Sustainability &People Report 2022
JANUARY 2023

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

CONTENTS

4

13

31

INTRODUCTIONINVESTING SUSTAINABLY

OPERATING PURPOSEFULLYICG is a global alternative asset manager.
We provide flexible financing solutions to
help companies develop and grow.

ICG seeks to expand and embed responsible
investing practices throughout its portfolios.

How we do our work matters as much as what
we do. We operate with the ambition of making
a positive impact on society.

41
FURTHER DISCLOSURES

CEO foreword

5

Embedding ESG in our investment culture

14

Our people & culture32

GRI and SASB content index

42

ICG at a glance

6

Responsible investing across our asset classes

16

Our communities

36

Supplementary corporate disclosures

56

Generating sustainable value

7

Evaluate17

Our operations

38

Important information

57

ESG governance

8

Engage19

Areas of focus in 2022

9

Report28

Our ESG approach – looking back, looking ahead

10

Collaborate

30

Towards net zero11

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SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

ABOUT THIS REPORT
Welcome to ICG’s Sustainability & People Report 2022.
This report provides sustainability achievements and updates delivered
by ICG through the year in both our investments under management andwithin ICG’s operations.
The report focuses on our key priorities, approach and performancethrough an environmental, social and governance (ESG) lens which
are integral to our vision and strategy.
Reported data is provided for the 12-month period ending 30 September
2022, and is provided for all operating subsidiaries within the Group,
unless otherwise stated.
In developing this report, we have considered the guidance of SASB
and the Global Reporting Initiative (GRI) in the approach, structure,
principles and indicators on which we report. Our SASB and GRI content
index is provided in the final section of the report.

How to use this report
The following symbols indicate that
additional information can be found either
in this report, on our website, in a video
online, or in our latest Annual Report:
Read morein this report
View moreon our website
Watch
as a video online
Find out morein our 2022 Annual Report

Find out more about our approachto sustainability online atwww.icgam.com/sustainability-esg/

3 | ICGAM.COM

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Operating purposefully

Further disclosures

Introduction

ICG is a global alternative asset manager.
We provide flexible financing solutions to
help companies develop and grow. We adopt
responsible and sustainable business practices
to make a positive impact on society throughour investments and operations.

CEO foreword

5

ICG at a glance

6

Generating sustainable value

7

ESG governance

8

Areas of focus in 2022

9

Our ESG approach – looking back, looking ahead

10

Towards net zero11

4 | ICGAM.COM

Investing sustainably

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

CEO FOREWORD
Last year I was proud to announce our commitment to achieving net zero greenhouse gas
emissions across our operations and relevant investments by 2040, supported by two
ambitious targets which have been approved and validated by the Science Based Targets
initiative (SBTi) (see pg. 12). While it is exciting to be one of the first alternative asset managers
to have set a net zero commitment, it’s even more important to show progress againstthat goal. Hence, I’m pleased to share that on the first anniversary year of ICG’s net zerocommitment, nine portfolio companies have led the way in setting science-based GHG
emissions reduction targets: 15% of relevant investments in our first year alone. And, manyother companies have advanced their target-setting plans, placing ICG well on track toachieve its interim target of 50% of relevant investments having such targets by 2026
(see pg. 12).
We continue to build a culture that promotes ESG through our people (see pg. 32) andin the expansion of our investment strategies. During the year we enhanced our approachto ESG integration in order to enable our investment teams to better evaluate ESG factors
and engage on ESG matters with our portfolios – with results demonstrated throughout
this report.

Benoît Durteste
Chief Executive Officer and Chief Investment Officer, ICG
I am pleased to share our 2022 Sustainability & People Report, which builds on last year’s
efforts to make the report more comprehensive and reflective of ICG’s progress, and toensure more robust communication with our stakeholders.
Over the last year, against an increasingly challenging macro environment, ICG continued
to grow – in AUM, in client base, in profitability, and in number of employees. We havemaintained a strong focus on sustainability and people, as both are integral to ourcontinued success.
I believe leadership on ESG is not only the right thing to do – enabling us to contribute to amore sustainable global economy, more equitable workplaces and communities, and morerobust and transparent governance practices – but it also makes good business sense.

We have approached the Sustainable Finance Disclosure Regulation (SFDR) withthoughtfulness and intent, and I’m pleased to note that the vast majority of the funds wemanage are Article 8 – meaning they promote environmental and/or social characteristics.
We have made some strategic hires across the organisation to ensure we have the breadthand depth of expertise to execute on the long-term opportunities ahead, and helping tofuture-proof ICG as we continue to market a larger range of products to a growing andincreasingly complex set of clients.
I invite you to review our progress and explore some areas we will look to expand in the
future, as we continue to strengthen our approach to ESG throughout the firm.

2022 benchmarks and ratings2
UN PRI1
2021 assessment

Climate Change Score 2022
Investment & Stewardship Policy

Fixed Income – Corporate

Leadership
A(2021: Management, B)

Fixed Income – Private Debt

S&P Global

MSCI

Corporate Sustainability
Assessment 2022

ESG Rating 2022

65/100Industry Leader
AAA(2021: 59/100)(2021: Industry Leader, AAA)Benoît Durteste
Chief Executive Officer and Chief Investment Officer, ICG

While we consider numerous environmental, social and governance matters on an ongoingbasis, this year three themes emerged as particular priorities across both our investment
approach and our own operations: climate change, diversity and inclusion (D&I), and digital
resilience as a governance matter. These topics are not only timely, but worthy of focus
as they contribute to greater business resilience – in our own firm and in the ambitious
companies in which we invest.

Sustainalytics
ESG Risk Rating 2022

1.	2021 UN PRI assessment scores: 4/5 stars for Investment & Stewardship Policy; 5/5 stars for Fixed Income – Corporate; and 4/5 stars for Fixed Income – Private Debt.
2. All scores and information with regards to benchmarks and ratings were accessed on 13 December 2022.

Became a member of DJSI Europe
Index in 2022

Low risk
15.8(2021: Low risk, 18.4)

5 | ICGAM.COM

CDP

Constituent of the FSTE4Good
UK Index since 2018

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

ICG AT A GLANCE
ICG provides flexible capital solutions to help companies develop and grow.
We manage and invest capital on behalf of our clients across the asset capital
structure to achieve our strategic objectives.

Assets under management

Our key strengths$68.6bn2

Local presence

575

15

permanent employees acrosscountries1$25.3bn

Structured and Private Equity$18.7bn$7.7bnPrivate Debt

$16.9bn

CreditA global network of 575 employees in 15 countries
underpins our ability to source, execute, supportand manage investments.

Real Assets

Focus on clients’ needs
Our global client team ensures that we continue
to understand and meet the requirements ofour clients.

Global client franchise

6183

Ability to invest acrossthe capital structure
We provide capital to companies
in a form appropriate to their needs.

35%

EMEA (excl. UK and Ireland)

24%

Asia Pacific22%

Americas19%

UK and Ireland

Capital to support growth

1. Group headcount as of 30 September 2022.
2.	Total AUM as at 30 September 2022. Due to rounding, numbers do not add up
precisely to the total.
3 As at 30 September 2022. Split based on Total AUM.
6 | ICGAM.COM

Our balance sheet is a strategic advantage thatenables us to seed and accelerate new strategies
and align our interests with our clients.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GENERATING SUSTAINABLE VALUE
We develop long-term, resilient relationships to deliver value for shareholders, clients and employees, and work with ourportfolio companies to foster positive impacts on society and the environment. We identify the ESG topics most relevant
to our stakeholders as well as those that align to our company values and investment ethos.
Our values drive success

Our platform generates value for...

to inform our ESG priorities

our stakeholders...

For Group and investment activities

Grow AUM

Entrepreneurialism
and innovation– Raise and manage third-party assets,largely in closed-ended funds

Environmental
Shareholders and lenders
Climate change*
Clients

Grow AUM
Performance for our clients

Employees

Invest

Inv
e st

ali
se

re

Ambition and focus

Communities

Diversity and inclusion* Employee development& engagement

EnvironmentdanWorking collaboratively andacting with integrity– Identify and secure attractive
investment opportunities

e
Manag

Taking responsibility andmanaging riskSocialSuppliers

Manage and realise– Work with management teams in ourinvestments to drive strategic change– Successfully realise investments
to crystallise returns for clientsand shareholders

Regulators

Corporate governance &business ethics Governance & business ethics

Portfolio companies

Digital resilience*

Read more*
Areas of focus in 2022 on pg. 9

7 | ICGAM.COM

Read more
about how we assess materiality in
our Further disclosures on pg. 51

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

ESG GOVERNANCE
ICG has been a publicly listed company since 1994. We seek to promote the highest standardsof corporate governance throughout our activities and culture to act in the best interests ofour stakeholders.

Board oversight of ESG matters

The ICG Board is strongly engaged in our focus on
stewardship and ESG, regularly receiving reports onclient considerations, client experience, investment
performance and ESG matters. We have a NonExecutive Director responsible for ESG mattersand another Non-Executive Director with a specificresponsibility for employee engagement.

The Board comprises three Executive Directors, a Non-Executive Chair,and seven Non-Executive Directors (all of whom are independent) who
have a broad and diverse set of skills and experience.

Board of Directors

Audit
Committee

Risk
Committee

Remuneration
Committee

Find out more
Please see our Annual Report pg. 57 for our approach to risk management.

8 | ICGAM.COM

Executive Directors

Nominationsand GovernanceCommittee

Responsible
InvestingCommittee

The Board receives formal updates on ESG-related
matters at least twice every financial year andreceives annual updates on progress. In addition,
the Board also considers ESG risk, as relevant, whenreviewing the annual strategy and business plansover the short, medium, and long term. The Board
has delegated responsibility for the implementationof the Responsible Investing Policy to the Executive
Directors. As part of the Board, the Executive
Directors review and guide any decisions maderegarding investment strategies, including the
Responsible Investing Policy and the Climate Change
Policy, as well as any arising or potential climaterelated issues.
The Board Risk Committee oversees the Group’s
comprehensive risk governance framework andcompliance processes and procedures to ensurethat all risks, including ESG and climate-related risks,
are identified, managed, and monitored and that theGroup is compliant with all applicable legislation.
ICG’s eight established principal risks incorporate
or consider a variety of factors that cut across them,including ESG. Further information on our approachto managing risk can be found on pg. 57 of our
Annual Report.

Responsible Investing Committee
ICG has had a Responsible Investing Committee since2014, made up of our Global Head of Sustainability &ESG, Head of Investment Office, and senior investment
professionals from across ICG’s investment strategies.
The Committee promotes, supports, and helps tointegrate responsible and sustainable business practices
across ICG’s investment strategies and the businesses
in which we invest, in line with our Responsible Investing(RI) Policy and Framework. The Committee is also
responsible for ensuring that ICG’s investment teams
have the required skills and understanding to effectively
identify ESG risks and opportunities and engage with
relevant company management in our portfolio companies
on ESG matters.

Find out more
Please see our Responsible Investing Policy.

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

AREAS OF FOCUS IN 2022
2022 saw significant global macro and geopolitical events that affected the economy and our lives.
Three large ESG themes emerged as focal areas for ICG, all of which factor into business resilienceand are important traits of business growth and success.
Climate change

Diversity and inclusion

Investment activity highlights

Climate risk assessment

Engagement on decarbonisation

90%

300+

of total AUM covered by a comprehensive climate risk
assessment, with enhanced scenario analysis of holdings withpotentially heightened climate risk exposure (see pg. 17).

investee companies and 10+ GPs engaged on
climate change (see pg. 19-27).

Digital resilience

Investment activity highlights

Investment activity highlights

87%

ESG dataof portfolio companies3 in our Europeanand Asia Pacific corporate funds, and 77%
of borrowers in our Senior Debt Partners
strategy, are implementing initiatives ortargets to improve diversity and inclusion(D&I) in their organisations (see pg. 23).

ESG data management platform deployed to support
ESG integration, portfolio monitoring and reporting
across 100% of AUM (see pg. 29).

Group highlights

Strategies with climate focus

27%
of total AUM in strategies2 with explicit focus on engagement
on climate change and/or in scope of ICG’s portfolio coveragescience-based target (see pg. 19 and pg. 23).

9
portfolio companies have set science-based emissions
reduction targets, committing to a reduction of over
69 thousand tonnes of CO2e emissions today in linewith the latest climate science (see pg. 11-12).
Group highlights

Renewable energy infrastructure capacity

Renewable energy in ICG operations

1,703 MW58%

of renewable energy capacity deployed across theInfrastructure Equity portfolio1 (see pg. 26).

of electricity consumed by ICG offices was fromrenewable sources in FY22, up from only 22.5%
in FY21 (see pg. 12 and pg. 38).

1. 	As at 30 September 2022.
2.	Includes European and Asia Pacific Corporate, Infrastructure Equity, Sale and Leaseback, and European Real Estate Debt.
3.	Source: ICG’s Annual ESGs survey of portfolio companies across European and Asia Pacific Corporate, and Senior Debt Partners.
4. Year ending 30 September 2022.
9 | ICGAM.COM

senior management at ICG globally, and
35% female
41% in the UK, at the end of FY22. We were
therefore pleased to achieve our UK Women in
Finance Charter ambition (33% female senior
management in the UK) a year early.

portfolio companies where we have
94% ofsufficient
influence across the European

Corporate strategy have completed orlaunched an internal audit of cyber capabilities
and include a clear plan of remedial actions.

1st Inclusion Survey
conducted across all ICG operations with 75% response
rate from our employees globally (see pg. 34).
from FY23 to FY25, to support our£4m committed
new partner charities, focusing on educationand social mobility (see pg. 36). £2.5m has
been donated to charity this year in total4.

Group highlights

Cyber controls
Continuously enhanced vigilance and controls over cyberrisks at ICG (see pg. 40).

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

OUR ESG APPROACH – LOOKING BACK, LOOKING AHEAD
For example, this year we put in place a requirement for portfolio
managers to attest to the implementation of relevant ESG assessments
and procedures for their given strategies, which will be linked to theiryear-end compensation. This measure not only ensures accountability
for ESG integration, but also enables senior investment professionals
to set an example for their teams.

Elsa Palanza
Global Head of Sustainability & ESG, ICG

I am delighted to have joined ICG. Its track record in investing
successfully and its commitment to ESG leadership are clear, and I am
excited for the opportunity to further develop and embed meaningfulsustainability action throughout the firm and its investment activities.
The universe of ESG topics facing investors is ever-expanding, andICG’s challenge and opportunity will be to add value – both societal
and economic – through the thoughtful consideration of these
ESG factors. The structural trends towards private markets remain
intact, with asset owners continuing to increase allocations. With
growing AUM over the long term across multiple asset classes, ICG’sopportunity becomes ever-greater to support the development of
more resilient, nature-positive and human-centred businesses befitting
a low carbon economy and sustainable economic future.
Following a year of important announcements – including ICG’scommitment to net zero by 2040, supported by the establishmentof two important approved and validated science-based targets(see pg. 12) – the Group has focused on embedding the rightinternal systems to ensure we can make progress against thosetargets and further embed ESG into decision-making.

NatureWe have also seen innovative approaches to aligning our investments
and business with our decarbonisation goals. In one year alone, wehave seen a 47% increase in the total AUM of sustainably-themed
products in real assets (see pg. 24). And, in 2022 ICG issued an 8-year,€500m unsecured bond with an annual coupon adjustment based on
the progress ICG makes in achieving its science-based targets.
This is the latest facility to contribute to our overall total of $3.6bn
in ESG-linked financing to date.

