Standards Guidance
for the SDG Impact Standards
for Private Equity Funds

May 2022

1

Contents

Contents............................................................................................................................................................... 1
Standards Guidance .............................................................................................................................. 1
for the SDG Impact Standards for Private Equity Funds ...................................................................... 1
Introduction ........................................................................................................................................... 3
Note to Managers .................................................................................................................................. 4
General Guidance .................................................................................................................................. 8
Strategy ................................................................................................................................................ 10
Management Approach ....................................................................................................................... 33
Transparency ....................................................................................................................................... 69
Governance.......................................................................................................................................... 752

Introduction
PurposeThe Standards Guidance for the SDG Impact Standards for PE/Debt/VC funds (from now on “PEfunds”) provide additional information and detailed explanation of the Standards to:•••Help PE fund managers apply the Standards
Support more consistent understanding and application of the Standards across users (PEfund managers, assurers, and other users)
Ensure alignment with key reference frameworks, principles, and tools in the application of
the Standards

Using the Standards Guidance
The Standards Guidance should be used in conjunction with:•••

About the SDG Impact Standards
SDG Impact Standards for PE funds
SDG Impact Standards Glossary

Guidance is set out by practice indicator, generally at the individual practice indicator level andsometimes for several related practice indicators. Not all practice indicators are provided withadditional guidance.
The level of aspiration in the Standards is set in line with the changes UNDP believes are consistent
with achieving sustainability and the SDGs. They are provided as a best practice guide to show thedirection of travel and ultimate goals required.
The assurance framework will set out minimum thresholds required to be demonstrated by PE funds
to qualify to use the SDG Impact Seal. The minimum thresholds are based on the practice indicatorsin the Standards but set at a lower level to encourage participation and adoption. PE funds will alsoneed to demonstrate commitment to continuous improvement and progress towards best practicein line with the Standards to continue to meet the requirements to apply the SDG Impact Seal.

Education and training
User training on the SDG Impact Standards
The Standards Guidance is not user training. User training materials and programs tailored todifferent user groups will be available to support the adoption and implementation of the SDG
Impact Standards. Updates will be posted at https://sdgimpact.undp.org/.
Impact Measurement and Management for the SDGs
UNDP has partnered with CASE at Duke University’s Fuqua School of Business to develop a free online training course available through the Coursera platform called Impact Measurement andManagement for the SDGs. This is a foundational course covering concepts and frameworks related
to impact management. The course assists managers in developing the internal impact
management capabilities needed to implement the SDG Impact Standards successfully. You canaccess the training on the Coursera platform at https://coursera.org/learn/impact-for-sdgs.

3Note to Managers
Introduction
The SDG Impact Standards set out practice indicators across strategy, management, transparency,
and governance that increase the likelihood of having a positive contribution to sustainability andthe SDGs. This means improving the well-being of people and planet and recognizing that improving
people’s wellbeing includes protecting their human rights since any potential or actual change tothose will have consequences for their well-being.
The PE fund needs a strategy that embeds this purpose, a set of policies, management practices,
culture and incentives that are coherent and aligned with that purpose, and governance thatprovides effective oversight. This implies that the PE fund is making decisions, at all levels and at a
rate, that optimize that contribution and therefore the Standards are a decision-making framework
focusing on practices that drive performance and not on the performance.
That said, decision-making requires information to make decisions and so the PE fund will need tocollect data to inform decisions, and it will need to measure changes in aspects of well-being andestimate its own contribution towards those changes, or in other words its impacts. (Aspects ofwell-being may be social, environmental, or economic in nature). For transparency, this approachand performance should then also be disclosed to stakeholders.
The purpose of measurement is to provide information to inform decisions, where the purpose of
the decision is to make something better than it was. This means that decisions represent choices
between options. For the SDG Impact Standards, the purpose is to help PE funds increase thelikelihood of having a positive contribution towards sustainably and the SDGs.
The PE fund will make decisions to achieve a positive contribution based on information available.
So, we need to measure changes in aspects of people’s wellbeing, including environmental impacts.
In other words, we need to understand and estimate how the PE fund is impacting on people’s
wellbeing and the environment and how this could be changing as a result of the PE fund’s decisions
and actions.
Embedding impact into decision-making for a PE fund, requires a holistic approach that is applied at
the organization, portfolio and transaction levels:

To implement the SDG Impact Standards, the Standards and practice indicators have been organizedthough 12 Fund actions as follows:4

The 12 SDG Impact Private Equity Actions
STRATEGY

2. Understand3. Embed impact

4. Set goals

what’s important to Stakeholders andachievement of the SDGs, and where
the Enterprise is making impacts todetermine where material impact canbe made in the future

into purpose and strategy

in line with now integrated
purpose and strategy

MANAGEMENTAPPROACH

1. Commit
to operating responsibly andsustainably, contributing
positively to the SDGs, andoptimizing impact

7. Develop

6. Align

5. Adjust strategy

methodology, processes andsystems to effectively
measure impactsand
integrate into businessdecision-making

organization al cu lture,structure,capabilities, systems, andincentives with purpose andstrategy

and impact goals as needed
to optimize impact

10. Disclose

11. Integrate

12. Ensure

how responsible businesspractices, sustainability andcontributing positively to the SDGs
are integrated into decisionmaking and report on performance

responsible business and impact
management practices intogo vernan ce framework

governing body leads by
exampleGOVERNANCE

9. Embed
continuo us improvement,
updating impact management
practices as needed

TRANSPARENCY

8. Assesscomp are and monitor material
impacts over time, with externalbenchmarks and between stakeholder
groups and subgroups, generate
options for increasing impact andmake choices betw een options

The practice indicators are aligned to each business action and shall be used as guide to implement
each action (see About the Standards).

Prioritizing, measuring and managing the things that matter
When we act on the world there will be an infinite number of choices that generate differentchanges in well-being (outcomes), ranging from the immediate to the longer term, from ones thatare caused by our actions to ones to which our actions contribute, and including positive andnegative, intended and unintended changes (outcomes).
We can’t measure all of these, and not all of them matter equally for the decisions we need to taketo improve well-being and our contribution to the SDGs. In other words, we need to make sure wecollect information that is critical for taking the decision, considering whether not having theinformation (not measuring such changes in well-being) would change the decision. Indeed, there
are some changes that if we don’t measure, it won’t make any difference to the choices we make.
We’ll still pick the same option.
So, we need to prioritize all changes in aspects of well-being to those experiencing them. And there
will always be a risk that we get this wrong. In part we can filter based on expected changes in wellbeing. And then we can forecast the amount of change using metrics that we can subsequently
measure, and we can measure with different levels of rigor. Each step reduces the risk that we misssomething out that would have made a difference to our choice.
The bigger the difference between the choices, the lower the risk, the less we need to worry. But
the biggest risk comes at the start, the risk we miss things out at the start, and so do not forecast the5amount of change in aspects of well-being that we should have included. There are many
psychological traps here but stakeholder involvement and testing for completeness of any changes
in well-being for all stakeholders, especially for negative changes (outcomes) is designed to reduce
the risks of these traps.
In forecasting the amount of change, we will get quantitative data that will both inform our decisionof what matters and allow us to assess our performance in creating change, creating change as
effectively as possible with the resources we have. We also need to recognize that positive change is
not any change in the right direction. It’s a change above a minimum threshold set by a mix ofscience, stakeholder expectations and social norms.

Using information to generate options and make decisions
We also need data that will give us insights that lead to these options from which we can choose.
Limiting our data risks excluding data that matters because it creates these insights. What matters is
not just about matters to the decision, it is also what matters to create insights that lead to options
that lead to decisions.
There are more psychological traps, for example, that we tie ourselves up with our purpose. Again,
stakeholder involvement and testing for completeness, especially of our non-intended positivechanges (which may be our stakeholder intended changes) is designed to reduce the risk of thesetraps.
Although stakeholder involvement is critical to identifying the things we should measure, it is notenough. The SDGs are the set of things that we should also consider irrespective of the results ofinvolving stakeholders, and for these Standards, there are four which always matter – inequality(“leaving no-one behind” is the overarching goal of the SDGs), and gender equality, climate action
and decent work (including as cross-cutting goals of all others).
As a result of stakeholder involvement and assessment of the SDGs, including the four above, we willthen have a set of expected positive and negative material impacts, and our options will include
different subsets of these which will be experienced by different people. In choosing between thesesets of expected material impacts we need to know some things. For each expected change we needto know: what is the change, who is affects, how deep the change is, against both a starting point
but also against minimum thresholds; how long it lasts; how much was caused by us – but taking
care here as if others contributed to it, it may still matter, it’s just that we should be working withthose others; how many people were affected; and what are the characteristics of those people.
And these will give us the ability to quantify and aggregate each impact.
It will also give us the ability to assign people to groups based on characteristics – the most common,and the ones we generally consider, are grouping people as customers or investees, suppliers,
investors, and employees – although of course people can be more than one of these, and although,of course these types are not really a consistent taxonomy, or even complete, if we miss out theowners.
But by themselves this is just a list of aggregated expected impact for groups of people depending on
how we have grouped them (and who decides this?). Choosing between options requires us to havea normative position on which we think is better. Most of the time the decision maker does thisbased on their preferences, their own prejudices, and all those other psychological traps. We almost
may not have bothered with all that measurement.

6

We need some information on the relative preferences for these different expected impacts fromthe perspective of the people that will experience them – in finance this is money – a proxy for thechange in wellbeing people expect to get from their purchases. For other changes in well-being, weneed another way to quantify these relative preferences recognizing that this is reducing the risk ofmaking the wrong decision, but it is not removing that risk.
Now we can make decisions on what matters informed by the quantified expected value of impacts.
But just because this is low doesn’t mean it doesn’t matter. We can include things that have low
expected value, but we can’t exclude things that have a high expected value.
We have raised the issue of proxies or approximations. Approximations are both approximations of
the amount of change, as soon as we don’t measure change for everyone or use a measurement
approach that doesn’t precisely measures the thing we want to measure, we are approximating – sothat’s always. Approximations may also be of the thing we want to measure. We might use outputs
as a proxy for the aspects of well-being. This might be supported by scientific research that there is astrong causal link. Unfortunately, this is not so useful in choosing between different options if the
purpose is to increase well-being. It is only good for choosing between different options if the
purpose is to increase outputs.
But often we find ourselves in a situation where we only have outputs, and yet we have to make achoice (ignoring the situation where we are not going to make a decision, and neither is anyone else,
but we have spent time collecting and reporting this nonetheless). And now the risk that we makethe wrong choice, or we would have made a better choice, has gone up.
The biggest risk is that our goal and purpose, considering what problem we are trying to solve issuboptimal. But then we make choices about how we are going to achieve that goal or purpose, andhow much of it we try and how we do it, making choices about the design of products and services,
choices about how they are packaged and delivered, and choices about how this is financed,
resourced, and supported. In all of these we need to understand the risk, seek to stop the cause of
the risk, or subsequently seek to reduce the consequences of that risk.

