pressures 
that households are currently 
experiencing. These case 
studies provide an example of 
how three companies have 
responded through providing 
support and innovative 
solutions to a complex 
situation affecting people in 
different ways.
Arrow Global joins StepChange to  
promote Debt Awareness Week
Arrow Global UK provided support to 
StepChange, the UK’s largest debt 
advice charity, during Debt Awareness 
week in March. This year’s Debt 
Awareness Week has been named 
‘Let’s Start the Conversation’, centred 
around problem debt. This recognises 
people struggling to talk about 
personal debt due to the perceived 
stigma and embarrassment. Arrow 
and StepChange have partnered 
to provide a comprehensive range 
of support materials including virtual 
seminars to help Arrow’s customers 
better manage their financial 
wellbeing.
Asda helps to tackle holiday hunger
In the run-up to the school summer 
holidays Asda launched a new Kids 
Eat for £1 initiative to help parents 
cope with the cost of living crisis over 
the summer. As part of the initiative, 
children under 16 were able to buy 
a hot or cold meal for just £1 in Asda 
cafes across the country. The offer 
was made available seven days a 
week with no minimum adult spend 
required. This has helped to ensure 
that those children that normally 
rely on a school meal were not left 
without over the school holidays. 
ilke launches ZERO energy bills homes
ilke has launched ZERO Bills, the UK’s 
first home to guarantee residents zero 
energy bills. Octopus Energy and ilke 
Homes have entered a world-first 
strategic partnership on a site in Essex 
where ilke is delivering the UK’s largest 
zero-carbon housing development. 
Low-carbon technologies will 
combine to provide free, clean 
energy round the clock, with Octopus 
Energy providing a bespoke tariff. 
Launched in July 2021, ilke ZERO aims 
to deliver thousands of operational 
zero-carbon homes per year for major 
investors, housing associations and 
councils across the UK.
“‘Let’s start the conversation’ is a hugely 
important discussion as more household 
finances are put under pressure. As a 
customer-led business whose purpose is 
to build better financial futures, we have 
an obligation to support customers during 
these uncertain times.”
Jim Appleby
CEO, Arrow UK 
“We aim to help customers, colleagues 
and communities to enjoy better lives, 
by removing the barriers to opportunity, 
health and wellbeing. We know that 
families can find the school holidays 
tough, and our customers told us that 
this year more than ever, they were 
concerned about holiday hunger. With 
that in mind, we were so pleased to be 
able to offer children’s meals for just £1 
and ease their burden.”
Jacki Simpson
Vice President of Reputation, Asda
“Our strategic partnership with Octopus 
Energy Group is the next milestone on 
our ilke ZERO journey. The premise of 
this partnership is to both empower 
consumers, who are faced with one of 
the worst cost of living crises in decades, 
and demonstrate that net-zero and 
construction can work hand in hand.“
Giles Carter
CEO, ilke Homes
Cost of  
living crisis

29       ESG & Sustainability Report 2021/22
        30
GOVERNANCE
Governance
Overview
We seek to ensure compliance with laws and regulations 
including anti-corruption, competition law, labour laws 
and regulations and fair working practices at our portfolio 
companies. TDR works closely with the relevant management 
at portfolio companies to ensure that appropriate policies and 
procedures are in place to deal with work related incidents.
As a majority investor, TDR’s presence on the board of portfolio 
companies enables us to ensure accountability at the highest 
level. We take a case-by-case approach with management to 
understand compliance with guidelines. If gaps are identified, 
we will work closely with companies to align with the necessary 
guidelines and industry best practices, for example TCFD,  
UN SDGs, CDP, GRI, as appropriate. 
We engage with portfolio companies to ensure high standards of 
governance, this includes:
	
●Business continuity plans
	
●Policies and procedures to safeguard against acts of  
modern slavery
	
●Strong safeguards against potential acts of bribery and 
corruption, including money laundering
	
●Data protection & cyber security – policies, practices and 
procedures to avoid any data or security breaches.
GOVERNANCE IN ACTION
TDR CAPITAL 
Systematically  
collecting ESG data
31-32
ASDA
A commitment 
to transparency
33-34
HURTIGRUTEN
Making data breaches history 
35-36
Cyber Security
We continue to build upon our relationship with Orpheus Cyber, 
the only UK-government accredited company providing threat 
intelligence and cyber risk rating services. Orpheus provides 
cyber risk ratings across all of our portfolio companies. Each 
company’s risk rating is a combination of vulnerabilities visible 
on the organisation’s attack surface and threat intelligence. This 
helps to manage potential risks and avoid value erosion in the 
portfolio from a cyber-attack. The Orpheus solution also helps to 
mitigate our own risk and avoid direct attacks.
Orpheus provides a further line 
of defence against potential 
exposure to cyber security 
threats, providing external 
verification of the effectiveness 
of portfolio companies’ 
external facing security 
systems and processes. Over 
the next 12 months, we aim 
to deepen our understanding 
of companies’ cyber security 
strength and ensure they are 
taking a risk-based approach 
to cyber resilience.
Maninder Singh
Head of IT, TDR Capital