With more than half of the world’s economic output moderately
or highly dependent on nature, the loss of nature and biodiversity
poses enormous risks – and opportunities – for economies, andthus for investors. Moreover, nature loss is inextricably linked tothe climate crisis, ensuring we cannot achieve net zero without
also addressing nature. In 2022, ICG joined the Taskforce on
Nature-Related Financial Disclosures (TNFD) Forum, to support
the development of a risk management and disclosure frameworkfor organisations to report and act on evolving nature-relatedrisks, with the ultimate aim of supporting a shift in global financial
flows away from nature-negative outcomes and towards naturepositive outcomes. We look forward to exploring ways tobetter incorporate nature-related risks and opportunities into
our company engagement and investment considerations.

In recent years, stakeholders have increasingly demanded that financial
institutions play an active role in responding to the climate crisis.
Looking ahead, not only will climate change remain a central priority for
ICG, but we will make our approach more expansive and sophisticated,ensuring we consider the myriad, interconnected social andenvironmental factors related to climate. For example, we will explore
risks and opportunities related to nature and biodiversity,
as well as a just transition.
In 2023 and beyond, we will focus on building and implementing amore comprehensive plan for net zero for the firm. Where we havesufficient influence, we will continue to support management teams
in setting science-based emissions reduction targets for theirbusinesses. And, we will work to assess possible solutions for asset
classes or strategies within our portfolio where we do not yet have thetools to assess, measure and manage for net zero, where relevant.
We will also seek to expand our integration of additional ESG topics
as they become focal areas for our stakeholders and as they are
increasingly pertinent to our investments. For example, given thechallenges facing societies the world over, we will continue to assessthe “S” in ESG – advancing our commitment to progress on D&I,
and thinking about how best to assess equity and human rights.
We know engagement must remain a focal point in order to drive stronger
sustainability outcomes. ICG will continue to prioritise embedding ESG
into our activities, always with an eye towards continuous improvement
and action in areas where we can make meaningful impact.

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Spotlight on emerging issues

Human rights
As stakeholders increase focus on the “S” in ESG, there
is growing visibility and awareness of the private sector’s
responsibilities to uphold and protect human rights. The
regulatory and policy environment is increasingly focusedon human rights due diligence expectations in investment
decision-making, and on the responsibilities of business andinstitutional investors to respect human rights, as articulated
in the UN Guiding Principles on Business and Human Rights(UNGPs). As an alternative asset manager, ICG has a roleto play in incorporating human rights considerations into
our investment approach, in assessing the important links
between human rights and other ESG priorities, such as
climate change, and the role we can play in preventing or
mitigating potential impacts.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

TOWARDS NET ZERO
Climate change remains one of the most existential challenges of our time; a threat
to human lives, the natural world, individual livelihoods, and economies at large.
As an investor and provider of capital, ICG has an opportunity and a responsibility
to support the transition to a more sustainable economy.
In November 2021, ICG announced its
commitment to reach net zero greenhousegas (GHG) emissions across its operations
and relevant investments by 2040. The
Group’s net zero commitment is supported
by two ambitious emissions reduction
targets by 2030, which have been approved
and validated by the Science Based Targets
initiative (SBTi) (see targets below).
While our own operational emissions havenegligible impact compared to those of ourinvestments, we recognise our responsibility
to ensure our own business operations
are fully accounted for (see pg. 12). ICG
will continue to deploy energy efficiency
and renewable energy initiatives, and willoffset any residual emissions using credible
removal solutions.

In order to chart a path to net zero, ICG’s
top priority is the decarbonisation of ourportfolio wherever possible, through ourinvestment decision-making and engagement.
Over time, the tools to assess financed
emissions and measure net zero will evolvein the private markets. In addition to thesetting of SBTs for relevant investments,
ICG is developing a plan to systematicallyassess potential net zero solutions for the
strategies not covered by our SBTs.
We will continue to engage with industry
groups and thought leaders (see pg. 30) to
explore decarbonisation tools and net zeromeasurement frameworks for asset classes
which do not currently have them, and ICG
will consider these new solutions if/where
they might be applicable to our portfolios.

Our approved and validated science-based targets:

100%

80%

Ensure 100% of relevant
investments have SBTi-approved
science-based targets by 2030,
with an interim target of 50%
by 20261

Reduce ICG’s direct (Scope
1 and 2) emissions by 80% by
2030 from a 2020 base year

View moreon the SBTi website with our approved targets
11 | ICGAM.COM

Another powerful tool for responding
to climate change is ICG’s capacity forinvestment in climate solutions needed forthe real economy to reach net zero emissions,such as the infrastructure needed for thegrowth of renewable energy (see pg. 26).
Lastly, a successful global approach to
net zero will require the financial industry
to account for nature’s fundamental
contributions to combating climate change,
as well as a just transition to respond to
the impacts that a changing climate has
on human communities and livelihoods.
ICG will reflect these considerations in
our own approach, as we enhance our
ESG assessment and action over time.
ICG’s net zero strategy will continue to
evolve as we work towards building a morecomprehensive approach across the firm, tosupport the global goals of decarbonising
the real economy and building a moresustainable financial system.

1.	Relevant investments includes all investments
within Structured and Private Equity and Real
Assets where ICG has sufficient influence.

Operating purposefully

Further disclosures

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

TOWARDS NET ZERO CONTINUED
Progress report: Science-based targets
In November 2021, ICG was among the first alternative asset managers to have targets
approved by the SBTi. We are pleased to provide an update on the progress madesince we first set our targets and will continue to enhance our reporting, particularly
on relevant investments, as an industry-wide approach is adopted over time.
A. Scopes 1 and 2 – Absolute emissions
reduction target

B. Scope 3 – Portfolio coverage target“ICG commits to reduce absolute Scope 1 and 2 GHG
emissions 80% by 2030 from a 2020 base year.”During FY22, our Group Scope 1 and 2 (market-based)emissions decreased by 85% compared to FY20 baseline,
primarily due to a rise in the number of offices procuring
100% renewable electricity. While this means we have alreadyachieved our Scope 1 and 2 SBT, we remain determined tosustain this performance over time as the firm continues togrow and expand its presence globally. For further details
on our environmental stewardship initiatives across ouroperations, see pg. 38.

Group Scope 1 & 2 (market-based) greenhouse gas (GHG)
emissions (tCO2e)
1,000
800
600
400

0

In November 2021, building on years of focus on engaging portfolio
companies on climate change, we began implementing a dedicated
SBT engagement programme with relevant investments to:– Socialise what the science-based targets are, how they canbe developed, and the benefits to companies, namely further
building business resilience and encouraging greater innovation.
– Support portfolio companies in establishing their carbon
footprint baseline, following the GHG Protocol. Often
this involved educating management teams about thefundamentals of carbon footprinting and recommending
third-party climate advisors and/or solutions to support themin completing their baseline assessment; and building thecapability to monitor progress in the future.
– Input into the development of science-based targets and emissions
reduction action plans to ensure these are ambitious, yet feasible
to achieve and aligned with the business plan for our investment.
– Have such targets approved by the SBTi.
– Support the implementation of decarbonisation initiatives throughsharing networks, ideas and best practices across our portfolios.
As at 31 December 2022, we have engaged with all 321 portfolio
companies across five investment strategies2 qualifying as relevant
investments; representing nearly $8bn of invested capital.

200

FY
2017

“ICG commits that 50% of its relevant Structured andPrivate Equity, and Real Assets direct investments byinvested capital will have set science-based targets
by 2026 and 100% by 2030 from a 2021 base year.”

FY
2018

FY
FY
2019 2020

FY
2021

FY
FY
FY
FY
FY
FY
FY
FY
FY
2022 2023 2024 2025 2026 2027 2028 2029 2030

Total Scope 1 & 2 (market-based)
GHG emissions (tCO2e)

12 | ICGAM.COM

ICG SBTlinear trajectory

1.5 degreealigned trajectory

Watch
Portfolio companies at different stages of setting SBTs,
talking about their experience.

32

companies located in Asia Pacific, Europe, and North America qualify as relevant investments for ICG’s portfolio coveragetarget. ICG has engaged all such relevant investments on setting SBTi-approved GHG emissions reduction targets.
Completed

In progressIn early stages

Each of these companies is at a different stage of the SBT setting process, with progress shown below across three key milestones:

1 Establishing the required baseline carbon

2 Developing SBTs and decarbonisation plans to deliver

footprint by the SBTi3

on them in the short to mid term

13%

25%

are in early stages

16%

are in early stages

are working on their baseline

28%

47%

have completed Scope 1 and 2 emissions, and are in the processof completing Scope 3 emissions calculations

are in the process of developing theirtargets and plans

44%

28%

have completed a full baseline

have a fully developed target and plan

3 Have set SBTs
Number of relevant
investments% of relevant investments
by invested capitalby number of companies
Commitments for over

Have set SBTs andsubmitted them to SBTi

9

15%

28%

Of which,have approved targets
by SBTi

6

7%

19%

69

thousand tonnes CO2e of baseline
emissions to be reduced in line withthe latest climate science4

1.	Relevant investments that were in our portfolios at the time of setting our portfolio coverage target that are still in the portfolio as at 31 December 2022. Note that
the SBTi currently does not validate and approve SBTs for educational institutions, so three portfolio companies in this sector have been excluded from our update.
2.	These are Europe Corporate, Asia Pacific Corporate, Europe Mid-Market, North America Private Equity, and Infrastructure Equity.
3. Percentages are calculated based on number of companies in the respective stages, and may not add to 100% due to rounding.
4. As per the applicable SBTi requirements for target setting and validation, as of 31 December 2022.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

ESG issues are an important driver of investment
value and source of investment risk. By supporting
responsible and sustainable practices in ourinvestments we can deliver both long-term value
and attractive returns to our clients.
ICG has been a signatory to the UN-backed
Principles for Responsible Investment (PRI)
since 2013, and is an active contributor to arange of industry collaborative initiatives.

Embedding ESG in our investment culture

14

Responsible investing across our asset classes

16

Evaluate

17

Engage19

Report28

Collaborate30

13 | ICGAM.COM

Investing sustainably

Operating purposefully

Further disclosures

Investingsustainably

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

EMBEDDING ESG IN OUR INVESTMENT CULTURE
ICG aims to nurture a responsible business culture throughout its own organisation as well as ininvestments in which it has sufficient influence. This culture is embedded through the developmentof supportive systems and processes. Over 2022, ICG took some significant steps to ensure it iscontinuously embedding responsible investment practices in the business.

ESG-linked compensation for
all ICG portfolio managers

Incorporating ESG into our
New Product Approval process

In 2022, ICG incorporated ESG assessment into the annual
performance appraisals of portfolio managers across the firm.
The aim of this practice is to reinforce alignment and accountability
at the right levels for achieving ESG excellence, while ensuring
we comply with a continued increase in relevant regulatory
requirements. It will also position portfolio managers to lead byexample, ensuring ESG is being appropriately and consistently
considered in their teams’ approaches to investment.

We believe that an enhanced focus on sustainability can be a sourceof competitive advantage. We seek to integrate ESG considerations
into the design of new strategies or funds where their natureallows us to drive better ESG outcomes. This reflects theincreased societal need and client demand for funds with strong
environmental and social characteristics, and those that support thetransition to a net zero economy. Enhanced ESG practices as well
as climate change mitigation and adaptation at a fund level are key
considerations in the launch of new strategies or funds. For new
relevant strategies or funds where we have sufficient influence,
we also seek to align ESG priorities and practices with specific UN
Sustainable Development Goals (UN SDGs) and consider sciencebased GHG emissions reduction targets that support the goals of
the Paris Agreement.

14 | ICGAM.COM

ESG training to be offered to all ICG staff

Better utilising ESG data

Comprehensive online ESG training has been delivered to all
investment executives, the senior management and the Marketing
and Client Relations team every two years for the past six years.
During 2022, ICG has been developing its training programme so
it can be delivered to the wider business. Mandatory training will
incorporate core understanding of ESG at ICG, while extending theopportunity for more advanced specific knowledge-building forrelevant professionals such as investment executives in key topics
that relate to their role. Learning pathways can be built upon as
users expand their learning in priority topics such as climate change,
diversity & inclusion, and governance. The new approach will berolled out in 2023.

Since the start of 2022, ICG has partnered with an experienced
third-party vendor to develop a dedicated web-based ESG data
management platform for the firm. Investment teams can now
run ESG data collection processes and analyse the information
about their portfolios in a time-efficient and consistent way.
The underlying data is a key contributing factor to improving
our ESG disclosures to clients.

Read more
about our ESG reportingon pg. 28

Read more
about the use of our
ESG data platform on pg. 29

Investing sustainably

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Operating purposefully

Further disclosures

EMBEDDING ESG IN OUR INVESTMENT CULTURE CONTINUED
Our responsible investing approach

Co
lla
bo

Evaluatepot
ESG enti-re

ICG Responsible
InvestingEngage

s

r
ne
t
ss e
r
ts or deal pa
to
ity
driv
e sustainabil

e
tic
ac
pr
st

R

Co
s
ntin
ces
uous
pro
t
n
ly enhaencing the investm

15 | ICGAM.COM

driv
e
i
n
du
s
t
r
yb
e

ith
a

Pre-Investment

industry to
rs andpeeithents to id
estm s an entifyvin
sk d opp &al ted ri
orlaw

or asset-speci
tfolio
fic E
r
o
p
SG
n
o
pr
t
r
og
o
re
p
e

ss

s
ses
as itiesntu

Read more
about how we have
implemented these across
our asset classes – pg. 17-30

For each investment strategy, we consider ESG issues at every stage of the investment process – from exclusion, screening and due
diligence to closing, monitoring and eventual exit. The level of our ability to effect change and influence the portfolio company varies
by asset class, strategy and between investments.

cing the investm
ent p
ly enhan
roce
uous
n
i
t
n
ss
o
C

Investment Period

Deal screening, due diligenceand investment decision-making

All strategies

Ongoing portfolio monitoringand engagement– Exclusion List screen– Investment teams engage
regularly with assets and/or GPs– ESG assessment throughstrategy-specific ESG screening– Annual monitoring of ESG
checklist; including a climate risk
matters, e.g. through ESG
assessment, with additional review
surveys and portfolio reviewsfor high-risk exposure deals– ESG findings included ininvestment proposals, as standard– Third-party expert ESG due
Strategies withdiligence typically conducted
greater influence

as standard and incorporates
climate risk assessment

Exit
ENGAGEEVALUATEw
tera

Our Responsible Investing Policy
provides the overarching charter for
our approach to responsible investing
and covers 100% of ICG’s assets
under management. Our approachto responsible investing is focusedaround four key activities: Evaluate,
Engage, Report and Collaborate.

Preparation for exit

– Prepare for exit and visibility
for potential buyers– Raise ESG-related issues to– Conduct sell-side ESG due
portfolio company boards / LPACs
diligence prior to exit
– Implement ESG action plans
and targets– Establish ESG KPIs, including
on climate change and energy,
typically aligned with an SBT– Assess the carbon footprintof portfolios

Investing sustainably

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Operating purposefully

Further disclosuresRESPONSIBLE INVESTING ACROSS OUR ASSET CLASSES
For each investment strategy, we consider ESG topics at every stage of the investment
process. The level of our ability to effect change and influence a portfolio company
or an asset varies by asset class, investment strategy, and between investments.
However, we strive to adopt best practice in our approach across all asset classes.
Our ability to effect change is measured by the successful execution of our investment process

Key documents:
View more
about our Responsible Investing Policy
on our website (last updated June 2022)

ICG asset
class

Total AUM
(30 Sep 2022)

Overview

Key strategies

Structured andPrivate Equity$25.3bn

Providing structured andequity financing solutions
to private companies

European & Asia Pacific Corporate

Strategic Equity

View more
about our Climate Change Policy on our
website (last updated June 2022)
View more
about our UK Stewardship Code Statementof Disclosure, published in March 2022

ICG Enterprise Trust / LP Secondaries

Private Debt

$18.7bn

Providing debt financing
to high-quality corporate
borrowers

Senior Debt Partners

North America Capital Partners

Real Assets$7.7bnProviding financing
solutions to the real estateand infrastructure sectors

Real Estate Debt

Real Estate Equity(including Sale and Leaseback)Infrastructure Equity

Credit16 | ICGAM.COM$16.9bn

Investing in primary andsecondary credit markets

Liquid Credit
CLOs

EVALUATE

ENGAGEREPORTSUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Introduction

Evaluate
For most of our strategies, the best opportunity to fully understand and evaluate the ESG
characteristics of a potential investment and to exert influence is at the time of initial investment.
While the subject, methods, and nature of ESG evaluation vary across asset classes and between investments, ICG investment teams
use the information, tools and processes available to them and deemed suitable for each investment strategy to evaluate:

Risk

Opportunity

Alignment

Identify and assess the mostmaterial ESG risks pertinent toeach investment opportunity,with a view to:

Understand the potential forvalue creation from material
ESG factors, particularly
in situations where ICG has
sufficient influence.