Making decisions in an imperfect world
This is all very well but not realistic in practice. We won’t have all this data. And our risk will behigher than it could be. But that doesn’t mean we can’t make decisions. And the risk that what weare doing now isn’t addressing a meaningful goal hasn’t gone away. And we know we are not
identifying options and making choices to contribute to sustainability and the SDGs at the rate weneed, that people’s well-being is not being improved at the rate they should expect, that people’s
human rights are being abused.
We need to get on and be more critical of our strategies and then be willing to accept a level of risk.
And our risk assessment needs to consider the risk of the wrong choice to those that experience thechanges in their well-being. And to recognize that their risk tolerance is low. Which gives you, themanager, a conundrum. Caught between the need to have data to reduce the risk of making a
suboptimal decision, and the need to work with what data you must reduce the risk of inertia.
The solution is continuous improvement in your approach to measuring and managing impact. And
setting ambitious and rigorous goals for both your expected impact and for that improvement. A mix
of these, an understanding that sustainable development means increasing people’s well-being andan understanding of what measuring that for decision making means, a recognition of the risk
involved in deciding and risk in not making decisions, and an ambitious plan to improve is what willmeet the requirements of the SDG Impact Standards.
7

The SDG Impact Standards for PE funds and this guidance are designed for a manager making thesedecisions, in an imperfect and uncertain world.

GENERAL GUIDANCE
SDGs and Impact
The SDG Impact Standards address both the SDGs and Impact. These are linked concepts, but not
the same.
The 17 SDGs (and associated targets and indicators) set out an ambitious plan – as part of the 2030
Sustainable Development Agenda – to address critical issues affecting people and planet. The SDG
framework is already being widely referenced, adopted, and increasingly integrated into both public
and private actors’ organizational systems, reporting and decision-making. While the SDGs, and theinitial targets and indicators use 2030 as their reference point for achievement, the overarching
structure and the frameworks and infrastructure being built around the SDGs will endure wellbeyond 2030. The Standards have been designed to be timeless, with Standard users’ able toincorporate advancements in frameworks (including the SDGs), tools and their own and collective
understanding over time.
The SDGs are not mutually exclusive, and they overlap and interrelate. For example, SDG 4 (quality
education) also needs to be considered in all the other SDGs and performance in SDG 17(partnerships for the goals) will increase performance in other SDGs. They are also an internationalframework to provide a summary of sustainability issues. The SDG indicators are designed to show
progress at that international level in order that national governments can take corrective action tomeet the goals.
The material impacts that contribute to the well-being of people and the planet and which therefore
also contribute to sustainability are experienced by people because of the operations of an PE fund.
Although they may be aligned to an existing SDG, they may require different indicators to measure
the specific change in well-being the PE fund is affecting or seeks to influence. Those specificindicators will be helpful to better inform decisions to make a positive contribution to the SDGs.
Equally stakeholder engagement may not identify all the impacts that are material to sustainable
development and addressed in the SDGs.

Impacts and dependencies
The Standards focus on how an PE fund defines and identifies material sustainable development
issues and manages – and optimizes – its impacts on sustainable development and the SDGs. For the
purpose of these Standards, material sustainable development issues are those that relate tooutcomes that are important to the Stakeholders experiencing (or likely to experience) them,
important to sustainable development and achieving the SDGs by 2030, where the PE fund can make(or is making) the most significant (positive and negative) impacts on important outcomes and take
into account the sustainability risks and opportunities that are most significant for the PE fund’s own
value creation (i.e. its dependencies), because strong, resilient and sustainable PE funds will havemore capacity to contribute positively to sustainable development and the SDGs.
This means that good impact management necessarily requires the management of both the PE
fund’s impacts on people and planet and its dependencies on the world around it. Good impact
management will help PE funds manage and reduce their sustainability dependency risks and8capitalize on opportunities, however managing dependencies alone will not always lead to positive
outcomes for sustainable development and the SDGs.

ESG vs SDG Impact
Current approaches to incorporating environmental, social and governance (ESG) factors intobusiness and investment decision making are grounded in existing risk management mechanisms themarket has used for decades to protect financial value. However, these approaches are insufficient –and no longer future-fit – for businesses, investors, or society to contribute to sustainability (where
sustainability includes making financial returns) and achievement of the SDGs at the pace the planet
and the people need it.
The SDG Impact Standards have been designed to fill the gaps in current market practices that areundermining progress towards sustainability and achieving the SDGs – and which ultimately threaten
economic and financial system stability which PE funds depend on to survive and thrive. As theStandards focus on managing the PE fund’s material impacts – which also necessitates managementof its dependencies – and have a strong focus on responsible business practices and governance,
ESG is fully encapsulated within the Standards.

SDG 10 – Inequality – the overarching theme of “leaving no-one behind”
Addressing inequality and “leaving no-one behind” is an overarching objective of the SDGs and theseStandards. Creating more inclusive business models that engage base of the pyramid populations in
supply and value chains not only provides opportunity for better social outcomes but can reducesustainability risks to the business and create business opportunities to meet the needs of previously
underserved populations.
While gender equality, climate action and decent work are treated as cross-cutting goals in theseStandards, inequality and “leaving no-one behind” is overarching, and all actions and decisions
should be viewed through this lens. In particular, in terms of managing for more inclusive andequitable outcomes, a focus on making inequality more visible so it can be more effectively
managed is key. Many of the practice indicators in the Standards have been designed to help users
do this – for example, by involving Stakeholders in decision-making and disaggregating data toensure the needs of different Stakeholder groups and minority sub-groups are visible and not lost in
the process of averaging.

9

STRATEGY
Guidance Note 1.1. The Fund develops an impact thesis (or theses), embedding
contributing positively to sustainable development and achieving the SDGs in its
purpose and strategy.
Guidance Note. 1.1.1. The Fund determines how it intends to contribute positively tosustainable development and achieving the SDGs, including by engaging with therelevant local and national sustainable development context(s) and embedding
respect for human rights and other responsible business practices in its approach
Making sustainability and the SDGs central and contributing positively
Making sustainability and the SDGs central means that sustainability and the SDGs are not just an
add on. They become central and are embedded in the PE fund’s purpose and how it creates value
for itself and society (people and the planet). The lens shifts from a focus on the investee potential
and actual performance but to its management practices and commitment to contribute tosustainable development and the SDGs. In so doing, human well-being and long-term business andfund performance (including sustainability and resilience) can be optimized. Stakeholder
expectations and the requirements for sustainable development overlap and will drive purpose,
strategy, and impact goals of both the investee and the fund.
The Better Business Better World report of the Business & Sustainable Development Commission(Jan 2017) describes incorporating the SDGs into organizational strategy as follows: “…. That means
applying a Global Goals lens to every aspect of strategy: appointing board members and senior
executives to prioritize and drive execution; aiming strategic planning and innovation at sustainable
solutions; …; and using the goals to guide leadership development, women’s empowerment at every
level, regulatory policy, and capital allocation. Achieving the Global Goals will create 380 million newjobs by 2030. You need to make sure your new jobs and any others you generate are decent jobs
with a living wage, not only in your immediate operations but across your supply chains anddistribution networks. And you need to help investors understand the scale of value thatsustainable business can create.”(https://sustainabledevelopment.un.org/content/documents/2399BetterBusinessBetterWorld.pdf )Contributing positively
Through its investment, a PE fund will have indirect positive and negative impacts on stakeholders. A
positive impact is a positive change in the level of an impact experienced by a stakeholder above aminimum threshold. However, the starting and ending point for that change can be below thatthreshold. Something is good but can still get better. Some that are bad can get better but still bebad.
A positive contribution is made taking all the positive and negative material impacts experienced bypeople and the planet because of the operations of an organization or portfolio the PE fund isinvesting in. Positive impacts are then those that reach a minimum threshold set considering, and attimes making a judgement about a mix of, planetary thresholds, scientific targets, and stakeholder
requirements. Although this is a minimum, the Standards require ambitious and rigorous targets tomaximize impact, and set at the level of each expected impact, so that the positive change incontribution is being made at a rate commensurate with planetary thresholds, scientific targets,10

stakeholder expectations as well as SDG targets – and considering variations in impact within andacross Stakeholders and sub-groups with a view to “leaving no-one behind”.
Whether or not a positive contribution is being made, the challenge is that decision making should
be increasing the contribution. Where the contribution is already above these thresholds this is lessof a challenge, although the need for targets to be ambitious and rigorous remains. Accountability tothose experiencing the impacts would still require performance to be maximized. Maximized means
maximized subject to existing constraints. But constraints can also be changed, whether these arethrough capacity, capability, partnerships, or creativity and innovation.
Nonetheless the challenge is greater for an PE fund that has investments in companies that are
currently making a negative contribution or if considered positive overall, still has material negative
impacts.
This raises the challenge of considering impacts in the whole, taking positive and negative impacts,
recognizing that not all impacts are equal. Net impact implies quantification including valuation, andvaluation would need to consider values in relation to thresholds and planetary limits. Even where
there is thought to be more positive impacts than negative impacts, the focus for allocating
resources would be on reducing negative impacts before further increasing positive impacts.
The other challenge for PE funds is that impact is expected to occur through its investments but notdirectly. Indeed, the fund can have a direct effect though financial additionality and/or non-financial
support for the investee where the investee would not have been able to access such financing(type, amount, conditions, etc.) or technical support otherwise and this is critical for the delivery of
its impact goals. Depending on the investments, funds could also be part of the investee decisionmaking process.