31       ESG & Sustainability Report 2021/22
        32
As our approach to ESG and sustainability has evolved and 
we have adopted more frameworks for measuring impact, 
the processes we use for tracking and benchmarking progress 
against key metrics have had to evolve as well. We previously 
used a manual data collection process in Excel, which was time 
consuming and meant that tracking and reporting progress 
required significant effort. To simplify the process, TDR has 
partnered with Worldfavor to create a data platform that collects 
and helps to analyse ESG data from our portfolio companies. 
The platform automates data collection and reporting, allowing 
us to assess quickly and simply how our portfolio companies 
are managing key ESG risks and opportunities, as well as 
communicating this to our investors and other stakeholders. 
Worldfavor also allows us to benchmark our own impact 
and that of our portfolio companies, against standardised 
frameworks such as the SFDR, the UN Global Compact, UN 
SDGs and customised metrics. This will allow us to collect data 
on increasingly complex ESG KPIs, 51 in total, across each 
portfolio company every year. The platform also allows us to 
automate the receipt of quarterly portfolio company reports.
GOVERNANCE
TDR CAPITAL
13
portfolio companies’ 
data collected
51
ESG KPIs tracked for each  
company every year
107
million tonnes of CO2e  
(Scope 1,2&3) reported  
through the platform in 2021
“The introduction of a data collection 
platform will help enhance the way we 
collect and analyse the ESG data we 
receive from our portfolio companies. 
Working with our Data Science Team we 
can begin to more effectively monitor 
performance and identify the potential  
for value enhancing opportunities.”
Nigel Smith
Head of ESG & Sustainability, TDR Capital
Systematically  
collecting ESG data

33       ESG & Sustainability Report 2021/22
        34
Asda has always believed in straightforward, honest 
communication – and that is at the heart of its ESG reporting. 
It wants its progress – the good and the not so good – to drive 
wider change. As such, it annually reports on its approach to ESG 
issues and its performance during the year, covering Asda Group 
Limited and its subsidiaries including International Procurement 
Logistics (IPL). These reports are prepared in accordance with 
Global Reporting Initiative (GRI) core standards and the United 
Nations (UN) Sustainable Development Goals (SDGs). In 2021, 
Asda introduced a dedicated ESG claims management software 
system to capture and substantiate all its ESG disclosures. This was 
a significant milestone in how it governs and manages ESG in a 
credible and transparent way. In addition to its annual reports, 
Asda publishes information on initiatives it has implemented to 
create a better planet, better lives and better business on its 
website. It also tracks its strategic commitments across 13 ESG 
areas, including SDG-aligned targets such as reducing food waste 
by 20% and reducing GHG emissions by 50% by 2025, in a table 
published online. This tracks annual progress towards these goals, 
as well as baseline figures against which progress is benchmarked. 
GOVERNANCE
ASDA
SECTOR
Retail
HEADQUARTERS
Leeds, UK
WEBSITE
www.asda.com
51
strategic commitments 
tracked and reported online
10
years of reporting 
Asda’s carbon footprint
7
ESG policies published online for 
areas such as animal welfare, 
palm oil and pesticides
“At Asda, we’ve always believed in straight 
forward, honest communications – and that is 
at the heart of our ESG reporting. We want our 
progress, the good and the not so good, to 
drive wider change.”
Jo Warner
Senior Director, Corporate Responsibility & ESG 
Asda
A commitment  
to transparency

35       ESG & Sustainability Report 2021/22
        36
Prioritising data security is not a new concept for Hurtigruten, 
which has long worked to ensure privacy for all guests and 
employees. As a tourism provider working across multiple 
markets, including Europe, the Americas and Africa, providing 
digital privacy wherever the cruise ships go is a key part of the 
journey. Since suffering a cyberattack in 2020, the Hurtigruten 
data security and compliance systems and procedures have 
been updated and improved with the goal of having zero 
breaches requiring reporting to data protection authorities. 
Role-specific GDPR training has been implemented across 
the group, ensuring that every employee is aware of their 
role in data protection. The amount of mandatory training for 
employees is set to increase in 2022, reflecting the global data 
landscape. August 2021 saw the appointment of the group’s 
Data Protection Officer (DPO) who supports the Chief Digital 
and People Officer through performing audits and evaluations 
on group data compliance, as well as leading the continued 
development of Hurtigruten’s data security measures. Data has 
become one of the world’s most sought-after commodities. 
Guests and employees trust Hurtigruten with their data and it is 
the company’s responsibility to respect and protect it. 
GOVERNANCE
HURTIGRUTEN
SECTOR
Leisure
HEADQUARTERS
Oslo, Norway
WEBSITE
www.hurtigruten.com
0
reportable data  
breaches in 2021
2021
data privacy & security 
identified as one of eight  
key material topics
“Cyber Security is of the utmost importance 
for us, as the world and our ships are 
increasingly connected together. Today, 
taking a broad approach to cyber security 
is critical; automating and standardising 
wherever possible, diligently staying at 
the forefront of technical development, 
monitoring IT systems 24/7 and not least 
training every employee to be a strong line 
of defense against potential attacks.”
Ole-Marius Moe-Helgesen
Chief Digital Officer, Hurtigruten
Making data  
breaches history

For more information,
please contact
Nigel Smith
Head of ESG & Sustainability
nigel.smith@tdrcapital.com
Phone: +44 (0)79 0022 6197
TDR Capital LLP,
20 Bentinck Street,
London, W1U 2EU
TDR Capital LLP is a Limited 
Liability Partnership registered 
in England and Wales with the 
registered number OC302604. It is 
authorised and regulated by the 
Financial Conduct Authority.