Determine the extent ofalignment with sponsors,
management teams, thirdparty managers and/or otherinvestment counterparties, as
relevant to each investment, on
ESG direction and approach.

a. avoid investments that are
inherently prone to having
significant adverse impacts onsociety and the environment; and/or with significant governance
failures/shortcomings; orb. ensure that, if of acceptable
overall risk level, these risks canbe feasibly mitigated and/or
addressed post investment.

Spotlight: Scenario-based climate risk assessment for corporate deals
Every two years, ICG conducts a formal
assessment of exposure to climaterelated risks across its portfolios withsupport from a third-party climate
consultancy. We assess the impact
of climate-related drivers associatedwith both changing climatic conditions(physical risks) and the transition to a
low carbon economy related to policy,
regulatory, market, and technology
changes (transition risk).

17 | ICGAM.COM

In Q1 2022, we assessed approximately
900 portfolio companies across ourfour asset classes covering almost 90%
of our AUM as at 31 December 2021,
using our proprietary Climate Risk
Assessment Tool to identify companies
with potentially heightened exposure toclimate-related risk. With support fromthe third-party climate advisors, we thenconducted a scenario-based analysis ofthese investments under the frameworkprovided by the Network for Greening
the Financial System.

Following this analysis, we are working
with the advisors to enhance our Climate
Risk Assessment Tool to incorporate
sector-based transition risk scenario
analysis. When rolled out in 2023, thisimprovement will provide investment
teams with more nuanced climate risk
insights as part of the ESG evaluation
process for new deals.
View more
for further details on our latest
TCFD disclosures

Operating purposefully

Further disclosures

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

Evaluate
Over the course of 2022, ICG introduced new ESG tools andresources and enhanced existing ones to better equip investment
teams with the capabilities to evaluate investment opportunities.

Private Debt and Credit– Rolled out ICG’s proprietary ESG risk rating across ICG Private Debt and Credit; to not only
evaluate ESG-related risks for each potential investment but also to re-evaluate existing holdings
and enable an assessment of complete portfolios as a whole.
– In 2022, our Private Debt and Credit investment teams carried out more than 400 evaluations
utilising the enhanced ESG Screening Checklist to produce a two-dimensional ESG risk rating.

2022 developments
Across all asset classes
ICG updated its Good Governance Policy in line with the requirements of EU SFDR.
This provides more clarity and consistency as well as asset class-specific approaches
to assessing the governance practices of relevant counterparties for new deals andduring the lifecycle of investments.

Structured and Private Equity– Introduced an ESG Screening Checklist specifically designed to assist the evaluationof portfolios considered for investment by the ICG LP Secondaries strategy.
– Conducted, as standard, climate risk and maturity assessment, D&I diagnostics,
and cyber risk assessment as part of due diligence carried out on new direct
corporate investment opportunities, where ICG has sufficient influence.
– Cyber risk assessments formalised as standard part of the due-diligenceprocess for new investment opportunities in our European Corporate andEurope Mid-Market strategies.

Real Assets

ESG risk distribution of the portfolios of select flagship liquid credit funds1
Inherent sector ESG risk
The inherent sector ESG risk is measured on a 6-grade scale of A (Very Low) to F (Very High);and captures the inherent level of risk exposure associated with the primary sector of operationof the company being evaluated.
A: 2%

B: 37%

C: 25%

D: 23%

0%

E: 12%

F: 2%

1: 11%

0%65
investment opportunities were not approved due to
ESG concerns, such as reputation risks, climate risk,
corporate governance and bribery and corruption
concerns; across key strategies in our Structured andPrivate Equity, Private Debt, and Credit asset classes.

100%

Company-specific ESG risk
The company-specific ESG risk is measured on a 6-grade scale of 1 (Very Low) to 6 (Very High);
and represents a composite rating based on four risk components, each with a weighting as
indicated: A) Risks related to countries of operations (20%); B) Reputational risk (20%); C)
Climate risk (20%); and D) level of ESG maturity and transparency (40%).

– Developed a tailored ESG Screening Checklist for real estate investments to fully
capture and assess the nuances and characteristics of this asset class. The checklist
includes a dedicated evaluation of location-based physical climate risk and transition
climate risk. We will roll out the checklist to be used to evaluate new deals startingin 2023.

ESG considerations are an integral part of making
investment decisions and, as such, there are deals wedecline or assets we exclude because they do not meet
ICG’s robust ESG standards. In the 12 months prior to
30 September 2022, more than

2: 27%

3: 49%

5: 0%
4: 12% 6: 0%

100%

Next steps:– Incorporate a climate scenario-based transition risk
analysis into the Climate Risk Assessment Tool tosupport the pre-investment evaluation of corporate
deals (see pg. 17).
– Continue to enhance our approach to assessing Good
Governance practices with regard to our investments.
– Over time, update existing tools and processes
to incorporate an appropriate level of evaluationof emerging ESG themes, such as nature andbiodiversity and human rights (see pg. 10).

1.	Portfolios consist of 265 unique issuers as at 30 September 2022, across six liquid credit funds managed by ICG. Percentages are calculated based on number of issuers in the respective portfolios,
and may not add to 100% due to rounding.
18 | ICGAM.COM

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Introduction

EngageSTRONG ESG PERFORMANCE ACROSS OUR EUROPEAN
AND ASIA PACIFIC CORPORATE PORTFOLIOSWe recognise the commercial opportunity in engaging with portfolio companies
to drive sustainability performance.
Asset class

Strategies in focus

STRUCTURED AND
PRIVATE EQUITY

European and Asia Pacific Corporate

Total asset class AUM

Strategies overview
Providing structured and equity financing solutions to principally
mid-market private companies.

$25.3bn1
We know that every portfolio company isdifferent, so we take the time to understandtheir business model, exposure to ESG
risks and opportunities, key stakeholders,
and their actual and potential positive
and negative impacts on society and/or
the environment. These insights inform
our engagement with management teams
and help us identify the areas where
we can support them in achieving theirsustainability ambitions and building
lasting value across our portfolios.

For any new investment where wehave sufficient influence, we conduct a
structured ESG onboarding process toalign with management teams on ESG
governance, key ESG areas of focus forthe business, and KPIs and progress
monitoring. Typically, ESG is a regular
agenda item at Board meetings, and wereview ESG progress and performance withall portfolio companies at least annually.

While topics of engagement vary foreach portfolio company, we focus ourengagement on the following three topics:
Climate change
Diversity and inclusion
Cyber resilience

Read more
about our Areas of focus in 2022
on pg. 9

1. As at 30 September 2022.
19 | ICGAM.COM

Operating purposefully

Further disclosures

Investing sustainably

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Operating purposefully

Further disclosures

EngageENGAGESTRONG ESG PERFORMANCE ACROSS OUR EUROPEAN AND ASIA
PACIFIC CORPORATE PORTFOLIOS CONTINUED
Climate change

Diversity and inclusion
Progress and impacts

Key aims and drivers– Reduce carbon intensity of
portfolio companies– Set ambitious GHG emissions
reduction targets in line with a
1.5oC global warming scenario– Sustainable business growth

Science-based targets

64%

78%

7 (out of 9 across ICG)

of portfolio companies
have assigned board ormanagement responsibility
for climate change-relatedrisks and opportunitiesof portfolio companies haveset or are in the process ofestablishing climate changeor energy-related objectives
and targets

relevant2 portfolio companies
have set SBT in the last 12 months,
with 4 being approved by the
SBTi and 3 awaiting approval(2021: 61%, 2020: 42%)(2021: 67%, 2020: 55%)

1

1

80%1

76%1

13

of portfolio companies haveassessed, or began assessing, thebusiness risks and opportunities
associated with climate changeof portfolio companies haveassessed their carbon footprint

other relevant portfolio
companies have started
developing their SBTs

(2021: 61%, 2020: 32%)

Progress and impacts
Key aims and drivers– Promote a more inclusive andequitable working environmentthat supports attracting andretaining best talent– Improve diversity at senior
management and board level– Sustainable business growth

2

75%

76%1

of portfolio companies in
European Corporate Fund
VIII, the latest fund in thestrategy, have improved
gender diversity at board
level since ICG’s investmentof portfolio companies
have a D&I policy in place

87%1

76%1

of portfolio companies are
implementing initiatives
or targets to improve D&I

of portfolio companies
run regular employee
engagement surveys(2021: 64%, 2020: 48%)(2021: 69%, 2020: 68%)(2021: 69%, 2020: 55%)(2021: 58%, 2020: 39%)

Next steps
Encourage the exchange of best practices,innovation and ideas among portfolio companies.

Next steps
Continue to drive decarbonisation across the portfolios andsupport the setting of SBTs by relevant portfolio companies.

1.	Source: ICG’s Annual ESGs survey of portfolio companies across European and Asia Pacific Corporate.
2.	Relevant companies are those where ICG has sufficient influence (i.e. at least 25% of fully diluted shares and a board seat).

20 | ICGAM.COM

Encourage the exchange of bestpractices, innovation and ideas
among portfolio companies.

ICG will continue to promote andencourage greater diversity at
strategic decision-making levels.

Investing sustainably

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Operating purposefully

Further disclosures

EngageSTRONG ESG PERFORMANCE ACROSS OUR EUROPEAN AND ASIA
PACIFIC CORPORATE PORTFOLIOS CONTINUED
Cyber resilience

Key aims and drivers– Ensure appropriate
cybersecurity governance,
tools and processes – in linewith best practice– Enhance transparency onrisk detection– Encourage cyber training for
portfolio company employees– Continuously improve cyber
resilience in the context ofchanging threat landscape2022 Annual ESG Survey
Progress and impacts1(across the European Corporate portfolio)

100%

100%

Cyber due diligence completed
on all new investments in
European Corporate Fund VIII.
No red flags were identified
and portfolio companies took
mitigating actions to address
key potential risks.

of portfolio companies, where
we have sufficient influence,
have discussed cyber risk atboard level at least once inthe last 12 months.

94%

Incidence
responseof portfolio companies, where
we have sufficient influence,
have completed or launched
an internal audit of cybercapabilities. This includes
having a clear plan ofremedial actions.

retainer established toensure immediate support in
the event of a cyber attack.

Next steps
Encourage the exchange of bestpractices, innovation and ideas
among portfolio companies,
where appropriate.

As cyber-attacks become more frequentand sophisticated, full immunity is very
difficult to achieve so we will continue
to reinforce our efforts and monitor
cyber risks and capabilities.

1. Figures as at 31 December 2022. Data excludes any sponsor-led deals and recent exits.
21 | ICGAM.COM

ICG has been conducting its Annual ESG
Survey for portfolio companies across theEuropean and Asia Pacific Corporate portfolios
since 2015, seeking to engage with portfolio
companies to understand the ways in which
they are managing ESG issues and areas thatcan be further improved.
The Annual ESGs survey assesses practices
with regards to ESG governance and oversight,
compliance with ESG-related laws andregulations, climate change, and diversity,
equity and inclusion. In 2022, the survey
was further enhanced to include performance
metrics drawn from leading industry frameworks

such as the Principal Adverse Impact metrics
under the EU Sustainable Finance Disclosure
Regulation (SFDR), the ESG Data Convergence
Initiative, the Task Force on Climate-related
Financial Disclosures (TCFD), the GRI standards,
and SASB standards.
In 2022, a total of 45 companies across theEuropean and Asia Pacific Corporate portfolios
took part in the survey (36 in 2021, 32 in 2020),
maintaining a 100% response rate.

45
portfolio companies took
part in the 2022 survey

100%
response rate

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

EngageALIGNING ESG OBJECTIVES WITH GP PARTNERS
We believe that GP partners that are better able to manage ESG risks and capitaliseon ESG opportunities across their portfolio may create more lasting value for investors
and the underlying assets.
Asset class

Strategy in focus

STRUCTURED AND
PRIVATE EQUITY

Strategic Equity

Total asset class AUM

Strategy overview
Strategic Equity invests in bespoke sponsor-led liquidity transactions(termed “GP-Led Transactions”), providing equity financing toestablished private equity firms to purchase either a single, highperforming asset or a portfolio of assets from their existing fund(s).

$25.3bn1
Our GP partners vary in terms of size, scale,geographical or sector focus, and ESG
maturity. That is why we carefully evaluate
the ESG credentials of potential deals, bothof GP partners and underlying assets, andmake engagement on ESG matters a crucialcomponent of ICG’s approach.
Ongoing ESG engagement and monitoringis achieved through a combination ofboard seats, information rights, active
engagement with the GP/sponsor on
material ESG issues and the Annual GPs
Survey and follow up dialogues to discuss
progress. The Strategic Equity team, withsupport from ICG’s Sustainability & ESG
team, targets engagement with GP partners
to support them in further enhancing theirapproach to ESG integration by sharing
our experience and networks, as well as
resources for portfolio monitoring andreporting. For the first time in 2022, we
utilised our corporate Annual ESGs survey(see pg. 21) to assess the ESG practicesof underlying assets, and we plan toshare key findings with our GP partners
to support further ESG improvements.

Continued focus on aligning with GP partners on:
ESG governance

Climate change

100%

89%

44%

33%

of managers have an ESG
Policy which is broadlyaligned with ICG’s RI Policyof managers have dedicated
ESG resource

have a formalised approachto managing climate-relatedrisks and opportunities

already monitor the
carbon footprint of
portfolio companies(2021: 40%)(2021: 30%)(2021: 100%)(2021: 60%)

89%

100%

are UN PRI signatories

use board influence toengage on ESG matters(2021: 79%)

(2021: 100%)
Source: ICG Annual GP survey. In 2022 all 9 GP partners in Strategic
Equity IV responded to the survey. In 2021, 10 GP partners in Strategic
Equity III and IV responded.
22 | ICGAM.COM

Diversity and inclusion

100% NEW19%

of GP partners state thatthey actively support D&I
in their firms

female investment
professionals on averageamong GP partners(2021: n/a)

(2021: 14%)

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Introduction

Operating purposefully

Further disclosures

EngageCONTINUED ESG PROGRESS ACROSS OUR DIRECT LENDING PORTFOLIOSIn our Direct Lending portfolios, the success of our engagement with borrowers depends on the strength of our relationshipwith their private equity shareholders and the continuous alignment of our overarching ESG objectives.
The focus of engagement varies fromdeal to deal but we typically prioritise thefollowing three themes as we believe they
have universal importance for the lasting
success of any business: ESG governance,
Climate change, and Diversity and inclusion.

Asset class

Strategy in focus

PRIVATE DEBT

Senior Debt Partners

Total asset class AUM

Strategy overview
Providing senior debt financing to high-quality corporate borrowers.

$18.7bn1

Engagement in our Direct Lending portfolios is vital to understand and account for the ESG risks and opportunities pertinent to
our investments. We engage with borrowers and monitor the ESG performance of investments through a two-pronged approach:01

02

Deal teams maintain ongoing
dialogue with management
and/or PE sponsors,which covers material ESG
developments.

Our Annual ESG Survey enables
us to assess more holistically
how ESG matters are managed
by borrowers in our portfolios
and the progress they haveachieved over time.