Interdependency
The SDGs are interconnected, integrating economic, social, and environmental targets. Changes in
one outcome can affect other outcomes directly or indirectly, intentionally, or unintentionally,
positively, or negatively. A lack of progress on one goal can also hinder progress on others, forexample, the relationship between inequality and climate action.
Consequently, impacts need to be considered holistically to understand how actions in one area
might affect other areas, to understand the overall impact being created, and to avoid unintended
negative impacts and consequences. PE funds shall consider how their investees consider and makedecision around interdependencies and positive net impacts.
REFERENCE FRAMEWORKS
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed toachieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
Impact Management Project (IMP), five dimensions of impact, provides guidance on the types of data needed tounderstand and assess impact performance. The IMP community of 2,000+ practitioners identified fivedimensions of impact, which can be broken down into 15 more detailed data categories. Organizations can use
the five dimensions as a checklist to ensure the information gathered is sufficient for the decision it will inform11

(see also the ABC methodology and SDG Impact Standards Glossary).
https://impactmanagementproject.com/impact-management/how-PE funds-manage-impact/ and Five
Dimensions of Impact (Impact Management Norms), https://impactmanagementproject.com/impactmanagement/impact-management-norms/
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 1: SDG IMPACT THESIS AND
MEASUREMENT, “Business should develop a specific SDG impact thesis, which maximizes their unique capabilities
and assets, promotes the most effective private-sector solutions to sustainable development and is updated or
expanded over time”; “Align impact thesis with countries’ own needs and priorities for SDG investments (climate
and SDG gap analyses and investment plans), and where relevant, focus on priority sectors in less developed
markets, considering the unique characteristics of each market, and respecting a common but differentiatedapproach to the sustainability transition.”; Principle 2: INTEGRATED SDG STRATEGY AND INVESTMENTS, “Adopt
investment criteria and decision-making processes based on SDG impact, alongside financial risk and returninvestment criteria”
UNEPFI Principles for Positive Impact Finance, Definition, Principle 1: Positive Impact Finance is that which serves
to finance Positive Impact Business. It is that which serves to deliver a positive contribution to one or more of thethree pillars of sustainable development (economic, environmental, and social) once any potential negative
impacts to any of the pillars have been duly identified and mitigated. By virtue of this holistic appraisal ofsustainability issues, Positive Impact Finance constitutes a direct response to the challenge of financing the
Sustainable Development Goals (SDGs).
UNEPFI Principles for Responsible Banking, Principle 1: Alignment – We will align our business strategy to beconsistent with and contribute to individuals’ needs and society’s goals, as expressed in the Sustainable
Development Goals, the Paris Climate Agreement and relevant national and regional frameworks.
Positive Impact Finance Principles (United Nations Environment Programme Finance Initiative, UNEPFI)
acknowledge the interconnectedness of sustainability issues and therefore base themselves on a global
assessment of positive and negative impacts rather than on the singling-out of sectors, recognizing some sectors
are in and of themselves carriers of positive impact but no sector is devoid of potential negative impacts andmost sectors arguably carry at least some positive impact for one or the three main pillars of sustainable
development.
Capitals Coalition Natural and Social and Human Capital Protocols, and Principles of Integrated Capitals
Assessments outlines a process that organizations should follow to identify, measure and value their impacts anddependencies on the natural environment and on social and human capital respectively including developing
integrated thinking and decision-making capabilities through application of the Protocols.
OTHER RESOURCES:
SDG Action Manager (developed by B Lab and the United Nations Global Compact), is an online tool for
exploring how an PE fund’s operations may relate to the SDGs. Based on geography and industry, an PE fund can
get a view into the positive impacts created by their operations, supply chain, and business model and the risk
areas for each SDG. The SDG Action Manager also enables an PE fund to set goals and track improvement.
https://bcorporation.net/welcome-sdg-action-manager
SDG Compass Guide (developed by UN Global Compact, GRI, and WBCSD) provides guidance for companies on
how they can align their strategies as well as measure and manage their contribution to the realization of theSDGs https://sdgcompass.org/
SDG Ambition Benchmark Reference Sheets (developed by the United Nations Global Compact) provide
illustrative details on the steps a company can take to integrate actions related to achieving the SDGs into its
business systems. As of this recording, there are at least 10 reference sheets covering topics such as Gender
Balance Across All Levels of Management, Zero Discharge of Hazardous Pollutants and Chemicals, and 100% of
Employees Across the Organization Earn a Living Wage. https://unglobalcompact.org/library/5790

12

The SDG Industry Matrix, developed by the UN Global Compact and KPMG, reviews likely SDG intersections for 7
different industries. https://www.unglobalcompact.org/library/3111

13

Guidance note 1.1.2. The Fund develops an impact thesis, or theses (see Impact
thesis) specifying:
1.1.2.1 the SDG and/or other sustainable development outcome areas it intends totarget1.1.2.2 the type of impact it intends to achieve (see ABC Impact Classifications)1.1.2.3 set in context of its impact risk appetite and tolerance (see Impact risk)
Understanding the sustainable development context
When setting the fund impact goals and priorities, evidence and relevant social and scientific datafrom reputable agencies such as government, scientific, community and civil society organizations
should be taken into account to better understand the sustainable development context(s) the PE
fund is/ plans to be operating in.
It is important that this information is:•

Relevant to the people experiencing the impacts. International research or research with asimilar group of people but in a different context, that aggregates different groups of people
together (such that needs of disadvantaged or marginalized groups are masked), or that
excludes certain groups may not be relevant and its use may increase the risk of making suboptimal decisions. Therefore, data should be sufficiently disaggregated (i.e., segmented) for
decision-making, especially regarding excluded or disadvantaged groups. Inclusive data sources
may need to be expanded over time to counter for the shortcomings in currently available data
sets and factors which might inadvertently compound disadvantage or discriminatory
approaches.

•

Timely and up to date, especially as the sustainable development context and our understandingof it is changing rapidly.

•

Supported by meaningful stakeholder engagement (taking into account stakeholders along the
PE fund’s whole supply and value chain, its products and services) and does not supplant thatengagement either in selection of potential impacts or in design of products and services tocreate impacts without documented reasons – and therefore informed by 1.1.5.

The Sustainable Development Goals (SDGs)
The 2030 Sustainable Development Agenda and SDGs call on all businesses to apply their creativity
and innovation towards solving sustainable development challenges. This includes exploring
different business models and new ways of working – including collaborating and partnering with abroader range of actors and constituents than in the past to achieve the SDGs, being moreconnected across the system, and looking for opportunities to target activities where sustainable
development needs are greatest and aligned with in-country policy priorities.
Sustainability and achieving the SDGs is a shared accountability that requires all actors across thesystem to work together in realizing the SDGs. The SDGs help to break down silos between different
actors and geographies – creating space and opportunities for new ways of working towards
solutions around a common purpose and shared goals and targets (see also 1.1.7).
REFERENCE FRAMEWORKS:

14

United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed toachieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 1: SDG IMPACT THESIS AND
MEASUREMENT, “Align impact theses with countries’ own needs and priorities for SDG investments (climate and
SDG gap analysis and investment plans), and where relevant, focus on priority sectors in less developed markets,considering the unique characteristics of each market, and respecting a common but differentiated approach to thesustainability transition”; Principle 2: INTEGRATED SDG STRATEGY AND INVESTMENTS, “Adopt investment criteria
and decision-making processes based on SDG impact alongside financial risk and return investment criteria.”;
Principle 3: INTEGRATED CORPORATE SDG FINANCE, “Leverage blended finance from governments, development
finance institutions, philanthropic foundations and impact investors to de-risk or subsidize corporate investments fortechnologies, sectors and geographies that are critical for the SDGs by currently underfunded.
UNEPFI Principles for Responsible Banking, Principle 4: Stakeholders – We will proactively and responsibly consult,engage, and partner with relevant stakeholders to achieve society’s goals
OTHER RESOURCES:UNDP SDG Impact Investor Maps are a market intelligence product produced by UNDP Country Offices andpartners to help private investors (funds, financiers, corporations) identify investment opportunities and businessmodels that have significant potential to advance the SDGs in specific country or regional contexts.
https://sdginvestorplatform.undp.org/
Sustainable Development Knowledge Platform https://sustainabledevelopment.un.org/vnrs/ which houses
information on countries’ sustainable development voluntary national reviews.

Determining Materiality
Determining materiality means identifying the issues that matter to a user for making decisions witha specific purpose. For the SDG Impact Standards: the issues are impacts and the users are thoseexperiencing the impacts to their well-being or those required to act in their interests that result
from an organization’s work; the decision is to provide resources to organizations or, withinorganizations, to produce products and services; and the purpose is to contribute positively tosustainability and the SDGs to maximize the well-being of people and planet.
Where the purpose of the PE fund, the purpose of the investee, the requirements for sustainable
development and the impacts that matter to those that experience them are aligned there is noconflict (1.2.1). Where the purpose of the PE fund and/or the investee is not aligned there is a riskthat the investee identifies material issues but then focuses on a subset that are deemed to matterto the investee, often on its ability to generate cashflows for investors. Nonetheless corrective
action is possible both at the investee and the fund levels:-

the investee may have a plan for how it changes its business model, strategy, or operations
to the point where its approach to materiality is aligned. So long as the Fund encourages theinvestee to act and to have plans that are ambitious and rigorous (2.2.1), and the investee

15-considers the increased risk of making decisions that are not optimal, the PE fund can meetthe requirements of the Standards.
If the investee does not act nor considers impact risks, the fund can reconsider its
investment and adjust accordingly, and still meet the requirements of the Standards.