1. As at 30 September 2022.
23 | ICGAM.COM

01

02

We noted continued progress among
the borrowers in our Direct Lending
portfolios, as demonstrated by responses
to our Annual ESG Survey (see pg. 21).
37 borrowers responded to the survey in2022, up from 31 in 2021, and 26 in 2020.
Among the borrowers who took part:

ESG governance

Climate change

Diversity and inclusion

87%

57%

77%

have implemented or
are implementing asustainability policy

have begun assessing
exposure to climate risks& opportunities

have implemented or aredeveloping initiatives ortargets to improve diversity(2021: 65%, 2020: 44%)(2021: 35%, 2020: 28%)(2021: 50%, 2020: 33%)

62%

81%

89%

have set or are in theprocess of developing
ESG KPIs and targets

have initiatives to reduce
GHG emissions

run regular employee
engagement surveys(2021: 69%, 2020: 39%)(2021: 81%, 2020: 72%)(2021: 38%, 2020: 33%)

Investing sustainably

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Operating purposefully

Further disclosures

EngageFINANCING THE GROWTH OF SUSTAINABLE REAL ASSETS
We recognise promising investment opportunities in growing sustainable real assets, and insupporting the transition of real estate and infrastructure assets to more sustainable models.
Real Estate

Asset class

Asset class

Strategies in focus

REAL ASSETS

European Real Estate Debt, Sale and Leaseback,and Infrastructure Equity

Total asset class AUM$7.7bn1
Investments in real assets, such ascommercial real estate, housingdevelopments, renewable energy and otherinfrastructure delivering core services,can play an important role in supporting
global economic growth and enhancing
social cohesion. The Organisation for
Economic Co-operation and Development(OECD) estimates2 that $6.9 trillion peryear is needed up to 2050 for investment
in sustainable and resilient infrastructure toachieve the UN Sustainable Development
Goals by 2030 and net zero emissions
by 2050.

To capitalise on this growing investment
opportunity, ICG has launched a numberof sustainably-themed products investingin real assets. These products havesustainability frameworks designed to alignwith specific UN SDGs, and all incorporate
climate-focused SDGs including SDG 7(Clean Energy) and 13 (Climate Action);and deliver tangible, targeted improvementsin the sustainability performance of assets
as part of the asset management plan.

As at 30 September 2022,
these sustainably-themed
products constitute nearly
half (48%) of total AUM
in real assets, compared
to 34% a year earlier;and a significant growth
opportunity for ICG.

1. As at 30 September 2022.
2.	Source: UNEP, accessed on 29 November 2022, https://www.unep.org/explore-topics/green-economy/what-we-do/sustainable-infrastructure-investment

24 | ICGAM.COM

Strategy

European Real Estate Debt

Strategy
overview

Pan-European real estatedebt strategy with a distinctive
approach to investing in self
originated, predominantly
first mortgage investments

Targets mission-critical,
commercial real estate assets
across the UK and Europe

Seeks to acquire a diversified
sustainable portfolio of Core+
mid-market infrastructure assets
in Europe, with a focus on
downside protection

Sustainability
approachFinancial incentives for
improvements, andtargeted engagement

Allocated capital forsustainability improvements,
and targeted engagement

Incorporated into active
asset management

Sustainability
focus themes– Climate change– Natural resource use– Climate change– Natural resource use– Climate change– Natural resource use– Diversity and inclusion– Human capital management

Strategies overview
Providing financing solutions in the real estate and infrastructure
sectors, with focus predominantly on the European mid-market.

Towards a more sustainable real economy

Infrastructure

Targeted UN
SDGs

Sale andLeasebackInfrastructure
EquitySUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Introduction

Operating purposefully

Further disclosures

EngageFINANCING THE GROWTH OF SUSTAINABLE REAL ASSETSCONTINUED
Creating innovative opportunities in sustainable real estate debt investments

European Real Estate Debt
The strategy provides financial incentives,in the form of margin ratchets, to borrowers
seeking to improve the sustainability ofexisting and new commercial real estate.
This is achieved through a dedicated Green
Loan Framework (GLF) that ICG designed
in alignment with current best practice,including the recommendations laid out inthe LMA Green Loan Principles and the EU
Taxonomy. The aim of is for the majority ofcommitted capital to qualify under the GLF
by demonstrating, over time, a high standardof performance across a combination ofareas (see graph).

n
ee
r
G

wellbeing building c
ert
ific

Sustainable
travelati
onsEnergyefficiency

ICG Green
Loan
Framework80%

A mezzanine facility to finance an office campus in Berlinwith clear commitments to reduce energy consumption
by 57% and corresponding carbon emissions by 58%, inline with the Goals of the Paris Agreement.

Water
efficiency

im
Cl

at
em

igr
a ti
on
in

he
line w
ith the Goals of t

m
ee
r
g
sA
i
r
Pa

1	The Primary Goal of the Paris Agreement is defined as “limiting global warming to well below 2, preferably to 1.5 degrees Celsius, compared to pre-industrial levels.” https://unfccc.int/process-andmeetings/the-paris-agreement/the-paris-agreement2	Committed capital based on deals in the portfolio as at 30 September 2022. Green loan qualification status accurate as at 1 December 2022, based on independent verification by a third-party advisor.
3	In line with the UK Net Zero Carbon Buildings Standard – https://www.nzcbuildings.co.uk/

25 | ICGAM.COM

Supporting the borrower’s commitment to refurbish acentral London office with the aim to deliver a Net Zero
Carbon3 building, which among other things will include
pursuing an EPC A rating and replacing gas boilers with
an electric air source heat pump system. The property willseek an Excellent BREEAM certification in demonstrationof its holistic approach to sustainability.

ent1

Responsible
use of materials
and wastemanagement

To date,of committed capital has
been in green loans2 toprojects that have madeclear commitments tosustainability.

/or
an d

Since the inception of the strategy, 80% of committed capital has been in green loans2 to projects that have madeclear commitments to sustainability. The investment team has actively engaged with borrowers and sponsors,
typically at the time of investment, to identify value-add opportunities for improvement. Bellow are some examplesof green loans provided and our engagement efforts.

Supporting the development of a premium hotel in thesouth of France working with a sponsor that has a long-term
commitment to operate the property in line with the Goals of
the Paris Agreement, including switching over time to 100%
renewable energy supply and delivering top-tier energy
efficiency performance when benchmarked against similar
properties, among other sustainability characteristics.

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Introduction

Operating purposefully

Further disclosures

EngageFINANCING THE GROWTH OF SUSTAINABLE REAL ASSETSCONTINUED
Sale and Leaseback
ICG Sale and Leaseback has adopted
a distinctive approach to enhancing
the sustainability of the underlying
assets in its portfolios.
The Sale and Leaseback team isworking collaboratively with tenants ofmission-critical real estate to diagnosecurrent performance and to drive
improvements that promote greater
energy security and cost predictability,
reduction of greenhouse gas emissions,better utilisation of energy and water
resources, and efficient waste
management programmes.
As part of its approach Sale andLeaseback is able to re-invest up to 2%of its committed capital to enhance thesustainability of the underlying assets in
its portfolios. Since launching the strategy
in 2019, the team has engaged with the
majority of tenants and directly contributed
to the financing – or facilitated third-party,
innovative financing solutions – for a rangeof tangible improvements that have a
combination of environmental, economic,
and social benefits.

Some recent examples of such engagements include:
ICG's Sale and Leaseback team worked closelywith the developer and contractors of a logistics
park in the Midlands, UK, on one of the largest net
zero-ready developments in the UK, benefitingfrom a BREEAM Excellent rating. High levels ofsustainability and safety standards were adopted
during construction, including recycling almost all
waste, on-site concrete batching, and using 100%
green diesel for deliveries, which alone resulted
in over 300 tCO2e saved to date.
ICG worked with an energy solutions tenantin Austria to facilitate the construction of anenergy transfer station which deploys innovativetechnologies to redistribute surplus energy fromthat tenant’s operations to other members of
the community, including heating the local public
outdoor swimming pool.

The Sale and Leaseback team has partnered withrenewable technology solution providers to facilitate
the installation of solar panels on the rooftops ofsuitable assets in the portfolio. Through energy-asa-service arrangements, tenants benefit from greater
energy supply security at competitive prices withlimited impact on the environment and in supportof their own corporate climate commitments.

Below are examples of the positive impacts4 of the portfolio in 2021 and 2022:

455 GWhInfrastructure Equityof renewable energy generated (2020: 277 GWh), contributing
to the growing electricity demand around the world

The strategy has adopted a“green generalist” approach,including operational value
creation with a sustainability focus.
Through its asset management efforts,
ICG operates a tailored Infrastructure
Sustainability Framework, drawing on
the Global Impact Investing Network’s
IRIS+ taxonomy, to identify, assess,monitor and, where possible, quantify
the direct contribution of portfolio
companies’ core activities to relevant
SDGs. Under the Infrastructure
Sustainability Framework, portfolio
company engagement – including
KPIs setting (where ICG has accessto and influence over management)– prioritises four themes: Climatechange, Natural resource use, Human
capital management, and Diversity
and inclusion, alongside othermaterial company-specific ESG risks
and opportunities.

1,703 MW5of installed renewable energy generating capacity (2020: 221 MW)
contributing to the low carbon energy transition on 5 continents

669

MW

MW

WESTERNEUROPE26 | ICGAM.COM

CENTRALEUROPENORTHAMERICA

341
MW

53

13

MW
ASIA
PACIFICMWAFRICA

SOUTH
AMERICA

Solar PV

Wind

Hydro

HybridBiomass

Biogas4,300 km

30 million m3of owned fibre network deployed andoperated (2020: 4,075 km) — 25% in
rural areas (2020: 22%), supporting theconnectivity of over 112,000 households
and businesses (2020: 80,000)

of water saved (2020: 27 million m3)
across 1.7 million households throughsmart metering (2020: 1.6 million)

215
4	Source: ICG, figures aggregated from data reported by individual assets in the portfolio for the specified period.
5 Installed capacity across all assets in the Infrastructure Equity portfolio as at 30 September 2022.

319

MW

309

net jobs created(2020: 135)

Providing decent jobs to over

1,330

(2020: 1,100) people,

36%of whom are female (2020: 35%)SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

EngageGREATER FOCUS ON ENGAGEMENT ACROSS OUR FLAGSHIP CREDIT FUNDS
In order to play a more active role in encouraging better ESG practices, ICG has increased our focus on engaging
directly with issuers in our liquid credit funds, in addition to collaborating with other stakeholders.
Asset class

Strategies in focus

Our requests for ESG information from issuers2

CREDIT

Syndicated Loans, Multi-Asset Credit, and US andEurope CLOs

Environment

SocialGovernance

243

166

207

issuers were engaged
on Environmental topics,
such as climate change,
natural resource use, andenvironmental compliance.

issuers were engaged on Social
topics, such as health andsafety, workforce diversity andinclusion, and customer welfare.

issuers were engaged on
Governance topics, suchas board diversity, businessconduct, and exposure tohigh-risk countries.

Total asset class AUM$16.9bn1
With over 500 issuers across our credit
portfolios, primarily sub-investment gradeprivate issuers in Europe and North America,
we recognise the need to be targeted in our
engagement efforts. Given the nature of ourcredit strategies, we may engage directlywith management teams or collaboratively
with other lenders as part of a syndicate.

Strategies overview
Investing in primary and secondary credit markets, with focus on
sub-investment grade credit in Europe and the US. We invest in
liquid (tradable) senior secured loans and high yield bonds as partof a syndicate of lenders or investors, as well as structured credit.

In the 12 months to 30 September 2022,
ICG credit analysts engaged with morethan 300 issuers across North America
and Europe to seek more information
and/or improvements on relevant ESG
topics. As comprehensive ESG disclosures
are still nascent among sub-investment
grade private issuers, our key focusof engagement in many cases was on
improving transparency on ESG matters,
including disclosure of ESG performanceand GHG emissions.

1. As at 30 September 2022.
2.	For the 12 months to 30 September 2022. An issuer may be engaged on more than one ESG topic.

27 | ICGAM.COM

It is encouraging to see that 48% of
issuers in six of our market value credit
portfolios (as at 30 September 2022)
measure and report GHG emissions –a significant increase from only 30%
of issuers as at 31 December 2021.

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

ReportIMPROVING TRANSPARENCY ON ESG MATTERS
Why does it matter?
Better-informed investment
decisions
We believe that transparency on material
ESG-related risks and opportunities,
such as those posed by climate change, is
important to fully consider the risk-return
characteristics of investments and as suchcan better inform decision-making ofinvestors. That is why we have supported
the TCFD since 2019, and in 2022 formally
expressed our support for the Taskforce
on Nature-related Financial Disclosures(TNFD) by becoming a member of the
TNFD Forum.

The role of regulation –standardisation
Financial market regulators around theworld have understood the importance ofstandardised, minimum ESG disclosuresfor preventing greenwashing. The EU
Sustainable Finance Disclosure Regulation(SFDR), which came into effect inMarch 2021, is a prime example of sucha regulation in our industry. As the US
Securities Exchange Commission, the UK
Financial Conduct Authority and otherregulators globally are contemplating
ESG disclosure and/or labelling regimes
in their markets, we urge for suitableharmonisation and proportionate andpractical implementation in private markets,to ensure a truly levelled playing field.
To support this, in 2022, we collaborated
with peers at Initiative Climate Internationaland BVCA to collectively respond to
the UK FCA consultations on Climate
Disclosures for Asset Managers (finalised)
and Sustainable Disclosure Regulation(pending); and with fellow membersof Invest Europe to respond to further
consultations by the European Commission
on the implementation of SFDR.

Read more
about our participation incollaborative initiatives on pg. 30

Our disclosures
We seek to provide regular updates to our clients and other stakeholders on how ESG considerations are integrated into our investment decisions and processes;
and the outcomes we have achieved. We do this at firm level and for individual funds, depending on the purpose of disclosure and nature of underlying information.

ICG-level disclosures
As a listed company and a regulated asset manager, ICG seeks to provide timely and detailed reporting on
relevant ESG matters through its own annual disclosures and by participating in voluntary assessments.
TCFD disclosures

Sustainability & People Reports

UK FCA Stewardship Code

Recognising the importance of climate
disclosures, ICG has been reporting voluntarily
against the TCFD recommendations since 2019.
Building on this, as part of its Annual Report for
FY22, ICG plc produced its first mandatory climate
disclosures in line with the recommendationsof the TCFD to respond to the requirements forpremium listed companies in the UK.

Our first firm-level ESG report was
produced in 2014, and the focus, breadthand depth of this report have considerably
expanded ever since. For its 2021
Sustainability & People Report, ICG further
enhanced its approach by drawing on
relevant GRI & SASB standards.

ICG was admitted as a signatory to the
UK FCA Stewardship Code in March 2022 andhas an obligation to provide an annual updateon progress on its stewardship activities.

View morein our TCFD disclosures

28 | ICGAM.COM

View morein our Sustainability & People Reports

View morein our most recent disclosure

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Introduction

Operating purposefully

Further disclosures

ReportIMPROVING TRANSPARENCY ON ESG MATTERS CONTINUED
Data integration for ESG assessment and reporting

Fund-level disclosures
Responding to key regulatory
developments
The EU Sustainable Finance Disclosure
Regulation has been one of the mostsubstantive disclosure regimes thatcovers our investment activities. Since
March 2021, for each fund in scope of
the SFDR, we have prepared and provided
to investors:– pre-contractual disclosures, specifying
the promoted environmental and/or
social characteristics or the pursued
sustainable objectives by each fund,as relevant and applicable.
– periodic disclosures, communicating
the extent of attainment of thepromoted environmental and/or social
characteristics or pursued sustainableobjectives by each fund, as relevant
and applicable.