However, the requirement for sustainability to be central (1.1.1) and for positive contribution toconsider what matters from the perspective of those that experience the impacts (1.1.4) means thatapproach would not be consistent with the Standards.
There are three points at which judgements are made that result in the understanding of material
impacts where the risk of missing impacts must be considered:•••

The initial identification of stakeholders as the impacts experienced by
The engagement with those stakeholders to identify potential material impacts (relevant) which
would include consideration of the SDGs
The assessment of the significance to determine a final list of expected material impacts

The approach should be designed to result in a complete list of stakeholders and the impacts thatmatter to them as a basis for making decisions alongside this plan. The objective is to reduce the riskthat impacts are missing that would change decisions being made to increase well-being, and socovers the approach to stakeholder engagement (1.1.5), the checks to ensure that potential impacts
are being identified through that engagement, including these in the Impact Thesis and Strategy(1.2.3 and 1.2.5)) and recognizing trade-offs in decision-making are inevitable (2.2.5). This should
also include an assessment of the PE fund’s relative capabilities and ability to deliver impacts thatmatter to stakeholders both efficiently and effectively (acknowledging that PE funds can decide tochange their capabilities to meet stakeholder requirements).
Whether or not a potential impact is material depends on subsequent measurement (2.1.6) and soan PE fund starts with expected material impacts which is refined over subsequent measurement
cycles. This means the initial effort is higher and in subsequent cycles, where materiality judgements
have been made based on data, a less frequent check to confirm would be adequate to meet risk
tolerance.
The fund can also use predetermined lists of sector level material impacts which can help, but overreliance on this increases the risk that impacts are missing and that decisions will not be optimal (therisk of this happening increases if the sector level resources are based on a more narrow or different
definition of materiality than is applied in the Standards).
Inequality (overarching) and gender equality, climate action and decent work are always material(1.2.2 – cross cutting goals).
REFERENCE FRAMEWORKS:
Social Value International (SVI) Principles of Social Value, Principle 3: Value what matters – “Making decisions
about allocating resources between different options needs to recognize the values of stakeholders. Value refers
to the relative importance of different outcomes. It is informed by stakeholders’ preferences”
https://socialvalueint.org/wp-content/uploads/2019/11/Standard-on-applying-Principle-3-Value-the-Things-thatMatter-FINAL.pdfm
Social Value International (SVI) Standard for applying Principle 3: Value the things that matter – guidance to value
impacts from the perspective of affected stakeholders, emphasizing the importance of using data collected
directly from stakeholders.

16Social Value International (SVI) Principles of Social Value, Principle 4 – “Determine what information and evidence
must be included in the accounts to give a true and fair picture, such that stakeholders can draw reasonableconclusions about impact”.
Social Value International (SVI) Standard for applying Principle 4: Only include what is material – “Determine what
information and evidence must be included in the accounts to give a true and fair picture, such that stakeholders
can draw reasonable conclusions about impact”. https://socialvalueint.org/social-value/standards-andguidance/standard-applying-for-principle-4-only-include-what-is-material/
Social Value International (SVI) Principles of Social Value, Principle 8: Be Responsive – (work in progress) “making
decisions that optimize value for all stakeholder groups materially affected. Consideration of risks and rigour ofdata in context of decisions being made”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 1: SDG IMPACT THESIS AND
MEASUREMENT, “Identify and mitigate “significant negative impacts on relevant SDGs, based on an analysis of
the corporate portfolio and the supply chain and benchmarked against impacts generally associated withcomparable assets, activities, or operating contexts”; “Align impact thesis with countries’ own needs and priorities
for SDG investments (climate and SDG gap analyses and investment plans), and where relevant, focus on priority
sectors in less developed markets, considering the unique characteristics of each market, and respecting acommon but differentiated approach to the sustainability transition”.
OTHER RESOURCES:
SDG Action Manager (developed by B Lab and the United Nations Global Compact) has been designed to help
users learn which SDGs matter most based on PE fund profile, get a clear view of how the PE fund’s operations,
supply chain, and business model create positive impact, and identify risk areas for each SDG.
The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The
identification phase of the Tools’ workflow helps users identify their most significant impact areas based on thenature of their business and the sustainability needs of the countries in which they operate. The Tools have inbuilt sector mappings which consider positive and negative impacts of business sectors and activities on specificsustainability topics and needs mappings which provide data on global and country specific sustainable
development needs from various global
SDG Industry Matrix, developed by the UN Global Compact and KPMG, which reviews likely SDG intersections for
7 different industries
Impact Beacon, developed by Citylight Capital, which helps an PE fund define the sectors, issues, impact areas,
and outcomes they want to influence, and suggests which SDGs match. Initial industries include environment,
education, and safety and care, and others will be added over time.

17

Guidance note 1.1.3. The Fund links its purpose and strategy with its impact thesis ortheses (and its impact risk appetite and tolerance), including:
1.1.3.1 demonstrating compatibility with its investment strategy (including its financial
return targets and its financial risk appetite and tolerance)
No additional Guidance is needed
REFERENCE FRAMEWORKS:
IMP ABC Classification. The IMP has developed a set of impact classes that group investments based on theirimpact characteristics. https://impactmanagementproject.com/investor-impact-matrix/
SDG Investor Platform. https://sdginvestorplatform.undp.org/
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed toachieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 1: SDG IMPACT THESIS AND
MEASUREMENT, “Align impact thesis with countries’ own needs and priorities for SDG investments (climate and
SDG gap analyses and investment plans), and where relevant, focus on priority sectors in less developed markets,considering the unique characteristics of each market, and respecting a common but differentiated approach tothe sustainability transition”.
The Fundamental Principles of Official Statistics (General Assembly resolution 68/261) – where feasible, data
should be disaggregated (i.e., segmented) by income, sex, age, race, ethnicity, migratory status, disability andgeographic location, or other characteristics pertinent to the PE fund’s impact goals.
OTHER RESOURCES:UN Sustainable Development Knowledge Platform https://sustainabledevelopment.un.org/vnrs/ contains thesustainable development goals, targets and indicators and information from the Voluntary National Reviews ofprogress towards achieving the SDGs conducted by member states.
UN Stats - SDG Indicators Database https://unstats.un.org/sdgs/indicators/database/ provides access to datacompiled through the UN System in preparation for the Secretary-General's annual report on "Progress towards
the Sustainable Development Goals" that can be used to identify areas of need in relation to specific SDG targets
by SDG indicator.
The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. Organizations
can use the Tools to identify areas of need in relation to specific sustainability topics. The Tools incorporate dataon sustainable development needs from various global and regional databases.

18

UNDP SDG Impact Investor Maps are a market intelligence product produced by UNDP Country Offices andpartners to help private investors (funds, financiers, corporations) identify investment opportunities and businessmodels that have significant potential to advance the SDGs in specific country or regional
contexts. https://sdginvestorplatform.undp.org/
OECD Statistics is a database of OECD’s publicly available statistics that can be used to identify areas of need inrelation to specific sustainability topics. Especially useful for organizations designing business models to meet theneeds of a group of people or the natural environment.
World Bank Data is a database of the World Bank’s publicly available statistics that can be used to identify areasof need in relation to specific sustainability topics. Especially useful for organizations designing business models
to meet the needs of a group of people or the natural environment.
Better Business Better World: The report of the Business and Sustainable Development Commission, January 2017https://sustainabledevelopment.un.org/index.php?page=view&type=400&nr=2399&menu=1515
IFC’s Environmental and Social Performance Standards which define IFC clients' responsibilities for managing theirenvironmental and social risks and can be applied by other organizations to manage ESG risks(https://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/Sustainability-AtIFC/Policies-Standards/Performance-Standards)
The Equator Principles (EPs) is a risk management framework, adopted by financial institutions, for determining,assessing and managing environmental and social risk in projects and is primarily intended to provide a minimum
standard for due diligence and monitoring to support responsible risk decision-making https://equatorprinciples.com/about/352/
Sendai Framework for Disaster Risk Reduction (Sendai Framework) provides Member States with concrete actions
to protect development gains from the risk of disaster. It works hand in hand with the other 2030 Agenda
agreements, including The Paris Agreement on Climate Change, The Addis Ababa Action Agenda on Financing forDevelopment, the New Urban Agenda, advocating for the substantial reduction of disaster risk and losses in lives,
livelihoods and health and in the economic, physical, social, cultural and environmental assets of persons,businesses, communities and countries.

Guidance Note 1.1.4. The Fund specifies how it intends to establish and promotealignment of interests among general and limited partners, Investees and other
Stakeholders.
As Funds do not have access to the investees’ stakeholders, funds are advised to encourage and setalignment and incentives for investees to engage stakeholders in decision making around theidentification of the most material impact, settings goals, monitoring, reporting and theidentification of lessons learned.

Stakeholder identification
Stakeholder identification should differentiate between people and organizations that experience
impacts and people and organizations that contribute to those impacts. Stakeholders includes bothcurrent Stakeholders and potential future stakeholders, including currently excluded sub-groups andstakeholders along the whole investee supply and value chain, its products and services.
Stakeholder identification should consider the appropriate level of disaggregation for use in theimpact thesis and in design and development of products and services recognizing that these arelikely to be different.
19

Stakeholder engagement/involvement plan for those experiencing impacts
Stakeholder engagement should be designed to reduce the risk that material impacts (both current
and potential future impacts identified based on what matters to stakeholders and achievement of
the SDGs) are not identified to an acceptable level. This includes making sure that:•the engagement is appropriate and inclusive for different stakeholders.

•the approach to identifying potential impacts is open and results have been documented.

•

the risk of bias from the person conducting the engagement is recognized and minimized, forexample there is a risk of explaining away or not recording negative impacts, or differences
between stakeholders and those conducting the engagement.

•

Risk of unintended or perverse consequences of the approach has been considered.

The initial assessment is likely to be more demanding and time consuming than in future
measurement cycles. A risk-based approach can be taken to the frequency and extent to stakeholder
involvement by stakeholder, allowing for changes in the sustainability context and in thecharacteristics of the stakeholder group.
REFERENCE FRAMEWORKS:
Social Value International, Principles of Social Value: Principle 1 Involve stakeholders – “inform what getsmeasured and how his is measured and valued in an account of social value by involving stakeholders (the people
who experience change as a result of your activity”.
Social Value International “Standard on applying Principle 1: Involve stakeholders” explains options and processes
for identifying stakeholders and meaningfully engaging stakeholders, including sample questions to ask, andcollecting information to help shape strategy and objectives. This Standard talks about how speaking to andinvolving people who experience change is an essential part of the process. But it also acknowledges thatspeaking directly to stakeholders is not the only source of relevant information. Third party research may becomplementary to what you hear from stakeholders or may be a substitute if your stakeholders are particularly
difficult to reach, or if they do not feel comfortable sharing their opinions. https://socialvalueint.org/wpcontent/uploads/2019/03/Standard-on-Stakeholder-Involvement-V2.0-FINAL-1.pdf
Capitals Coalition Natural and Social and Human Capital Protocols provides guidance on how to identify andengage with stakeholders in order to set objectives for a natural and social and human capital based assessment
respectively (see Step 02).
Office of the United Nations High Commissioner for Human Rights, Free and Prior Informed Consent for
Indigenous Peoples,
www.ohchr.org/Documents/IssueFree_and_prior_informed_consent_for_indigenous_peoples/Peoples/FreePrioran
dInformedConsent.pdf
UNEPFI Principles for Responsible Banking, Principle 4: Stakeholders – We will proactively and responsibly consult,engage, and partner with relevant stakeholders to achieve society’s goals.
OTHER RESOURCES:
OECD Directorate for Financial and PE fund Affairs, Guidelines for Due Diligence and Stakeholders Engagement in
Investments, https://www.oecd.org/fr/daf/inv/
British Standards Institution, BS 8950 Social value – Understanding and enhancing – Guide (Draft, 2020)20

Maximise Your Impact, A guide for social entrepreneurs (developed by Social Value UK) – guidance to help anorganization maximize its positive social value by engaging stakeholders and understanding their objectives andneeds in order to design a business model around delivering those objectives.
The Accountability Council, https://www.accountabilitycounsel.org/wp-content/uploands/2018/08/6-27-16-amsbenefits-and-best-practices_short.pdf
The Kampala Principles on Effective Private Sector Engagement, http://www.oecd.org/dac/effectiveness/KampalaPrinciples-on-effective-private-sector-engagement-development-cooperation.pdf
The OECD Blended Finance Principle 3, http://www.oecd.org/dac/financing-sustainable-development/blendedfinance-principles/principle-3/P#_Guidance_Note.pdf
Tri Hita Karana (THK), Impact Working Group Checklist for Assessing the Impacts of Blended Finance on the Poor,
https://www.thkforum/org/project/a-checklist-for-assessing-the-impact-of-blended-finance-on-the-poor/

Guidance note 1.1.5. The Fund ensures the magnitude (i.e. scale and/or depth) of theintended impact is commensurate with the size of the Fund
No additional guidance is needed.

Guidance Note 1.1.6. The Fund determines the resources it intends to allocate as partof its overall strategy.
Adequate resourcing
Integrating sustainability and impact management into decision-making requires investment interms of resourcing, leadership and building capability, which if not adequately budgeted for will
undermine strategy implementation.
REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Determine specific internal resources, investments, (R&D, capex, M&A, FDI) and fundingneeds to implement the SDG impact thesis and integrated strategy and analyze the financial risk-return profile(IRR) of SDG investments”.
Capitals Coalition Capitals Protocols. The Natural Capital Protocol highlights the consideration of the trade-off
between investing in building skills and institutional knowledge within internal staff and hiring external specialists
with significant technical expertise. It also gives an example of indicative resources that may be needed
throughout an assessment within the context of natural capital (see Step 01).
OTHER RESOURCES:

21

Guidance Note 1.2 The Fund sets realistic but ambitious portfolio level impact goalsaligned with its purpose and strategy, including its impact thesis, to optimize
contributing positively to sustainable development and achieving the SDGs.
1.2.1. The fund draws on available evidence and relevant SDG impact data andinformation from reputable government and scientific and civil society organizations
to set portfolio level impact goals that are:1.2.1.1 realistic and ambitious (in context of current performance and relevant local or
national SDG and/or other sustainable development outcome thresholds)
1.2.1.2 commensurate with the Fund’s size
1.2.1.3 align with its purpose, impact thesis, investment strategy and the sustainable
development context of the markets in which the Fund intends to operate
No additional guidance is needed.

Guidance Note 1.2.2. The Fund includes in its impact goals:
1.2.2.1 specific cross-cutting goals on creating gender equality, climate action, and decent
work
1.2.2.2 specific goals to prevent and/or reduce all material negative outcomes in its direct
operations and its supply and value chains (i.e. acting to avoid harm)
1.2.2.3 specific goals to optimize its own investor contributions (see Investor contribution(s)to impact)
When setting impacts goals, the following shall be considered both at the fund, portfolio and theinvestees levels.

Ambitious and rigorous impact goals
The PE fund having an impact thesis and setting rigorous and ambitious goals is fundamental to theargument that these processes will drive decision making that, taken up across the ecosystem,
would maximize contribution to sustainability and the SDGs. Ambitious goals also relate to the needfor continuous improvement.
Goals may be descriptive but must be associated with quantitative targets. The encouragement of
debate between those preparing the targets and those setting the targets, who are responsible forholding the management to account is key.
Where there is an element of performance related pay in relation to those targets there will need tobe more willingness by directors to ensure that those payments meet directors’ fiduciary
responsibilities and the approach to impact management may be less risky.
Targets
The process for setting targets should consider the local context:
•
•
•
•
•
•
•
•

Wider market and sustainability developments, including SDG goals and timescales
Thresholds, and allocation of those goals
Inequality, gender equality, climate action and decent work
Recognition and prevention or mitigation of material negative impacts
Trade-offs between positive and negative impacts in decision making
The relationship between impact targets, impact risk and risk tolerance
The relationship between impact targets and risk adjusted expected financial returns
Scale
22

Ambitious targets
A process for ambitious targets requires:
•
•
•
•
•
•
•

•

Assessing current performance (establishing baseline)
Estimating thresholds for each relevant impact both positive and negative
Setting targets within the longer-term strategy for the business and the impact thesis over the
coming years, recognizing the need for targets to be above thresholds for each impact
Comparison with peers and competitors recognizing that comparators must also meet theserequirements to be a useful benchmark
Agreement and sharing of targets with identified collaborations
Separation of roles between preparation and approval of goals
Process to adjust targets
o Regular director review of performance against targets that then informs future targets
o Changes made to address the results of that review, covering both strategy andoperations
A process to check progress on those actions

Rigorous targets
A process for rigorous targets necessitates quantified indicators or metrics (SMART), based on
•
•
•
•
•

Definitions as used in the Standards, including dimensions of impact in setting targets (2.1.6)
Stakeholder involvement to inform potential impacts and to understand and quantify the
relative importance of impacts (1.1.4)
Materiality process that ensures completeness of all material impacts (1.1.5)
Sufficient segmentation that captures relative differences between stakeholder groups and subgroups
Relate impacts to SDGs and ABC classifications (1.2.2)

Thresholds
A threshold is a societal norm or ecological level that is the minimum that must be reached for an
impact to be positive. The threshold defines the acceptable range for the impact. Performanceoutside of the acceptable range is negative or unsustainable. Performance within the acceptable
range is positive or sustainable. Thresholds can be set locally, nationally, or internationally. They
should also represent the affected stakeholder’s perspective, so stakeholder feedback can be an
important way to corroborate thresholds, especially when they are not well-established. (Note: careshould be taken to recognize—and adjust accordingly—that under-represented stakeholder
populations may not be aware of the negative impacts that business or other activities may have on
their access to basic rights and services. Precedence should be given to international norms where
locally set thresholds are unavailable or lower than international norms.) The PE fund should default
to using international norms when locally set thresholds are lower than international norms or notavailable.
There are three methods of arriving at thresholds for sustainable development:•

The first is grounded in natural or social sciences. Through research and empirical study, thismethod produces evidence to help organizations understand how their actions affect thepeople and natural resources they interact with (e.g., climate science).

23

•

•

The second is grounded in ethics. This method looks to social norms for what is considered
fair in society. These norms may be enshrined in law or formalized through institutions thathave legitimacy in producing associated reference documents (e.g., ILO Conventions).
The third is stakeholder expectations.

PE funds should look to identify authoritative institutions which provide credible sources ofthresholds for the impact they are trying to measure. Where established thresholds are notavailable, PE funds will need to determine a relevant threshold themselves. One option to inform thedecision is through Stakeholder feedback, so that at least the perspective of the affected
Stakeholder is included, and drawbacks of other methods can be mitigated (for example they areoften historical and “universal” and may have entrenched bias, for instance, gender bias).
PE funds may find that they have a choice between several credible thresholds. For example, when
considering the outcome of income from employment, a PE fund might consider the national
minimum wage, the national living wage, or a regional living wage. In such cases, the PE fund should
select the most ambitious threshold, so long as it is relevant to the affected stakeholder group. PE
funds may consider testing the relevance of thresholds through stakeholder engagement. It is
important to note that setting ambitious thresholds provide incentives for continuous improvement
even if reaching the target might take longer to achieve. It also increases the chances to findsolutions that will be most impactful.
Investees shall also be expected to set ambitious goals and targets which consider context,
stakeholders’ perspectives and threshold.

Ensuring impact goals are sufficiently targeted
Impact goals should account for relative differences between stakeholder groups – and different
segments within stakeholder groups. For example, on average the SDG threshold may be met,
however outcomes for certain stakeholder sub-groups (e.g., socio-economically disadvantaged
groups, indigenous peoples, religious or racial minority groups, people living with disability, women)
may be significantly below the threshold level. This requires making intergroup comparisons ofimpact, which in turn requires transparent valuation of impacts (including incorporating theperspectives of those experiencing the impacts into the valuation process).

Setting impact goals to avoid or significantly reduce all material negative impacts
This includes taking into account all expected material direct and indirect, intentional andunintentional (upstream and downstream) impacts that arise as a consequence of decisions, actions
and business relationships. Goals can also be set to improve the identification and management of
indirect impacts over time, recognizing the challenges that currently exist.
Avoiding or significantly reducing expected negative impacts is a positive contribution to sustainable
development and the SDGs when reaching the threshold level.