Promoting best practice, beyond regulation
In 2022, after listening to ourclients’ needs, and exploring
best practices from peers,
we developed a harmonised,
modular approach to fundlevel ESG reporting across thefirm. This approach was first
implemented to one Direct
Lending fund (Senior Debt
Partners 4) and select liquid
credit funds. All of these reports
incorporated a presentation of
ESG Risk Ratings distribution
across the portfolio, based on
ICG’s proprietary methodology
which we rolled out across ourPrivate Debt, and Credit asset
classes at the end of 2021
(see pg. 17-18).

We also continued to enhancethe dedicated fund-level ESG
reporting to investors in our
European Corporate funds(first issued in 2019) andInfrastructure Equity fund(first issued in 2021).
In the past year, we also
incorporated the TCFDrecommended portfolio climate
metrics as standard in our fundlevel ESG reporting. Disclosureof greenhouse gas emissions
data by private companies isstill nascent, so for any gaps
in actual data we utilise proxy
data modelled by a reputable
external data provider.

At the start of 2022, ICG began implementing a dedicated web-based ESG data management solution to enable more efficient datacollection, analysis and reporting for our portfolios, in line with ICG’s wider efforts to build digital resilience across the firm.

Evaluate

Engage500+

1ReportData collected from

Plan to roll out ESG reporting
for active funds in100+ 15+ 2023
1

1

ESG Screening Checklists
completed by deal teams

companies and

GPs

Firm-wide ESG data management platform99%
of raised capital in scope of
SFDR, since March 2021, hasbeen in products that promote
environmental and/or social
characteristics (Article 8)

Datacollection

Performancemonitoring

1 Since the platform was launched at the start of 2022.

29 | ICGAM.COM

Analytics

Internal
validation

ReportingIntroduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

Collaborate
COLLABORATING TO STRENGTHEN THE INDUSTRY
ICG recognises that, in pursuing the best interests of our clients, we havea responsibility to collaborate and work closely with our peers and otherstakeholder groups.
We are committed to working with others operating in the space of responsible investing, in order to advance
best practice and drive consistency in shared challenges such as data consistency, measurement frameworks,
and reporting. We also recognise the value of learning from industry experts and thought leaders, in order toleverage that knowledge in our own ESG approaches.

ICG has been focused on 3 key areas:

Driving better data,
particularly climate data

01

02
Supporting
standardisation
within the industry
across asset classes

03
Promoting efficientand proportionate
implementation of
ESG regulations

2022 working groups participation– Active member of the Initiative Climat
International (iCI) – co-chaired theCarbon Footprinting Working Group –see spotlight for further details. ICG also
cofounded the Private Credit Working
Group and sits on the Net Zero, andRegulatory working groups.
– Contributing to industry advancement
through a number of other collaborationgroups: PRI Investors Corporate
Reporting Reference, Invest Europe
ESG standards, PRI/LSTA/ACC – ESG
Integrated Disclosure Initiative.
– Member of the TNFD Forum.
– Regularly contributes to the BVCA and
Invest Europe regulatory working groups.

Industry initiatives

Spotlight: Towards harmonised GHG accounting andreporting in private equity – an iCI sector guidancePrivate market investors are increasingly being called upon to set
ambitious climate commitments. Regulators, investors, lenders,and other stakeholders alike, are demanding GHG reporting against
consistent and comparable climate metrics.
Against this backdrop of rising transparency requests, the iCI members
saw an opportunity to develop a specific guidance to private equity
investors. As co-chair of the working group tasked with developing
this guidance, ICG was proud to spearhead this effort, and bring our
experience to bear in providing investors and their portfolio companies
consistent guidance on:

1. Carbon footprinting

2. Financed emissions

Calculating Scope 1, Scope 2
and Scope 3 emissions.

Attributing GHG emissions
from portfolios to GPs andLimited Partners (LPs).

3. Fund reporting

4. Target setting

Aggregating emissions at
the fund level and reportingto stakeholders.

Conducting portfolio analysis
with a view to set targets that
support the transition to a net
zero economy.

View more
The guidance is available here and was developed inpartnership with leading sustainability consultants – ERM

30 | ICGAM.COM

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

How we operate matters as much as what we do.
We are a long-term business that manages capitalon behalf of our clients, looks to generate attractive
returns for our shareholders, and seeks to have apositive impact on our broad range of stakeholders,
including our employees.
We do this by focusing on the hiring, development andinclusion of our people, as well as by ensuring strong
governance policies are in place.

Our people & culture32

Our communities

36

Our operations

38

31 | ICGAM.COM

Investing sustainably

Operating purposefully

Further disclosures

Operatingpurposefully

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Operating purposefully

Investing sustainably

Further disclosures

OUR PEOPLE & CULTURE
I am excited for the part we will
be able to play in the coming
years to help ensure thatour people are contributing
not only to the continued
success of ICG, but also to thecommunities in which we live
and work.
Antje Hensel-RothChief People andExternal Affairs Officer, ICG
Successfully hiring and developing ourpeople is key to our growth, as we seek
to maintain and enhance our culture as
ICG develops.
We have continued to make strategic hires
across the organisation to ensure we havethe breadth and depth of expertise to
execute on the long-term opportunities
ahead. We have welcomed a number ofsenior hires within the organisation acrossour investment, ESG and Sustainability, andmarketing and client relations teams. These
are important hires, helping to future-proof
ICG as we continue to market and invest alarger range of products to a growing andincreasingly complex set of clients.
The number of Group permanent employees
at 30 September 2022 was 575 and over thelast five years our employee base has grown
at a CAGR of 14%.

Watch
a video about the passion, energy
and the quality of our people
32 | ICGAM.COM

Our people initiatives focus on four key areas
Attract

Retain– High level of personal impact andbusiness building– Wide-ranging opportunities forcareer development– Inclusive culture at the core andthroughout the firm

Develop– Comprehensive career development– Market-leading, holistic benefits– Engagement and opportunity tocontribute across the firm

– Dedicated Learning & Development
programmes at all levels– Mentoring and Employee Networks– Development of teams and individuals
a core KPI for leaders

As we welcome new colleagues to the firm, it
is vital that we ensure they integrate quickly
and are able to add to our effectivenessand culture. During the year we continued
to evolve our induction programmes for
new joiners at all levels, ensuring they geta holistic view of ICG and are rapidly able
to build their internal networks.
Being able to bring one’s full self to work
is a core part of having an open working
environment, and we have further advanced
our employee-led networks during the year,
including ensuring that employees acrossall our offices globally are able to actively
participate. We have also reviewed ourpolicies, including around family building
and care leave, to ensure that employees areable to balance their work and family lives.
Finally, our charitable efforts have beensignificantly enhanced in the year, witha targeted approach to support social
mobility and early career development,in line with ICG’s broader values.

Diversity and inclusion

Employee development

Wellbeing and support

Engagement and voice

Cultivating a diversity of perspectives,
improving our teams’ performance

Helping our people reach theirfull potential and building thenext generation of talent

Supporting the physical andmental wellbeing of our employees,
their families and dependants

Effective communication tobuild and maintain engagement

Read moreon pg. 34 of this report

Read moreon pg. 35 of this report

Our values
Read more
about our values on pg. 7 of this report

Read moreon pg. 35 of this report

Read moreon pg. 35 of this reportIntroduction

SUSTAINABILITY & PEOPLE REPORT 2022

Operating purposefully

Investing sustainably

Further disclosures

OUR PEOPLE IN NUMBERS
Our people are fundamental to every part of our success. As we continue to grow,we ensure we have the right breadth and depth of expertise across the firm, working
in close collaboration and helping to drive each other forward.
Group permanent employees
Grow AUM

1

Gender4

49%

Investment professionals

1

re
nd
ea
Manag

ali
se

40%

WHAT WE DO
Inv
es t

3

(H1 2023)575

3

Corporate and Business Services1

1

11%

2

2

3

Marketing and client relations

Board
(11)

Male – 55%
Female – 45%

New hires(134)

Male – 61%
Female – 39%

Workforce breakdown4

336

FY 2019

1. Includes finance, legal, regulatory compliance, operations, Information Technology and other corporate functions.

33 | ICGAM.COM

408

FY 2020

470
FY 2021

Age

White – 61%
BAME – 24%
Unspecified – 15%

41%
in the UK525

FY 2022

Male – 65%
Female – 35%

Women in top
management
positions3, 4

1Ethnicity(UK only)2

All employees(525)

Below 30 – 18%
30-50 – 69%
Over 50 – 13%

35%
globally

2. Based on data as at 31 March 2022 for UK only the disclosure rate was 85% (inclusive of “chose not to disclose”).
3. Maximum two levels away from the CEO or comparable positions (as % of total top management positions).
4. As at 31 March 2022.

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

Further disclosures

PROGRESS ON OUR DIVERSITY INITIATIVES
Enhancing inclusion

Through an inclusive approach, we cultivate a diversity ofperspectives. Our global Diversity and Inclusion (D&I) strategy
plays an important role in enhancing our performance by fostering
an environment of constructive challenge and creative approaches,
as well as enabling us to attract and retain the best talent.

Our hiring strategies aim to foster inclusion
and to acknowledge diverse representation.
We have implemented talent policies andpractices to minimise bias at every stage.
We work relentlessly on ensuring that we
maintain and nurture an inclusive culture
and environment.

Key initiatives

An employer of choice
We aim to create a culture in which our
employees feel comfortable to bring their
entire experience and background to work,in order to develop their talents and deliver
exceptional results. We ensure that leaders
are capable of creating an inclusive culture
in which a diverse set of perspectives isshared, heard and acted upon.

Key initiatives– Continue to cultivate an environment
where there are significant opportunities
for employees to take incremental
responsibility to enable them to growprofessionally and personally– Comprehensive mentoring anddevelopment programmes for employees
throughout all stages of their careers75%
response to our first Inclusion Survey
34 | ICGAM.COM– D&I Champions Group to bring all our
employee networks together, including
representatives from all regions toensure global connectivity– All leadership development now
incorporates a focus on D&I , and a
new mandatory annual D&I training
programme has been implemented.
D&I is also a leadership KPI for
Executive Directors– Our Competency Framework has an area
dedicated to D&I, thereby hardwiring
this important area into our annual
performance management cycle andpromotions process– Following on from our first Inclusion
Survey, and in an effort to remain current,
we now ask a number of D&I questions
within each of our Employee Engagement
pulse surveys, ensuring we continue toalign our initiatives with what mattersmost to our employees– There has been a refocus on unconscious
inclusion through mandatory global
workshops and new annual mandatory
D&I compliance training. Workshops
were delivered with our training partners
through both in-person and virtual
means globally to the vast majority of ouremployees to aid a successful inclusion
culture at ICG. D&I mandatory training
also incorporated other important topics
such as discrimination and harassment in
the workplace

Building a diverse poolof future talent
We are focused on supporting specificexternal bodies and initiatives whose aim
is to increase the diverse pool of talentacross the industry in order to help bringthe entire sector forward, to challenge
each other, and to share best practices.

Key initiatives– Significantly enhanced our early-years
sponsorship through our new charity
framework; see pg. 37 for further details– Continued our Graduate Programme,with focus on diversity: 63% female and
37% identifying as an ethnic minority– We provided internships to candidates
from diverse backgrounds in ourinvestment teams in the UK and USA in
Summer 2022, reflecting our partnerships
with #10000BlackInterns and SEO USA– Continued support for Level 20, to mentor
and develop women in investment positions– Sponsored the BVCA Diversity series,
educating, promoting and valuing diversity
across our sector– Part of 100 Women in Finance, a global
initiative to increase the pool of talented
women in our sector

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Operating purposefully

Investing sustainably

Further disclosures

PROGRESS ON OUR ENGAGEMENT INITIATIVES
Employee development

Wellbeing and support

Onboarding

Our wellbeing strategy also incorporates
a strong framework of policies to support
families, and we have made significant
progress in that area this year. We havereviewed our policies to ensure we support
employees at every stage in their timewith us and introduced a number of newpolicies during the year. These include
policies around Global Conception andFamily Building; Pregnancy Loss; Primaryand Secondary Care Leave; a Carer Policy;
and a Menstruation and Menopause Policy.
As an example, parental leave for all primary
caregivers globally is 26 weeks and nonprimary caregivers is four weeks, during
which time we do not pro-rate bonuses.

– Part-time working options are available
to all permanent employees upon mutual
agreement between employee andthe manager– Childcare facilities or contributions– Breast-feeding/lactation facilities or benefits– Paid parental leave for the primary
caregiver is 26 weeks globally, in excessof the minimum legal requirement.
– Paid parental leave for the non-primary
caregiver is four weeks globally, in
excess of the minimum legal requirement

We view this policy framework as animportant tool in ensuring that ouremployees are able to balance theirwork and family lives.

26

We run a comprehensive programme
for new joiners to ensure our people feel
welcome and swiftly become part of ourculture, irrespective of their background,role or location. The centrepiece is a twice
yearly in-person Global Induction, helping
to bring the business together acrossbusiness lines and geographic boundaries.

Supporting continuous
development
We provide our people with varied training
and learning opportunities. These include
an individual development budget, onthe-job opportunities and social learning
through mentoring, coaching and internaland external networks.
Our global learning platform provides
structured training and support. With achoice of over 8,000 online courses, themajority of colleagues have explored morethan 250 topics since the start of 2021.
We also support all permanent staff(including part-time employees) to complete
professional qualifications, such as CFA,CAIA and IMC.
We run a number of targeted development
programmes at various levels of theorganisation. These include: Successful
Promotions; Leading for Impact; andWomen’s Development programmes.

8,000
online courses available

35 | ICGAM.COM

We continue to promote our
global Employee Assistance
Programme, ensuring that all
employees are aware of theconfidential, independent support
available to them and their families.
Wellbeing Champions are in our
offices globally to support ourpeople by championing health andwellness campaigns and initiatives.

weeks’ paid parental leave
for the primary caregiver

Engagement and voice
Effective two-way communication with our
employees is essential to build and maintainengagement. Following a comprehensive
baseline survey in November 2021, we runGroup-wide pulse surveys three times ayear to ensure we capture timely, targeted
feedback from our employees across multiple
aspects of engagement. Participation inthese surveys is more than 80%, enabling us
to focus more dynamically on specific areasof strength and improvement. Managers arestrongly encouraged to share and discuss
results at a team level to ensure change istargeted and relevant.

Amy Schioldager
is our designated NonExecutive Director for
employee engagement.
She conducts focus groups
during the year to obtain
employees’ feedback on
the business and culture.
These are reported back to
the Board and factored into
decision-making.

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Operating purposefully

Investing sustainably

Further disclosures

Our communities
CHARITABLE GIVING
During the year we have significantly enhanced ICG’s charitablegiving, ensuring that it is impactful and clearly aligned to our
corporate purpose and values and with a specific focus on
education and social mobility. We have committed £4m from
FY23 to FY25 to support our new partner charities, in addition toother charitable commitments. We also provide a number of ways
for our employees to leverage their own contributions, whether
financial or time and expertise. ICG’s charitable contributions
totalled over £2.5m for the year ending 30 September 2022.

Employee involvement– Education and social mobility have been
embedded within ICG’s D&I activities fora number of years– Following a review of our charitable giving
we have decided to focus on these areas– We are focusing on a wider geographic
and a broader spectrum of academic
and career stages:
1. School into university
2. University into employment
3. Employment

36 | ICGAM.COM

Our new partnerships during the year

– This framework, together with our existing
initiatives, positions ICG as a committed
supporter of education as a means ofimproving social mobility outcomes– It also amplifies our voice in the D&I
space and allows us to build a more
impactful profile at an international
scale mirroring our business footprint

The Access Project

UpReachSEO London

School to university (UK)

University to employment (UK)

Description: helps support students
from disadvantaged backgrounds
to access top universities, througha unique combination of tuition andin-school interventions.

These new partnerships are in addition
to our long-standing support of othercharities, including the Education
Endowment Fund and ThinkForward, where
we have developed multi-year relationships.