Amplifying impact through setting market leadership and collective action goals
The SDGs are a shared responsibility and require partnerships and collaboration to realize. Impact
can be amplified through setting market leadership and collective action goals to further enable theSDGs, for example:•

sharing SDG impact data and lessons publicly (e.g., sharing case studies about whichbusiness models in which contexts are effective at tackling specific SDG targets; sharing
examples of the different decisions made as a result of impact data)24

•actively participating in initiatives to build and/or comprehensively (i.e., not selectively)
adopt shared industry impact management terms, conventions, and standardized
metrics where appropriate•

proactively seeking to have metrics added to standardized lists where they are likely tohave broader applicability•

mentoring and enabling others•building stakeholders’ capacity (especially underserved and/or vulnerable populations)•

exploring partnerships as an enabler for greater SDG impact•

developing industry infrastructure such as open-source tools and resources•

helping to scale value-adding intermediaries, platforms, and networks•

promoting policy reforms.

Cross-cutting goals
For the purposes of applying the Standards, reducing inequality is an overarching objective andgender equity, climate action and decent work1 are always material as they are key priority areasthat underpin global sustainable development and require collective action to progress.
However, with respect to climate action, cross-cutting goals should take into account thedevelopment context, ensuring that developing countries and regions’ ability to achieve importantdevelopment outcomes are not jeopardized by unreasonable cross-cutting goals on climate actionthat are more fairly borne by more developed countries, and recognizing the interdependency
between inequality and development issues and climate action.

Setting impact goals across the five dimensions of impact
An impact goal set across the five dimensions of impact is an expression of expected impact
performance. It should include who is affected, what outcome occurs for them, how much thatoutcome changes, the contribution the PE fund expects to make to the change, and the risk that the
impact is different from that expected. Quantified targets using both the dimensions and theassessment of materiality that incudes relative preferences on the set of impacts can then be set.
After considering each of the five dimensions, an PE fund can classify its specific impact goals
according to the ABC impact classifications, which may be helpful in describing and summarizing thenature and depth of its impact intentions to stakeholders.
REFERENCE FRAMEWORKS:
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed to

1 International Labour Organization (ILO)’s definition of decent work involves opportunities for work that is productive anddelivers a fair income, security in the workplace and social protection for families, better prospects for personal
development and social integration, freedom for peoples to express their concerns, organize and participate in thedecisions that affect their lives and equality of opportunity and treatment for all women and men. The four pillars of theILO Decent Work Agenda are: (i) employment creation, (ii) social protection, (iii) rights to work, and (iv) social dialogue.

25

achieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
UN Guiding Principles on Business and Human Rights
https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf
Impact Management Project (IMP), five dimensions of impact, provides guidance on the types of data needed tounderstand and assess impact performance. The IMP community of 2,000+ practitioners identified fivedimensions of impact, which can be broken down into 15 more detailed data categories. Organizations can use
the five dimensions as a checklist to ensure the information gathered is sufficient for the decision it will inform(see also the ABC methodology and SDG Impact Standards Glossary).
https://impactmanagementproject.com/impact-management/how-PE funds-manage-impact/ and Five
Dimensions of Impact (Impact Management Norms), https://impactmanagementproject.com/impactmanagement/impact-management-norms/
Social Value International (SVI) Principles of Social Value, Principle 1: Involve stakeholders – “Inform what getsmeasured and how this is measured and valued in an account of social value by involving stakeholders (thepeople who experience change as a result of your activity)”.
Social Value International (SVI) “Standard on applying Principle 1: Involve stakeholders” explains options andprocesses for identifying stakeholders and meaningfully engaging stakeholders, including sample questions to
ask. This Standard talks about how speaking to and involving people who experience change is an essential partof the process. But they also acknowledge that speaking directly to stakeholders is not the only source of relevant
information. Third party research may be complementary to what you hear from stakeholders or may be a
substitute if your stakeholders are particularly difficult to reach, or if they do not feel comfortable sharing theiropinions. https://socialvalueint.org/wp-content/uploads/2019/03/Standard-on-Stakeholder-Involvement-V2.0FINAL-1.pdf
Social Value International (SVI) Principles of Social Value, Principle 4 – “Determine what information and evidence
must be included in the accounts to give a true and fair picture, such that stakeholders can draw reasonableconclusions about impact”.
Social Value International (SVI) Standard for applying Principle 4: Only include what is material – “Determine what
information and evidence must be included in the accounts to give a true and fair picture, such that stakeholders
can draw reasonable conclusions about impact”. https://socialvalueint.org/social-value/standards-andguidance/standard-applying-for-principle-4-only-include-what-is-material/
The Ten Principles of the UN Global Compact https://www.unglobalcompact.org/what-is-gc/mission/principles
The UN Women’s Empowerment Principles https://www.weps.org/
The International Labour Organization’s 8 fundamental conventions for labor standards
https://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-andrecommendations/lang--en/index.htm
Office of the United Nations High Commissioner for Human Rights, Free and Prior Informed Consent for
Indigenous Peoples,
www.ohchr.org/Documents/IssueFree_and_prior_informed_consent_for_indigenous_peoples/Peoples/FreePrioran
dInformedConsent.pdf
OECD Guidelines for Multinational PE funds sets out principles and standards for responsible business conductconsistent with applicable laws and internationally recognized standards, including setting objectives withreference to minimum safeguards on topics such as: human rights, labour relations, employment practices, publichealth and safety, bribery and extortion, science and technology and taxation.

26

CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 1: SDG IMPACT THESIS AND
MEASUREMENT, “Identify and mitigate “significant negative impacts on relevant SDGs, based on an analysis of thecorporate portfolio and the supply chain and benchmarked against impacts generally associated with comparable
assets, activities, or operating contexts”; “Set goals, targets, and indicators that promote and credibly measure thecompany’s contribution to relevant SDGs and its mitigation of significant negative impacts, using consistent andcomparable metrics that are based on the official SDG targets and indicators”; Principle 2: INTEGRATED SDG
STRATEGY AND INVESTMENTS, “Business should translate their SDG impact thesis into strategic objectives andinitiatives that build upon the existing corporate strategy and business model”.
UNEPFI Principles for Responsible Banking, Principle 3: Clients and Customers – WE will work responsibly with ourclients and our customers to encourage sustainable practices and enable economic activities that create sharedprosperity for current and future generations.
UNEPFI Principles for Responsible Banking, Principle 2: Impact & Target Setting – We will continuously increase
our positive impacts while reducing the negative impacts on, and managing the risks to, people and theenvironment resulting from our activities, products, and services. To this end, we will set and publish targets
where we can have the most significant impacts.
Social Value International (SVI) Principles of Social Value, Principle 4 – “Determine what information and evidence
must be included in the accounts to give a true and fair picture, such that stakeholders can draw reasonableconclusions about impact”.
Social Value International (SVI) Standard for applying Principle 4: Only include what is material – “Determine what
information and evidence must be included in the accounts to give a true and fair picture, such that stakeholders
can draw reasonable conclusions about impact”. https://socialvalueint.org/social-value/standards-andguidance/standard-applying-for-principle-4-only-include-what-is-material/
OTHER RESOURCES:
R3.0 work with UNRISD – https://r3dot0.medium.com/thresholds-of-transformation-a -common-denominator-totranscend-incrementalism-unrisd-r3-0-74fff499bcdb
SHIFT (human rights thresholds)
UN Stats - SDG Indicators Database https://unstats.un.org/sdgs/indicators/database/ provides access to datacompiled through the UN System in preparation for the Secretary-General's annual report on "Progress towards
the Sustainable Development Goals" that can be used to identify areas of need in relation to specific SDG targets
by SDG indicator.
OECD Statistics is a database of OECD’s publicly available statistics that can be used to identify areas of need inrelation to specific sustainability topics. Especially useful for organizations designing business models to meet theneeds of a group of people or the natural environment.
World Bank Data is a database of the World Bank’s publicly available statistics that can be used to identify areasof need in relation to specific sustainability topics. Especially useful for organizations designing business models
to meet the needs of a group of people or the natural environment.
Stockholm Resilience Centre (SRC) is an international research centre on resilience and sustainability science –(planetary boundary thresholds) https://www.stockholmresilience.org/about-us.html (planetary boundary
thresholds)
How to guide for Setting Science Based Targets by the Science Based Targets Initiative provides guidance for atranslating planetary thresholds related to green-house gas emissions into company-specific targets which
incorporate a ecological threshold for a given global warming scenario.

27

Science-Based Targets for Nature Initial Guidance for Business by the Science Based Targets Network provides
guidance for setting science-based targets relating to nature by translating planetary thresholds and societal
goals into company-specific targets for air, water, land, biodiversity and ocean.
OECD Due Diligence Guidance for Responsible Business Conduct helps organizations comply with the OECD
Guidelines for Multinational PE funds providing guidance on setting up due diligence processes to identify andaddress principal adverse impacts in operations, supply chain and business relationships.
SDG Action Manager (developed by B Lab and the United Nations Global Compact) has a goal-setting
functionality which enables users to set specific goals with timelines for each question within a given SDG. Eachquestion within the SDG Action Manager is mapped to SDG targets. The SDG Action Manager also enables users
to get a clear and holistic view of how a company’s operations, supply chain, business model and collective action
create positive impact, and identify risk areas for each SDG.
SDG Compass Guide (developed by UN Global Compact, GRI, and WBCSD) provides guidance for companies on
how they can align their strategies as well as measure and manage their contribution to the realization of theSDGs https://sdgcompass.org/
SDG Ambition (an accelerator initiative developed by the UN Global Compact) aims to challenge and support
participating companies of the UN Global Compact in setting ambitious corporate targets and accelerating
integration of the SDGs into core business management. Established in partnership with several UN Global
Compact companies, the accelerator program provides participating companies with detailed guidance andtraining on how to integrate and mainstream sustainability goals across business units by pioneering aperformance integration approach that utilizes enabling technologies.
SDG Ambition Guide (developed by the UN Global Compact) establishes the initial set of SDG Ambition
benchmarks to support goal setting and the development of corporate targets in the areas in which business is
positioned to have a substantial impact. Business leaders can use the guide to support their strategy and set
goals ambitious enough to deliver the SDGs by 2030.
The UNEP FI Principles for Responsible Banking target setting guidance documents provide banks with guidanceon setting targets on a range of sustainability topics: biodiversity, financial health & inclusion, climate, genderequality.
IFC’s Environmental and Social Performance Standards which define IFC clients' responsibilities for managing theirenvironmental and social risks and can be applied by other organizations to manage ESG risks(https://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/Sustainability-AtIFC/Policies-Standards/Performance-Standards)
The Equator Principles (EPs) is a risk management framework, adopted by financial institutions, for determining,assessing and managing environmental and social risk in projects and is primarily intended to provide a minimum
standard for due diligence and monitoring to support responsible risk decision-making https://equatorprinciples.com/about/352/
UNDP SDG Impact Investor Maps are a market intelligence product produced by UNDP Country Offices andpartners to help private investors (funds, financiers, corporations) identify investment opportunities and businessmodels that have significant potential to advance the SDGs in specific country or regional contexts.
https://sdginvestorplatform.undp.org/
Oxfam Women’s Economic Empowerment
Framework https://oxfamilibrary.openrepository.com/bitstream/handle/10546/620269/gt-framework-womenseconomic-empowerment-180118-en.pdf?sequence=7
SEAF Gender Equality Scorecard Manual – https://www.seaf.com/ges-manual/
2X Challenge Financing for Women – https://www.2xchallenge.org/criteria

28

The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas and guide them on their performance assessment based on
which targets should be set. The Tools have an in-built indicator library which provides a compilation of impactrelated indicators and metrics, useful for setting meaningful targets. This is also available as a standalone
resource.
The Fundamental Principles of Official Statistics (General Assembly resolution 68/261) – where feasible, data
should be disaggregated (i.e., segmented) by income, sex, age, race, ethnicity, migratory status, disability andgeographic location, or other characteristics pertinent to the PE fund’s impact goals.
World Business Council for Sustainable Development, Sustainable Development Goals Sector Roadmaps:
Leveraging The Power of Collaboration to Drive SDG Impact,
https://www.wbcsd.org/Programs/People/Sustainable-Development-Goals/SDG-Sector-Roadmaps/News/SDGSector-Roadmaps-Leveraging-the-power-of-collaboration-to-drive-SDG-impact
OECD Directorate for Financial and PE fund Affairs, Guidelines for Due Diligence and Stakeholders Engagement in
Investments, https://www.oecd.org/fr/daf/inv/
British Standards Institution, BS 8950 Social value – Understanding and enhancing – Guide (Draft, 2020)
The Accountability Council, https://www.accountabilitycounsel.org/wp-content/uploands/2018/08/6-27-16-amsbenefits-and-best-practices_short.pdf
The Kampala Principles on Effective Private Sector Engagement, http://www.oecd.org/dac/effectiveness/KampalaPrinciples-on-effective-private-sector-engagement-development-cooperation.pdf
The OECD Blended Finance Principle 3, http://www.oecd.org/dac/financing-sustainable-development/blendedfinance-principles/principle-3/P#_Guidance_Note.pdf
OECD Directorate for Financial and PE fund Affairs, Guidelines for Due Diligence and Stakeholders Engagement in
Investments, https://www.oecd.org/fr/daf/inv/
The Future-Fit Benchmarks developed by Natural Step which identify a set of ‘absolute’ goals that are based onsocial and natural science and that all companies must ultimately strive to reach, irrespective of the products orservices they offer.
WBCSD’s Action2020 which sets the agenda for business to take action on sustainable development to 2020 andbeyond. Action2020 defines societal targets, ‘Societal Must-Haves’ and around nine Priority Areas, based on ascientific review led by the Stockholm Resilience Centre.
The United Nations website contains public commitments to goals and targets announced by companies.
PivotGoals by Winston Eco-Strategies which allows users to browse goals and targets set by Global 500
companies. Adapted from SDG Compass Guide 2015.
Reconstructing Baseline Data for Impact Evaluation and Results Measurement by the World Bank – for whenbaseline data is missing
GRI Sustainability Reporting Standards are designed to help organizations understand and report their impacts ina way that meets the needs of multiple stakeholders. There are a set of Universal Standards that apply to allorganizations, and 35 Topic Standards that contain disclosures for impacts related to economic, environmental,

29

and social topics. Organizations can use the standards to report to stakeholders on “material” topics that reflect
the organization’s most significant impacts.
IRIS+ System by Global Impact Investing Network (GIIN) is a tool designed to help impact investors translate
intentions into results (hence investors may request businesses they invest in to report using these metrics, andthey may be useful to businesses looking to select appropriate metrics to measure, manage and report theirimpacts). IRIS+ metrics and metric sets are aligned to the SDGs and five dimensions of impact and work isunderway to map various investor metric sets and corporate disclosure standards with a view to achieving global
consistency, including IRIS+-GRI, B Lab-IRIS+, HIPSO-IRIS+. It starts by helping investors frame their impact goals
in a common way (linked to an SDG or Impact Category) and offers a set of metrics (Core Metrics Sets) to assess
performance against set goals, together with an evidence base (Navigating Impact) and implementation
guidance.
HIPSO indicators (Harmonized Indicators for Private Sector Operations) are a list of reporting indicators set acrossvarious sectors and industries (including cross-cutting). They have definitions that have been agreed upon by 28
different development finance institutions from around the world, all of whom have signed the MoU on
harmonized indicators. These indicators may be used by any entity wishing to use them.
UNCTAD core indicators for entity reporting on contributions towards implementation of the Sustainable
Development Goals (GCI). The GCI is a set of core universal baseline indicators common to all businesses of all
types and sizes aimed to facilitation harmonization and comparability of SDG reporting by companies. The GCI
has been endorsed by UNCTAD member states, are selected based on main reporting frameworks and PE fundpractices and aligned with the SDG indicators monitoring framework. https://unctad.org/webflyer/guidance-coreindicators-entity-reporting-contribution-towards-implementation-sustainable
UNCTAD GCI Training Material https://isar.unctad.org/wp-content/uploads/2020/04/UNCTAD_DIAE_2020_2.pdf
GRI – forthcoming – sector standards
WBA likely impacts that all PE funds might have regardless of their industry
WEB IBC’s universal metric sets likely impacts that all PE funds might have regardless of their industry

30

Guidance note 1.2.3. The fund has a separation of roles between drafting andapproval of impact goals, where those approving the goals recognize they are acting
in both the interests of the Fund and those expected to be impacted
No additional guidance is needed.

Guidance note 1.2.4. The fund considers the potential for unintended consequences
and seek to limit the potential for unintended negative or perverse outcomes in theframing of its portfolio level impact goals.
Reducing the potential for unintended consequences
The success of deploying an impact strategy needs to consider potential unintended consequences
and limit its negative outcomes. When setting impact goals, the interdependency of the SDGs andwhether the strategic goals or metrics selected may inadvertently redirect resources and attention
from where they are needed most or incentivize unintended or undesirable behaviors that reduce
positive impact or create or increase negative impact should be considered.

Guidance note 1.3 The Fund periodically reviews – and refines – its impact thesis,
investment strategy and portfolio level impact goals to ensure they remain fit for purpose
over the Fund lifecycle and as the sustainable development context changes. The Fund:1.3.1 employs a dynamic approach to ensuring its impact thesis, investment strategy
and portfolio level impact goals remain fit for purpose
1.3.2 incorporates lessons from impact performance, including analyzing deviations
from expected outcome/impact performance
1.3.3 responds to current and anticipated changes in the sustainable development
context including changes to in country SDG priorities or needs and accounting for
sector advances and new and updated research/evidence, and lessons from its
engagement with Investees, partners and other Stakeholders.
Strategy always on and embedding continuous improvement
The sustainable development context is dynamic and constantly changing. Further, as the Fundcollects data and monitors its impact performance, it will learn about what’s working well, whatneeds refinement, and what’s not working. Strategy and goal setting is not a set-and-forget exercise
and should be periodically (for instance annually) reviewed and updated as appropriate, including by
incorporating:•lessons from the engagement with investees, partners and stakeholders•

lessons from impact performance (e.g., evaluating deviations from expected
outcome/impact performance, recognizing unintended positive or negative
outcomes/impacts, and eventual need of corrections to future plans)•changes in the sustainable development context (e.g., regulatory changes, technologicaladvances, other actors’ activities, possibility of local political developments or public
reactions, changes to in-country SDG priorities or needs)•

updated research, evidence, and/or approaches.

31

This process creates systematic feedback loops to support continuous improvement in impact
practices and performance. For example, impacts that may have been expected to be “positive” inthe planning phase that might no longer be sufficient and/or relevant for the stakeholders
experiencing the impact.
REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 1: SDG IMPACT THESIS AND
MEASUREMENT, “Business should develop a specific SDG impact thesis, which maximizes their unique capabilities
and assets, promotes the most effective private-sector solutions to sustainable development and is updated or
expanded over time”.
OTHER RESOURCES:

32

Management Approach
Guidance Note 2.1 The Fund has effective mechanisms and processes to deliver on its
strategy, including its impact thesis and portfolio level impact goals.
2.1.1. The Fund embeds in its policies and practices the UN Guiding Principles for
Business and Human Rights and Ten Principles of the UN Global Compact, including:
2.1.1.1 establishing or participating in effective grievance and reparation mechanisms
for affected Stakeholders (including for the avoidance of doubt, whistleblowing
safeguards)
2.1.1.2 ensuring senior leadership’s commitment to respect human rights and other
responsible business practices is visible throughout the organization
2.1.1.3 promoting the same in its supply and value chains
Respect for human rights, planetary boundaries, and other responsible business practices
Commitment to operating with respect for human rights, planetary boundaries and other
responsible investment practices and acting to prevent, mitigate and remediate actions any breachto that commitment – through the investees’ direct operations, business relationships andpromoting the same through supply and value chains – is foundational.
Both PE fund’s and the investees policies and practices should be aligned with, or they should have ademonstrated commitment and progress towards aligning policies and practices with, the:•••UN Guiding Principles for Business and Human Rights (which incorporates the International
Labour Organization – 8 fundamental conventions for labour standards)
Ten Principles of the UN Global Compact, andUN Women’s Empowerment Principles

Such policies include but are not limited to those labelled code of conduct, responsible business,
Environmental, Social and Governance (ESG) policies and those concerning specific sustainable
development issues such as climate change, human rights, and equal opportunities.
Practices may include, for instance with respect to workers, the role of trade unions being
recognized and supported, collective bargaining rights and mechanisms for the application of ILO
convention 169 (ILO, 1989) and as evidenced by the response, for example, a change to products orservices, a change in operations or to working conditions, evidence of proposals that are rejected bythose that are or may be impacted – even though they may generate financial returns.
Commitment is reinforced through visible senior leadership endorsement internally and externally inemails, newsletters, speeches, social media, website, etc. and coherence between stated policies
and behaviors.