ICG’s support: committed £1.5m
over three years to support theirwork in the UK.

Description: works alongside The
Access Project, helping ensure highachieving university students fromdiverse and disadvantaged backgrounds
complete their studies and transition
into sought-after graduate pathways
and into successful careers.

University while in employment(US, Europe, UK)

ICG’s support: committed £750k overthree years to support their work in
the UK.

Description: aims to increase accessto financial and professional services
careers among under-represented
demographics, with a focus onuniversity-years support in terms of
mentoring, coaching and internships
and also, distinctively, on supporting
early-years careers.
ICG’s support: committed £1.5m overthree years to work with SEO as a major
partner in Europe, building on their
UK presence as well as helping scale
into key continental markets whilstenhancing our partnership in the US.

ICG’s support: morethan just financial– Our employees have thepotential to bring a substantial
set of experiences to bear
– We believe our employees
benefit from this engagement,
and we encourage them todedicate two working days a year
to support our charity partners– To support this, we run a seriesof co-ordinated, firm-wide
volunteering days
– Recognising the importance of
local relevance, we encourage ouroffices around the world to support
charities in their communities– The firm supports all
employees who make charitable
donations through its matchedgiving programme

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Operating purposefully

Investing sustainably

Further disclosuresRESPONDING TO LOCAL NEEDS
We are pleased to be able to play a smallpart in helping support those most in need,
as a result of the cost of living crisis, in thecommunities in which our people live andwork. This initiative will not only provide muchneeded funding to leading charities providing
a range of food-based and social support, butalso enable our employees to volunteer theirtime to assist in the practical delivery of muchneeded assistance on the frontline.

ICG launches “Million Meals Initiative” to support charities
addressing the cost of living crisis
As a firm we are very conscious of thechallenging time many are facing withthe rising cost of living as we come into
winter in the northern hemisphere.

This initiative will provide a total of£500,000 of new funding across six leading
charities delivering support to people inneed in each of the cities in which ICG has
major operations worldwide. This seasonal
campaign will run from November 2022 toApril 2023. The charities ICG is partneringwith to provide this critical support are:

In response to these clear and growing
needs, ICG launched in 2022 the“Million Meals Initiative” to support
charities addressing these issues.

City Harvest(London)

City Harvest(New York)£500,000of new funding across six leading charities

European Food Banks Federation(pan-European)

Picture relates to ICG’s Million Meals Initiative

Food from the Heart(Singapore)
View more
about our charitable giving on our website

37 | ICGAM.COM

OnSide(UK)

Whitechapel Mission(London)In addition to providing funding, these charitable partnerships will also offer
significant volunteering opportunities to ICG’s employees worldwide. ICG has
also committed to double any charitable donations by ICG employees to thesepartner charities during the campaign.

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Operating purposefully

Investing sustainably

Further disclosures

Our operations
ENVIRONMENTAL STEWARDSHIP IN OUR OPERATIONSICG is aware of the potential impact of its business operations on
the environment. We seek to manage and reduce such impacts
and encourage key suppliers to do the same (see pg. 39 forfurther details). While our own direct operations have a lower
impact on the environment than our investments and financing,
we recognise the importance of upholding a high standard ofenvironmental stewardship across our business. Indeed, in 2021,
we set an approved and verified science-based target for ourown operations, to reduce absolute Scope 1 and 2 GHG emissions
by 80% by 2030 from a 2020 base year.
ICG operates from leased offices. As such our environmental stewardship efforts may differ
depending on the size of the office and our contractual arrangement with the landlord.
However, where possible, we seek to:– Procure 100% renewable electricity– Optimise the use of energy for heating and cooling in our offices– Implement ICG’s sustainable fit-out policy when moving or refurbishing office spaces– Divert all waste from landfill and maximise recycling rates– Work with cloud-based solution providers with robust decarbonisation policies– Conduct meetings virtually as far as possible to avoid unnecessary business travel which
is one of our highest carbon impacts

ICG annually measures and reports its operational carbon footprint, along with the key
impacts that our operations pose on the environment.
GHG emissions(tCO2e)Renewable energy

FY22

FY21

FY20

Direct emissions(Scope 1)

Combustion of fuel andoperation of facilities

7

11

66

Indirect emissions(Scope 2)

Purchased electricity/heat(location-based)1

194

211

448

Purchased electricity/heat(market-based)

74

184

479

Business travel (flights,
rail, vehicles & taxis)

749

41

2,640

Water supply and waste
generation (offices)

4

0.6

8

753

42

2,647

Indirect emissions(Scope 3)

Total Scope 3

1.	2021 Scope 2 (location-based) emissions for the UK have been restated following an update of the electricity
consumption.

Scope 1 and 2 (market-based) emissions decreased by 58% this reporting period, primarily
due to a rise in the number of offices procuring 100% renewable electricity. This is despitea growth in the number of employees in the Group and their return to more frequent workfrom the office, following the global pandemic. Our offices are consuming a comparable
amount of electricity from FY20 to FY21, which explains why total Scope 2 (location-based)emissions have only decreased slightly as national energy mixes continue to decarbonise.
Our measured emissions equated to carbon intensity of 0.13 tCO2e/employee or 0.09
tCO2e/£m revenue.
The GHG information for the period 01/04/2021 – 31/03/2022 is verified by Carbon
Intelligence to a limited level of assurance, consistent with the agreed verification scope,
objectives and criteria. The verification exercise was performed to the ISO 14064-3 standard.

38 | ICGAM.COM

FY22

FY21

FY20

Electricity

kWh650,729

686,572

1,468,177

Of which from renewable sourceskWh379,161

154,744

–

Fuels

kWh

25,99237,927316,156

Energy intensity

MWh/FTE

0.13

3.21

3.71

Total water consumption

m3

N/A2

7791

7,726

Total commercial waste

Tonne

66.43

N/A

N/A

Total waste diverted from landfill(London HQ)

%

100

100

100

1.	Water consumption in FY21 was significantly lower compared to previous years as offices were closed due to
Covid-19 restrictions. Data includes a prorated estimate for water consumption at our new London HQ office –Procession House.
2.	Data not available from managing agent for new London HQ office meaning FY22 was non-comparable.
Figure without London was 591 m3

The purchase of renewable energy in our operations has
significantly increased year on year, from 154,744 kWh in FY21
to 379,161 kWh in FY22. This constitutes 58.2% of our total
electricity procured from renewable sources, up from 22.5% in
FY21. This 145% increase is supporting ICG’s progress towards
achieving its SBTi approved target and will continue to be afoundation for the achievement.

ICG pension
ICG ‘s employees in the UK are automatically enrolled into aworkplace pension. Environmental, social and governance (ESG)
factors are integrated into the default fund as far as possible,
currently covering 85% of the portfolio. The ESG investments
include exclusions for companies with significant revenue fromcontroversial weapons, thermal coal, tobacco, and perennial
violators of the United Nations Global Compact (UNGC)
principles as a minimum. The default fund goes even further,for example by targeting net zero by 2050 and investing witha lower emissions profile compared to a non-ESG equivalentfund. 84% of UK employees enrol in the UK pension.

Internal and external communications
Building awareness on environmental matters is anotherimportant aspect of our environmental stewardship. ICG
delivers a range of public updates to its external stakeholders(see pg. 29). We also communicate to our employees via
our intranet and through our website, for example throughtargeted awareness raising campaigns on Earth Day about
the value of nature and sustainable living.

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

SUPPLIER MANAGEMENTAs an asset management company, ICG has a relatively
straightforward supply chain model which is built around its corefinancial practice, maintaining its global offices and supporting
its technological infrastructure.
In 2022, ICG began reviewing its processes
with suppliers (both onboarding and the
go-forward relationship) and is developing
a new and enhanced ESG assessment
process which all new and existing material
suppliers will be required to complete, andalso provide certain ongoing information
regarding the management of theirbusiness, which will seek to confirm how
certain ESG risks are managed.
In addition, material suppliers will be
requested to adhere to our Supplier Codeof Conduct which specifically outlines our
expectations with regards to complying withall relevant national laws and regulations:View more
about our ICG Supplier Code of
Conduct 2020 on our website

39 | ICGAM.COM

a. Adopting a responsible and ethicalapproach to businessb. Upholding and protecting labour &human rights in their business andsupply chainsc. Managing and reducing environmental
impacts in their business andsupply chainsd. Identifying and managing supply chain
risks in their own supply chains
We will continue to consider (whereappropriate based on the relevant industry
or region) whether to include contractual
provisions with regards to ESG practice inour material supply contracts – particularly
those for services in higher risk industries
or regions – to ensure that our suppliers
comply with their obligations underrelevant legislation.

Supplier review for
modern slavery risks
In 2022, we carried out our annual review
of our supplier list, which concentrated
on suppliers which invoice, on an
aggregate basis, over £5,000 or which
are from industries or regions which
may pose a higher risk of slavery or
human trafficking. In total, 442 suppliers
were considered, across 24 countries.
All suppliers which we considered topotentially pose medium or higher
risk were subjected to a more detailed
review and/or formally contacted torequest details of their practices andpolicies with respect to modern slavery.
There are currently no known mattersof concern from a modern slavery
perspective in our supply chain, but
this statement will be updated if any
subsequently arise. For further details
see our latest Modern Slavery and
Human Trafficking Statement.

View more
about our Modern Slavery
Statement on our website

Operating purposefully

Further disclosures

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

CYBER RISK
Protecting ICG’s data through technicalcontrol measures alongside employee training
and awareness remain focus areas for ICG.
Expectations around how, when and where
we work are changing; firms’ attack surfaces
are widening, and no longer can traditional
firewalls and anti-virus tools guarantee a firm’s
cyber security.
View more
about cyber threats as part ofour Principal Risk on pg. 57 of
our Annual Report40 | ICGAM.COM

Ensuring we have a secure andresilient technology environment
to deliver effective services to ourclients and portfolio companies
remains a key focus for ICG.
Delivering resilient IT services to ourcolleagues is essential to business
operations with resilience and security
by design one of our architectural pillars.
Our Executive Committee and Risk
Committee are provided with regular
updates providing KPIs to give themfull oversight of cyber risks, and wecontinue to invest heavily in processes
and technologies to combat the increased
attack surface that comes from working
outside a fixed perimeter office.
– ICG runs a 24x7x365 Managed Security
Operations Centre manned by cybersecurity professionals to detect andprevent possible threats to ICG’s data.
– The Managed Security Operations Centre
additionally provides ICG with ThreatIntelligence, giving us early warning
to emerging threats across the globe,
enabling ICG to put in place barriers toprevent attacks.
– Vulnerabilities are assessed and managed
on an ongoing basis 24x7, managed
in real time and any software updates
deployed rapidly.

Operating purposefully

Further disclosures

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

We align with all relevant sustainability bodies,including SASB and GRI Standards, as well as theUN’s Sustainability Development Goals.

GRI and SASB content index

42

Supplementary corporate disclosures

56

Important information57

41 | ICGAM.COM

Investing sustainably

Operating purposefully

Further disclosures

Further
disclosures

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEXThe following index tables summarise our disclosures against relevant SASB and GRI Standards. Reference pages within this reportrefers to relevant pages within the ICG Annual Report and Accounts 2022, andrefers to a webpage.
are labelled ,SASB content index
Topic

Ref

MetricLocation of disclosure

Commentary

Transparent information &fair advice for customers

FN-AC-270A.1

Number of covered employees with arecord of investment-related investigations,consumer-initiated complaints, private civil
litigations, or other regulatory proceedings

See Commentary

To the best of our knowledge, in the 18 months to 30 Sept 2022 , there were no known:

Transparent information &fair advice for customers

FN-AC-270a.1% of covered employees with a record of
See Commentary
investment-related investigations, consumerinitiated complaints, private civil litigations,or other regulatory proceedings

Transparent information &fair advice for customers

FN-AC-270a.2

Total amount of monetary losses as aresult of legal proceedings associated withmarketing and communication of financial
product related information to new andreturning customers

See Commentary

Transparent information &fair advice for customers

FN-AC-270a.3

Description of approach to informing
customers about products and services

See Commentary

Employee Diversity& Inclusion

FN-AC-330a.1

Percentage of gender and racial/ethnic
group representation for:(1) executive management(2) non-executive management(3) professionals (investment)(4) all other employees

AR pg. 75;

Incorporation of ESG
Factors in Investment
Management & Advisory

Incorporation of ESG
Factors in Investment
Management & Advisory

42 | ICGAM.COM

FN-AC-410a.1

FN-AC-410a.2

SPR pg. 33
See Commentary– covered employees with records of investment-related investigations, consumer-initiated complaints, private civil litigations or other regulatory proceedings– monetary losses as a result of legal proceedings, incidents of non-compliance associated with marketing and communications of financial product related
information to new and returning clientsAt ICG, there is a dedicated Marketing and Client Relations team that ensures timely, regular and transparent communication and interaction with existingand prospective clients. Information about products and services is disclosed in strict compliance with applicable laws and regulations and undergoes
review in accordance with ICG’s compliance procedures. All investors in ICG Funds receive regular performance reports (typically quarterly). ICG hosts
an Investor day each year where we provide an overview of ICG Funds’ performance and key developments and create a forum to interact with clients andanswer their questions.
As at 30 September 2022:
ICG’s Executive Directors: 33% female, 67% male
ICG’s Non-Executive Directors: 50% female, 50% male. See ICG’s website for further details on the composition of the Board of Directors.
Due to legal and other restrictions we do not monitor the ethnicity of employees in some of the jurisdictions in which we operate. Therefore, we have only
provided the self reported breakdown of our employees in the UK, which is ICG’s largest office representing nearly 50% of all employees.

Amount of assets under management,by asset class, that employ:(1) integration of ESG issues(2) sustainability themed investing(3) screening

SPR pg. 9, 12;

ICG's Responsible Investing Policy, including ESG screening and integration, applies to 100% of ICG's AUM.

ICG RI Policy

https://www.icgam.com/wp-content/uploads/2022/06/ICG-RIPol-May22-FINAL-NoDate.pdf

Description of approach to incorporationof ESG factors in investment and/or wealthmanagement processes and strategies

SPR pg. 14-30;

As at 30 September 2022, 27% of total AUM is in funds with explicit focus on engagement on climate change and/or in scope of ICG’s portfolio coveragescience-based target.

ICG RI Policy

RI Policy – https://www.icgam.com/wp-content/uploads/2022/06/ICG-RIPol-May22-FINAL-NoDate.pdf

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
SASB content index continued
Topic

Ref

MetricLocation of disclosure

Incorporation of ESG
Factors in Investment
Management & Advisory

FN-AC-410a.3

Description of proxy voting and investee
engagement policies and procedures

Business ethics

FN-AC-510a.1

Total amount of monetary losses as a resultof legal proceedings associated with fraud,insider trading, anti-trust, anti-competitive
behaviour, market manipulation, malpractice,or other related financial industry laws
or regulations

See Commentary

To the best of our knowledge, there are no known monetary losses as a result of legal proceedings associated with fraud, insider trading, anti-trust,anti-competitive behaviour, market manipulation, malpractice, or other related financial industry laws or regulations in FY22.

Business ethics

FN-AC-510a.2

Description of whistleblower policies
and procedures

See Commentary

ICG has an established grievance mechanism for any employee to express concerns. We support anyone who, in good faith, discloses a failure to meet
our high standards of business conduct and ethics. All complaints are investigated in accordance with ICG’s grievance or complaints procedure and thecomplainant is informed of the outcome once the investigation is completed. The is referenced in the ICG Code of Conduct.

SPR pg. 14-30;

Commentary
RI Policy – https://www.icgam.com/wp-content/uploads/2022/06/ICG-RIPol-May22-FINAL-NoDate.pdf

ICG RI Policy roup CodeGof Conduct

ICG is committed to promoting a “speak up” culture where staff feel they can raise concerns without fear of retaliation and in the knowledge that thematters they report will be taken seriously. Our Speak Up Policy outlines how staff may report a concern through both internal channels, which include
reporting to a dedicated Non-Executive Director, and external routes. All employees globally have access to a 24/7 anonymous and confidential service
for making a report, operated by an independent third party, EthicsPoint, whose contact details are available on the ICG intranet. In addition, all external
stakeholders can file a complaint by following ICG’s Complaints Policy.
Activity metrics

43 | ICGAM.COM

FN-AC-000.A(1) Total registered and(2) total unregistered assets
under management (AUM)

SPR pg. 6

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure Name

2-1

Organisational details

Location

GRI Universal Standards 2016

Commentary

GRI Standard Title

Disclosure Number

Disclosure Name

Intermediate Capital Group plc

GRI 102: General
Disclosures 2016

102-1

Name of the organisation

GRI 102: General
Disclosures 2016

102-3

Location of headquarters

https://www.icgam.com/who-we-are/our-offices/

GRI 102: General
Disclosures 2016

102-4

Location of operations

See commentary

Intermediate Capital Group plc is listed on the London Stock Exchange andheadquartered in London, United Kingdom.

GRI 102: General
Disclosures 2016102-5

Ownership and legal form

GENERAL DISCLOSURESGRI 2: General
Disclosures 2021

Front cover
Back Cover
ICG website

GRI 2: General
Disclosures 2021

2-2

Entities included in the organisation’ssustainability reportingSee commentary

The Group consists of a Parent Company, ICG plc, incorporated in the UK, and anumber of subsidiaries held directly or indirectly by ICG plc, which operate andare incorporated around the world. See AR FY22 for further details.

GRI 102: General
Disclosures 2016

102-45

Entities included in
the consolidated
financial statements

GRI 2: General
Disclosures 2021

2-3

Reporting period, frequency andcontact point

See commentaryThis annual Sustainability & People Report 2022 complements our AR FY22 andprovides a more comprehensive account of our progress and activities related to oursustainability and people priorities across the entire ICG Group for the year ending
30 September 2022, unless indicated otherwise.

GRI 102: General
Disclosures 2016102-50

Reporting period

See commentary

ICG follows an annual reporting cycle.

GRI 102: General
Disclosures 2016102-52

Reporting cycle

See commentary

For any questions or feedback related to this report, get in touch with us via:
https://www.icgam.com/contact-us

GRI 102: General
Disclosures 2016102-53

Contact point forquestions regarding
the report

See commentary

No previously disclosed information has been restated in this report.

GRI 102: General
Disclosures 2016

102-48

Restatements
of information

GRI 102: General
Disclosures 2016102-56External assurance

GRI 2: General
Disclosures 2021

2-4

Restatements of information

GRI 2: General
Disclosures 2021

2-5

External assurance

44 | ICGAM.COM

AR pg. 83

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure NameGRI 2: General
Disclosures 2021

2-6

Activities, value chain, and otherbusiness relationships

Location

Commentary

GRI Standard Title

Disclosure Number

Disclosure NameGRI 102: General
Disclosures 2016

102-2

Activities, brands,
products, and services

GRI 102: General
Disclosures 2016102-6

Markets served

GRI 102: General
Disclosures 2016

102-7

Scale of the organisation

GRI 102: General
Disclosures 2016

102-9

Supply chain

There were no significant changes to the organisation and its supply chain in the year. GRI 102: General
ICG opened an office in Dubai to provide local point of contact for our clients in the region. Disclosures 2016

102-10Significant changes tothe organisation and its
supply chain

GRI 102: General
Disclosures 2016

102-7-a-i

Scale of the organisation(total number of
employees)

GRI 102: General
Disclosures 2016

102-8

Information on employees
and other workers

102-8-dInformation on employees
and other workers(information on workers
who are not employees)

SPR pg. 6-7;
AR pg. 3
See commentary

ICG products are marketed in:– Americas: Canada, Chile, Colombia, Peru, and the United States of America.
– Asia Pacific: Australia, China (Mainland), Hong Kong, Japan, New Zealand,
Singapore, South Korea, and Taiwan.
– Europe: Denmark, Finland, France, Germany, Republic of Ireland, Italy,
Luxembourg, Monaco, the Netherlands, Norway, Spain, Sweden, Switzerland,
and the United Kingdom.
– Middle East: Bahrain, Israel, Kuwait, Oman, Qatar, Saudi Arabia, and theUnited Arab Emirates.

SPR pg. 6;
AR pg. 5
SPR pg. 39

See commentary

GRI 2: General
Disclosures 2021

2-7

Employees

GRI 2: General
Disclosures 2021

45 | ICGAM.COM

2-8

Workers who are not employees

As an asset management company, ICG has a relatively straightforward supply chain
model which is built around its core financial practice, maintaining its global offices
and supporting its technological infrastructure.

SPR pg. 33

SPR pg. 33

GRI Universal Standards 2016

Data provided is given in headcount.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure NameGRI 2: General
Disclosures 2021

2-9

Governance structure and composition

Location

GRI Standard Title

Disclosure Number

Disclosure NameGRI 102: General
Disclosures 2016

102-18Governance structure

GRI 102: General
Disclosures 2016102-22Composition of thehighest governancebody and its committees

GRI 102: General
Disclosures 2016102-24

Nominating andselecting the highest
governance body

GRI 102: General
Disclosures 2016102-23Chair of the highest
governance body

GRI 102: General
Disclosures 2016102-21

Consulting stakeholders on
economic, environmental,
and social topics

GRI 102: General
Disclosures 2016102-26

Role of highest governancebody in setting purpose,values, and strategy

SPR pg. 7

GRI 102: General
Disclosures 2016102-29Identifying and managing
economic, environmental,
and social impacts

 R pg. 57, 58, 59,
A64, 87

GRI 102: General
Disclosures 2016

102-30Effectiveness of risk
management processes

SPR pg. 8
AR pg. 73
ICG Governance

GRI 2: General
Disclosures 2021

2-10

Nomination and selection of the highest
governance body

AR pg. 79, 91

GRI 2: General
Disclosures 2021

2-11

Chair of the highest governance body

ICG Governance

GRI 2: General
Disclosures 2021

2-12Role of the highest governance body inoverseeing the management of impacts

SPR pg. 7

https://www.icgam.com/who-we-are/leadership-governance/

https://www.icgam.com/who-we-are/leadership-governance/

AR pg.23
ICG Governance

46 | ICGAM.COM

Commentary

GRI Universal Standards 2016

https://www.icgam.com/who-we-are/leadership-governance/Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021

GRI Universal Standards 2016

GRI Standard Title

Disclosure
Number

Disclosure Name

Location

Commentary

GRI Standard Title

Disclosure Number

Disclosure NameGRI 2: General
Disclosures 2021

2-13

Delegation of responsibility
for managing impacts

See commentary

The ICG Board provides oversight of our approach to managing our sustainability
and people priorities and for reviewing key policies. Stephen Welton has been
appointed as a designated Non-Executive Director on ESG matters and Amy
Schioldager as the Non-Executive Director responsible for liaising with employees.
Day to day responsibility for these matters has been delegated to the Executive
Directors as part of their formal remits.

GRI 102: General
Disclosures 2016

102-19Delegating authority

See commentary

The Executive Directors are responsible for ensuring the effective identification and
GRI 102: Generalmanagement of our sustainability and people priorities, and review progress at least
Disclosures 2016
annually. The Management Committee supports the Executive Directors in overseeing
and monitoring our policies and procedures, addressing issues if they arise andapproving new strategic initiatives. All sustainability priorities have designated owners
within the business to ensure our continued focus and effective management.

102-20Executive-level
responsibility foreconomic, environmental,
and social topics

GRI 2: General
Disclosures 2021

2-14

Role of the highest governancebody in sustainability reportingSee commentary

ICG’s Executive Directors reviewed and approved this Sustainability and People Report.

GRI 102: General
Disclosures 2016

102-32Highest governancebody’s role insustainability reporting

GRI 2: General
Disclosures 2021

2-15

Conflicts of interest

See commentary

Board-level conflicts are overseen by the Global Head of Legal and Compliance.
A register of such is maintained, and external positions are notified to the whole
Board and disclosed to shareholders as required by the Listing Rules.

GRI 102: General
Disclosures 2016102-25

Conflicts of interest

The Board of ICG typically meets formally six times per year, and the Audit, Risk and
GRI 102: General
Remuneration Committees typically meet at least four times per year. Each body
Disclosures 2016
receives full written reports on all matters within their remit. Senior management,
including heads of control functions, report formally to the Board and each Committee,
including regular private sessions for the Heads of Compliance, Risk and Internal
Audit. In between Board meetings, Non-Executives receive regular updates frommanagement, including formal meetings for the Chairman with the CEO, the Chairman
with the Global Head of Legal and Compliance, the Audit Chair and the CFOO, theAudit Chair with the Head of Finance, the Audit Chair with the Head of Internal Audit,
the Risk Chair with the Global Head of Legal and Compliance, the Risk Chair with theHead of Compliance, the Risk Chair with the Head of Risk and the Remuneration Chairwith the Chief People Officer.

102-33

Communicating
critical concerns

GRI 102: General
Disclosures 2016

102-34Nature and total numberof critical concerns

ICG has implemented a Conflicts of Interest framework including, but not limited to,a Conflict of Interests Policy and Conflicts Register.
GRI 2: General
Disclosures 2021

47 | ICGAM.COM

2-16

Communication of critical concerns

See commentary

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure NameGRI 2: General
Disclosures 2021

2-17Collective knowledge of the highest
governance body

GRI 2: General
Disclosures 2021

2-18

GRI 2: General
Disclosures 2021

2-19

GRI 2: General
Disclosures 2021

2-20

Location

Commentary

GRI Standard Title

Disclosure Number

Disclosure Name

AR pg. 74, 79

GRI 102: General
Disclosures 2016102-27

Collective knowledge ofhighest governance body

Evaluation of the performance of thehighest governance body

AR pg. 76

GRI 102: General
Disclosures 2016102-28

Evaluating thehighest governancebody’s performance

Remuneration policies

AR pg. 93, 94, 105, 110

GRI 102: General
Disclosures 2016

102-35

Remuneration policies

GRI 102: General
Disclosures 2016

102-36

Process for determining
remuneration

GRI 102: General
Disclosures 2016

102-37

Stakeholders’ involvement
in remuneration

AR pg. 105

GRI 102: General
Disclosures 2016

102-38Annual totalcompensation ratio

AR pg. 106

GRI 102: General
Disclosures 2016

102-39Percentage increasein annual totalcompensation ratio

Statement on sustainable
development strategy

SPR pg. 5

GRI 102: General
Disclosures 2016

102-14

Statement from seniordecision-maker

Policy commitments

RI Policy

GRI 102: General
Disclosures 2016

102-11

Precautionary Principle
or approach

SPR pg. 7

GRI 102: General
Disclosures 2016

102-16

Values, principles,standards, andnorms of behaviour

SPR pg. 14, 15

N/A

N/A

N/A

SPR pg. 14
Process to determine remuneration

AR pg. 93, 94, 105, 110
SPR pg. 14
AR pg. 93, 94, 105, 110
SPR pg. 14

GRI 2: General
Disclosures 2021

2-21

GRI 2: General
Disclosures 2021

2-22

GRI 2: General
Disclosures 2021

2-23

GRI 2: General
Disclosures 2021

48 | ICGAM.COM

2-24

GRI Universal Standards 2016

Annual total compensation ratio

Embedding policy commitments

AR pg. 12, 13, 14, 15
ICG’s risk management is an ongoing process under the leadership and supervision of
the Executive Committee, the Risk Committee and, ultimately, the Board of Directors.
ICG’s approach to managing risk can be found on pg. 57 of AR FY22.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure NameGRI 2: General
Disclosures 2021

2-25

Processes to remediate negative impacts

GRI 2: General
Disclosures 2021

2-26

Mechanisms for seeking advice andraising concerns

Location

Commentary PR pg. 56 (furtherS
disclosures)

See commentary

ICG has an established grievance mechanism for any employee to express concerns.
We support anyone who, in good faith, discloses a failure to meet our high standardsof business conduct and ethics. All complaints are investigated in accordance with
ICG’s grievance or complaints procedure and the complainant is informed of theoutcome once the investigation is completed.

GRI Universal Standards 2016
GRI Standard Title

Disclosure Number

Disclosure NameGRI 103:
Management
Approach 2016103-2-c-vi

The management
approach and its
components(Grievance mechanisms)

GRI 102: General
Disclosures 2016

102-17

Mechanisms for advice
and concerns about ethics

ICG is committed to promoting a “speak up” culture where staff feel they can raise
concerns without fear of retaliation and in the knowledge that the matters they reportwill be taken seriously. Our Speak Up Policy outlines how staff may report a concern
through both internal channels, which include reporting to a dedicated Non-Executive
Director, and external routes. All employees globally have access to a 24/7 anonymousand confidential service for making a report, operated by an independent third party,
EthicsPoint, whose contact details are available on the ICG intranet. In addition, allexternal stakeholders can file a complaint by following ICG’s Complaints Policy.
GRI 2: General
Disclosures 2021

2-27

Compliance with laws and regulations

See commentary

To the best of our knowledge, there were no known material fines or sanctions for
non-compliance with environmental laws and /or regulations across ICG Group in the
18 months to 30 September 2022.

GRI 307:
Environmental
Compliance 2016

307-1

Non-compliance withenvironmental laws andregulations

See commentary

To the best of our knowledge, there were no known incidents of non-compliance with laws
and regulations in the social and economic area in the 18 months to 30 September 2022.

GRI 419:
Socioeconomic
Compliance 2016

419-1

Non-compliance with laws
and regulations in thesocial and economic area

GRI 2: General
Disclosures 2021

2-28

Membership associations

SPR pg. 30, 36, 37

GRI 102: General
Disclosures 2016

102-13

Membership ofassociations

GRI 2: General
Disclosures 2021

2-29

Approach to stakeholder engagement

SPR pg. 7

GRI 102: General
Disclosures 2016

102-40

List of stakeholder groups PR pg. 56 (furtherS
disclosures)

GRI 102: General
Disclosures 2016

102-42

Identifying andselecting stakeholders

AR pg. 23

GRI 102: General
Disclosures 2016

102-43

Approach to
stakeholder engagement

49 | ICGAM.COM

AR pg. 11

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021

GRI Universal Standards 2016

GRI Standard Title

Disclosure
Number

Disclosure Name

Location

Commentary

GRI Standard Title

Disclosure Number

Disclosure NameGRI 2: General
Disclosures 2021

2-30Collective bargaining agreements

See commentary

As at 30 September 2022 there were collective bargaining agreements in place at twoof our geographies, covering approximately 5% of our employees. This constitutes thegeographies where collective bargaining agreements are applicable.

GRI 102: General
Disclosures 2016

102-41

Collective bargaining
agreements

GRI 3: Material Topics
2021

3-1

Process to determine material topics

SPR pg. 7

The content of the report was determined on the basis of the outcomes of ourmateriality assessment (see pg. 7) and draws on relevant GRI Standards and the
SASB guidelines for asset managers.

GRI 102: General
Disclosures 2016

102-46

Defining report content
and topic Boundaries

GRI 3: Material Topics
2021

3-2

List of material topics

SPR pg. 7

GRI 102: General
Disclosures 2016

102-47

List of material topics

GRI 102: General
Disclosures 2016

102-49Changes in reportingSee commentary

50 | ICGAM.COM

There have been no material changes in our reporting.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure NameGRI 3: Material Topics
2021

3-3

Management of material topics

LocationRI Policy

Commentary

GRI Universal Standards 2016
GRI Standard Title

Disclosure Number

Disclosure Name

102-11

Precautionary Principle
or approach

GRI 103:
Management
Approach 2016

Clauses 1.1 and 1.2

General requirements
for reporting themanagement approach

GRI 103:
Management
Approach 2016

103-1

Explanation of thematerial topic andits Boundary

GRI 103:
Management
Approach 2016

103-2

The management
approach and its
components

GRI 103:
Management
Approach 2016

103-3

Evaluation of the
management approach

ICG’s risk management is an ongoing process under the leadership and supervision
GRI 102: Generalof the Executive Committee, the Risk Committee and, ultimately, the Board of Directors. Disclosures 2016
ICG's approach to managing risk can be found on pg. 57 of AR FY22.

We assess materiality from two angles, first at a Group level; secondly within ourinvestment activities. We identified the environmental, social and governance issues
that are relevant to our industry and company. This included the topics of importanceto our clients, shareholders and employees, as well as those that align to our company
values and investment ethos.
Additionally, we assessed these topics against the sustainability reporting standards
and emerging disclosure regulations, such as the Global Reporting Initiative (GRI),
the Sustainability Accounting Standards Board (SASB), SFDR, the EU Taxonomy and
the Task Force on Climate-Related Financial Disclosures (TCFD), as well as relevant
aspects of ICG’s principal risks and uncertainties.
We consolidated the issues into six priorities. We plan to update the materiality
assessment at least every two years to ensure that we continue to focus on the topics
that matter most.

51 | ICGAM.COM

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI content index – General disclosures 2021 are shown in alignment with the 2016 edition
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure Name

Location

Commentary

GRI Universal Standards 2016
GRI Standard Title

Disclosure Number

Disclosure NameGRI 102: General
Disclosures 2016102-55

GRI content index

GRI 102: General
Disclosures 2016102-54Claims of reportingin accordance with
the GRI Standards

Content that has moved to GRI 1: Foundation 2021
GRI 1: Foundation 2021

52 | ICGAM.COM

N/A

Requirement 7: Publish a GRI
content index

 PR pg. 44
S(further disclosures)

N/A

Publish a GRI content index

 PR pg. 44
S(further disclosures)

N/A

Requirement 8: Provide a statement of use

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI Topic specific disclosures – content index continued
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure Name

Location

Commentary

TOPIC-SPECIFIC DISCLOSURESGRI 201: Economic
performance 2016

201-1

GRI 203: Indirect
Economic Impacts 2016
GRI 205: Anti-corruption
2016

Direct economic value generated
and distributed

SPR pg. 36, 37;

203-1

Infrastructure investments andservices supported

SPR pg. 25-27

205-2

Communication and training aboutanti-corruption policies and procedures

AR pg. 136, 162

See Commentary

Our policy is never to offer, request or receive bribes, and to refuse any request to pay them. We actively seek to reduce opportunities for corruption. We do
not invest in companies or projects that engage in corruption or appear to have a high risk of such behaviour and we investigate and deal with all reported or
identified cases of corruption in line with our policy. The policy applies to all entities within the Group wherever we do business and is communicated to all
employees and Directors of ICG plc.
Training on anti-money laundering, anti-bribery corruption and information security and cyber awareness is mandatory and is provided to all ICG employees
on an ongoing basis. Employees are required to undertake the training, which is web-based, at least once a year, and pass a test on what they have learned.

GRI 207: Tax

207-1

Approach to tax

GRI 207: Tax

207-2

Tax governance, control,
and risk management

GRI 302: Energy 2016

302-1

Energy consumption within
the organisation

GRI 302: Energy 2016

302-3

Energy intensity

GRI 305: Emissions 2016

305-1

Direct (Scope 1) GHG emissions

SPR pg. 38

GRI 305: Emissions 2016

305-2

Energy indirect (Scope 2) GHG emissions

SPR pg. 38

GRI 305: Emissions 2016

305-3

Other indirect (Scope 3) GHG emissions

SPR pg. 38

GRI 305: Emissions 2016305-4

GHG emissions intensity

SPR pg. 38

GRI 307: Environmental
Compliance 2016

307-1

Non-compliance with environmental
laws and regulations

53 | ICGAM.COM

See Commentary

SPR pg. 38

I CG’s Tax Strategy sets out the governance and core principles underpinning the tax affairs of ICG plc and its subsidiaries, both in the UK and in each of
the markets in which it operates. The Group is committed to full compliance with tax legislation across its geographical markets and maintaining open andtransparent communication with both HMRC and the respective local tax authorities.
Details on the energy consumption within our operations are provided in the Company Environmental Stewardship section.

AR pg. 42
See Commentary

See Commentary

To the best of our knowledge, there were no known material fines or sanctions for non-compliance with environmental laws and /or regulations across ICG Groupin the 18 months to 30 September 2022.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI Topic specific disclosures – content index continued
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure Name

Location

GRI 401: Employment
2016

401-1

New employee hires and employee turnover

GRI 401: Employment
2016

401-2

GRI 403: Occupational
Health & Safety 2018403-6

Promotion of worker health

SPR pg. 35

GRI 404: Training and
Education 2016

404-2

Programs for upgrading employee skills
and transition assistance programs

SPR pg. 35

GRI 404: Training and
Education 2016

404-3

Percentage of employees receiving
regular performance and careerdevelopment reviews

SPR pg. 33

Commentary
Notable workforce changes – ICG did not furlough any employees, or make any employees redundant, as a result of the Covid-19 pandemic.

AR pg. 31

GRI 405: Diversity and405-1
equal opportunities 2016

Benefits provided to full-time employeesthat are not provided to temporary or
part-time employees

Diversity of governance bodies
and employees

SPR pg. 35;

All benefits offered to full-time employees are offered to part-time employees.

See Commentary

See Commentary

During the year to 31 March 2022 there were no RIDDOR-reportable incidents, and no work-related accidents or cases of work-related ill health were reported.

All ICG employees receive regular performance and career development reviews based on the ICG Competency Framework. This involves a 360 assessment
and SMART goal setting and involves mid-year reviews with line managers.

AR pg. 21, 31, 75;

As at 30 September 2022:
ICG’s Executive Directors: 33% female, 67% male
ICG’s Non-Executive Directors: 50% female, 50% male. See ICG’s website for further details on the composition of the Board of Directors.

I CG Diversity& Inclusion Policy;

Due to legal and other restrictions we do not monitor the ethnicity of employees in some of the jurisdictions in which we operate. Therefore, we have
only provided the self-reported breakdown of our employees in the UK, which is ICG’s largest office representing nearly 50% of all employees.

SPR pg. 33;

See Commentary

https://www.icgam.com/wp-content/uploads/2022/06/icg-diversity-and-inclusion-policy.pdf

GRI 405: Diversity and405-2
equal opportunities 2016

Ratio of basic salary and remunerationof women to men

GRI 406: Nondiscrimination 2016406-1

Incidents of discrimination and corrective
actions taken

GRI 413: Local
communities 2016413-1

Operations with local community
engagement, impact assessments,
and development programs

GRI 415: Public Policy
2016

415-1

Political contributions

See Commentary

It is ICG’s policy not to make any political contributions or lobby policy makers. No contributions were made during the 18 months to 30 September 2022 forpolitical purposes.

GRI 417: Marketing andlabeling 2016

417-3

Incidents of non-compliance concerningmarketing communications

See Commentary

To the best of our knowledge, there were no known material incidents of non-compliance with laws and regulations related to advertising, promotion,and sponsorship in the 18 months to 30 September 2022.

54 | ICGAM.COM

AR pg. 107
See Commentary
SPR pg. 36, 37

To the best of our knowledge, there were no known incidents of discrimination and harassment reported in the 18 months to 30 September 2022.
The Group’s approach to charitable giving is overseen by our Charity Committee, which was established in 2019 and includes an Executive Director among its
members. Alongside our continued financial support at Group level for selected charities showcased in this report, all ICG offices are encouraged to support
charitable initiatives of their choice that have young people and education as a focus. We also seek to match any money that our employees, across all our offices,personally raise for charities of their choice. For the year ending 30 September 2022, ICG contributed £2.47m to charities and charitable initiatives.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Operating purposefully

Further disclosures

GRI AND SASB CONTENT INDEX continued
GRI Topic specific disclosures – content index continued
GRI Universal Standards 2021
GRI Standard Title

Disclosure
Number

Disclosure Name

Location

Commentary

GRI 418: Customer
Privacy 2016

418-1

Substantiated complaints concerning
breaches of customer privacy and lossesof customer data

See Commentary

To the best of our knowledge, there were no known substantiated complaints concerning breaches of customer privacy and losses of customer datain the 18 months to 30 September 2022.

GRI 419: Socio-economic 419-1
compliance 201655 | ICGAM.COM

Non-compliance with laws and regulations See Commentaryin the social and economic area

To the best of our knowledge, there were no known incidents of non-compliance with laws and regulations in the social and economic area in the 18 months
to 30 September 2022. Nor were there found any breaches to our Group Code of Conduct in the same period.

Introduction

SUSTAINABILITY & PEOPLE REPORT 2022

Investing sustainably

Further disclosures

Operating purposefully

SUPPLEMENTARY CORPORATE DISCLOSURES INDEX
Governance

ICG’s Group Code of Conduct

For further information on our governance approach please find links to our Annual Reportalong with the relevant page listing.

The following topics are listed in the Group Code of Conduct which can be found on ICG’spolicies page on our website.

 
Annual Report https://www.icgam.com/shareholders/annual-reports/

Document

Chapter

ICG’s Annual Report Governanceand Accounts 2022
Managing Risk

 Group Code of Conduct https://www.icgam.com/who-we-are/leadershipgovernance/policies-disclosures/

Topic

Page
reference

Document

Chapter

Topic

Page
reference

Document

Chapter

Corporate governance andoversight

Pg. 67 to 92

Group Code of
Conduct

Purpose, Culture
and Value

Our purpose

Pg. 4Group Code of
Conduct

Risk management (managing,assessing, principal risks anduncertainties

Pg. 57 to 64

Our culture and values

Pg. 4

Acting in the best Responsible investing
interestsof clients

Grievance procedure andspeak up

Pg. 4

Compliance with laws andregulations

Pg. 6

Anti-bribery and corruption
(ABC)

Pg. 6

Anti-money laundering(AML)

Business Ethics
and Integrity

56 | ICGAM.COM

Topic

Responsible marketing andcommunication with clients

Page
referencePg. 10Pg. 10

Responsible product offering Pg. 10
Employment

Anti-harassment anddiscrimination

Pg. 11

Diversity and inclusion

Pg. 11

Pg. 6

Digital and social media

Pg. 11

Pg. 7

Occupational health andsafetyPg. 11Anti-trust and anticompetition behaviour

Flexible working

Pg. 12Insider dealing

Pg. 7

Cyber security

Pg. 13

Conflict of interest

Pg. 8

Political contributions

Pg. 8

PrivacyPg. 13

Confidentiality of information

Pg. 8
Pg. 8

Oversight of Codeof Conduct

Pg. 14

Human rights
Modern slavery

Pg. 8

Supplier management

Pg. 9

CompliancePg. 14Training

Pg. 14Cyber andPrivacy
Implementationand compliancewith the Code of
Conduct

SUSTAINABILITY & PEOPLE REPORT 2022

Introduction

Investing sustainably

Operating purposefully

IMPORTANT INFORMATION
For institutional/professional/
accredited investors only.
This document is being provided to
you by the subsidiaries or affiliates ofIntermediate Capital Group plc (“ICG”,
and together with their respective
directors, officers, employees, partners,
members, shareholders, advisers andagents, as the context requires, “the ICG
Parties”) on a strictly confidential basis andno part may be reproduced or redistributedin any form, by any means without theprior express written consent of ICG. This
document is intended only for information
purposes and convenient reference
and does not create any legally binding
obligation on any of the ICG Parties.
The ICG Parties expressly disclaim any
liability for the use, misuse, or distributionof this information to unauthorised
recipients. PAST PERFORMANCE IS
NOT NECESSARILY INDICATIVE OF
FUTURE RESULTS, AND THERE CAN
BE NO ASSURANCE THAT THE FUND
WILL ACHIEVE COMPARABLE RESULTS
OR THAT THE FUND WILL BE ABLE TO
IMPLEMENT ITS INVESTMENT STRATEGY,
ACHIEVE ITS INVESTMENT OBJECTIVES
OR AVOID SUBSTANTIAL LOSSES.
This document: (i) is not intended as anoffer or solicitation with respect to thepurchase or sale of any security or financial
instrument; (ii) is not to be relied uponin evaluating the merits of investing inany securities; and (iii) is provided solely
as reference material for background57 | ICGAM.COM

purposes. You should be aware thatinvesting in a fund sponsored by ICG (an“ICG Fund”) involves a high degree ofrisk, and there can be no assurance thatan ICG Fund’s investment objective will beachieved or that you will receive a returnon your capital. The possibility of partial
or total loss of capital from an investment
in an ICG Fund will exist and you must be
prepared to bear such losses. You should
refrain from investing in an ICG Fund unless
you fully understand all the risks involved
and you independently determine that theinvestment is suitable for you. ICG is notyour designated investment advisor.
ICG may encounter potential conflicts ofinterest in connection with the activities
of an ICG Fund. Please see the applicable
ICG Fund’s offering memorandum or
any other such similar documents for
additional information. A private offeringof interests in an ICG Fund may only bemade pursuant to the final confidential
private placement memorandum for thefund and any supplements (or any othersuch similar documents) thereto (the“Memorandum”) and the fund’s governingand subscription documents (together,
the “Offering Documents”), which may
be furnished to qualified investors on aconfidential basis at their request for theirconsideration in connection with suchoffering. The information contained herein
will be superseded by and is qualified inits entirety by reference to the Offering
Documents, which contains additional
information about the investment objective,

terms and conditions of an investment in
the fund and also contains tax information
and risk and conflict of interest disclosuresthat are important to any investment
decision regarding the fund. No person has
been authorized to give any informationor make any representations other thanas contained in the Memorandum and, if
given or made, any such information or
representation must not be relied upon as
having been authorized by the fund or anyof the ICG Parties. A prospective investor
should not invest in any fund interests
unless satisfied that it (alone or together
with its investment representative) has
asked for and received all informationthat would enable the investor (or both ofthem) to evaluate the merits and risks of the
proposed investment.
Although certain information has beenobtained from, and is based upon sourcesthat we consider reliable, none of the ICG
Parties guarantee its accuracy, and it may
be incomplete or condensed. All opinions,projections and estimates constitute thejudgement of the ICG Parties, as of thedate of the document and are subject tochange without notice. The ICG Parties
make no representation or warranty,
express or implied as to the fairness,correctness, accuracy or completenessof this document. The ICG Parties accept
no responsibility for any loss arising
for any action taken or not taken byanyone using the information contained
herein. This document is not to be relied
upon in substitution for the exercise of

independent judgment. ICG may haveissued, and may in the future issue, othercommunications that are inconsistent
with, and reach different conclusions
from, the information contained herein.
This document reflects the different
assumptions, views and analyticalmethods of the analysts who preparedthem and ICG is under no obligation toensure that such communications arebrought to the attention of any recipientof this document. Past performance
should not be taken as an indication or
guarantee regarding future performance,and no representation or warranty,
express or implied is made regarding
future performance. Moreover, certain
information contained herein constitute“forward-looking statements,” which
may be identified by the use of forwardlooking terminology such as “may,”“will”, “should,” “expect,” “anticipate,”“target,” “project,” “forecast,” “estimate,”“intend,” “continue” or “believe,” orthe negatives thereof or other variations
thereon or comparable terminology. Any
forward-looking statements or resultsin this presentation are based uponcurrent assumptions, may be simplified
and may depend on events outside
ICG’s control. Due to various risks anduncertainties actual events or results or
the actual performance of the fund may
differ materially from those reflected orcontemplated in such forward-looking
statements. Statements herein are madeas of the date hereof unless statedotherwise herein.

Further disclosures

INTERMEDIATECAPITAL GROUP PLC

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icgam.com