Effective grievance mechanisms
The goal is that stakeholders are easily able to submit complaints or claims, get a fair assessment ofcases, and receive compensation/ reparation as applicable through effective accountability
mechanisms. Effective accountability mechanisms are principles based and adhere to all of the33

following principles: (1) Legitimacy; (2) Predictability; (3) Accessibility; (4) Equitability; (5)Transparency; (6) Rights compatibility; (7) A source of continuous learning; and (8) Based on
engagement and dialogue.
In general, accountability mechanisms:•

receive complaints from people harmed, or likely to be harmed, by the PE fund•determine whether the complaint is eligible under the mechanism’s rules; and then, if it iseligible, the accountability mechanism may:
• resolve the dispute through mediation, fact-finding or other methods; and/or• investigate whether the PE fund’s own policies or procedures have been violated by
the institution and whether those violations have caused or are likely to cause harmto people or the environment.

•

Finally, the accountability mechanism issues a public report with their findings of theinvestigation and recommendations, if any.

Policies and guidelines should be in place for receiving complaints, giving complaints serious
consideration, ensuring remedial actions are taken and commensurate to the magnitude of thedamage and taking action to reduce the likelihood of future negative impacts. Cases, status, andresolutions are monitored and reported and available to senior management, the board, and otherrelevant stakeholders.
PE funds should have an independent office to receive complaints from people alleging harm fromthe activities of the PE fund or its investees. The independent office should be equipped to addresscomplaints through two primary functions: dispute resolution2 and compliance review3. The
purpose of dispute resolution is to provide a process for resolving concerns and remedying harmcollaboratively with aggrieved stakeholders through a neutral facilitator. The purpose of compliancereview is to determine whether harm resulted from non-compliance with the PE fund’senvironmental and social policies. If the conclusion of a compliance review is that harm has resulted
from non-compliance, the PE fund should commit to remedy the harm (or potential harm),
remediate it, and report on it. All reports should be substantiated by evidence.
Organizations like Accountability Counsel and SHIFT create resources that make it easier and more
efficient for businesses to incorporate human rights and other responsible business practices into
their policies and practices. In many countries, options now exist for organizations to participate incost effective external complaints and dispute resolution schemes that support accountability to
stakeholders.
Source: Adapted from Accountability Counsel

2 Dispute resolution (also called conflict resolution) is a process that facilitates a dialogue between affected people, projectsponsors, and other local stakeholders toward resolving the issues raised in a complaint. Typically, an accountability officewill hire a neutral mediator or facilitator to aid the process. Dispute resolution frequently entails information-sharing,utilization of independent experts to better understand the extent of harm and possible solutions, and negotiation
between the parties. The process often takes several months. Agreements reached through dispute resolution are typicallyfollowed by a monitoring period where the accountability office reports on the progress of implementing agreed-uponcommitments. Source: Accountability counsel
3 Compliance review (also called compliance investigation or compliance audit) is the process of probing whether an
institution violated its own policies or procedures by engaging in activities that lead to the harm described in a complaint.
Source: Accountability Counsel.

34

REFERENCE FRAMEWORKS:
UN Guiding Principles for Business and Human Rights
Ten Principles of the UN Global Compact
UN Women’s Empowerment Principles
International Labour Organization – 8 fundamental conventions for labour standards
OECD Guidelines for Multinational PE funds sets out principles and standards for responsible business conductconsistent with applicable laws and internationally recognized standards, including setting objectives withreference to minimum safeguards on topics such as: human rights, labour relations, employment practices, publichealth and safety, bribery and extortion, science and technology and taxation.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria”; “ Leverage and strengthen corporate governance mechanisms to
incentivize and monitor the implementation of the integrated SDG strategy and investments (board oversight,
internal controls and audit, executive remuneration and disclosure”.
UNEPFI Principles for Responsible Banking, Principle 3: Clients and Customers – WE will work responsibly with ourclients and our customers to encourage sustainable practices and enable economic activities that create sharedprosperity for current and future generations.
OTHER RESOURCES:
OECD Due Diligence Guidance for Responsible Business Conduct helps organizations comply with the OECD
Guidelines for Multinational PE funds providing guidance on setting up due diligence processes to identify andaddress principal adverse impacts in operations, supply chain and business relationships
https://www.oecd.org/investment/due-diligence-guidance-for-responsible-business-conduct.htm
Accountability Counsel
Shift project: UN Guiding Principles 101
SDG Action Manager Baseline Module (developed by B Lab and the United Nations Global Compact)
Grievance Mechanism Gap Analysis by the Business Call to Action
Resource Guide on Good Practices in the Protection of Reporting Persons by the United Nations Convention
against Corruption
Accountability Counsel’s Accountability Mechanisms: Benefits and Best PracticeForthcoming October 2021: Good Policy Paper published by Accountability Counsel, SOMO, & others
Gaining Buy-In For A Human Rights Program: A Planning Worksheet by the Business Call to Action
UN Guiding Principles Checklist, Human Rights Policy Tool, Rapid Human Rights Risk Assessment, Internal andExternal Questionnaires available at Business Call to Action
UN Global Compact’s Supply Chain Sustainability: A Practical Guide for Continuous Improvement, Second Edition

35

The State of Play: The Corporate Responsibility to Respect Human Rights in Business Relationship by the Institutefor Human Rights and Business and the Global Business Initiative on Human Rights
IFC’s Environmental and Social Performance Standards which define IFC clients' responsibilities for managing theirenvironmental and social risks and can be applied by other organizations to manage ESG risks(https://www.ifc.org/wps/wcm/connect/Topics_Ext_Content/IFC_External_Corporate_Site/Sustainability-AtIFC/Policies-Standards/Performance-Standards)
The Equator Principles (EPs) is a risk management framework, adopted by financial institutions, for determining,assessing and managing environmental and social risk in projects and is primarily intended to provide a minimum
standard for due diligence and monitoring to support responsible risk decision-making https://equatorprinciples.com/about/352/

Guidance Note 2.1.2 The Fund integrates respect for human rights, other responsible
business practices and impact management into day-to-day roles and decision making
processes, including:
2.1.2.1 developing its integrated thinking and decision making capabilities using
mechanisms such as appropriate culture, communication systems and training
2.1.2.2 making choices between different options, taking into account trade-offs and/or impact risks to optimize contributing positively to sustainable development andachieving the SDGs
2.1.2.3 allocating adequate budget and people resources (including capability,
training and leadership) to deliver its strategy and impact goals
2.1.2.4 holding people at all levels accountable for operating in accordance withorganizational culture and responsible business and impact management policies andpractices
2.1.2.5 having sufficient diversity, sustainable development, Stakeholder engagement
and impact management specialization at the appropriate level of seniority andauthority to influence decision making
2.1.2.6 aligning its incentive mechanisms with its purpose and strategy, including by
rewarding challenge and diversity of thought and reducing emphasis on short term
financial outcomes
Organizational culture and diversity
Respect for human rights, planetary boundaries and other responsible business practices andoperating sustainably and contributing positively to achieving the SDGs should be embedded inorganizational culture and “how we do things around here”, and reinforced through businessprocesses, systems, job descriptions, training, organizational and personal KPIs and internal controls.
Particular care should be taken to ensure that what gets rewarded (financial and/or non-financial
incentives) is consistent with the stated organizational purpose and values and commitment torespect human rights, planetary boundaries and other responsible business practices and impact
goals – including holding people at all levels accountable for their actions. Goals, KPIs and incentive
structures should be designed and implemented in a way that avoids unintended consequences(including by creating perverse incentives). This is applicable both at the fund and the investee
levels.
36

Diversity of thought and effective challenge in decision-making is sought out, valued, and celebrated
in an open, curious, inclusive, culture (acknowledging that there are cultural variations in how this isachieved), contributing to break-through thinking and decision-making. Consequently, diversity
should be evident across the PE fund and its investees, including in leadership roles – not only interms of capabilities (including in sustainable development and impact management), but in termsof gender, minority representation and lived experiences, perspectives and thinking styles. A cultureof continuous improvement and evidence-based learning should be evident from how the PE fundand the investees respond when outcomes are different to what is expected and how impact data isused systematically to monitor performance and identify opportunities for improvement.

Impact management capabilities
Internal sustainable development and impact management capabilities and capacity should be
developed commensurate with the PE fund’s size and complexity and in line with its commitment toembed sustainable development issues and impact management into organizational purpose,
strategy, and business model. Some of these capabilities may include:•

Expertise in impact measurement and management, sustainability, international
development, stakeholder engagement, systems thinking, theories of change, integrated
thinking, change management, understanding of key sustainable development challenges
and sectoral issues (including key SDG priorities in context)•

Diversity of lived experience, perspectives and thinking styles•

Expertise in dealing with impact data including how data can be manipulated, identifying key
data elements that may be missing or unrealistic•

Ability to conduct high quality impact assessments and reviews, diagnose issues andopportunities, and integrate impact and financial analysis into decision making.

Where internal sustainable development and impact management expertise is supplemented withoutside support, there is a baseline level of internal expertise to identify skill gaps, select third
parties with appropriate skills and experience to fill those gaps and manage/oversee third party
arrangements, key person risks and institutional knowledge transfer.
This is also applicable to the investees.
REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by the UN Global Compact),
https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGY AND INVESTMENTS,“Determine specific internal resources, investments, (R&D, capex, M&A, FDI) and funding needs to implement the
SDG impact thesis and integrated strategy and analyze the financial risk-return profile (IRR) of SDG investments”;“Adopt investment criteria and decision-making processes based on SDG impact alongside financial risk andreturn investment criteria’; “Leverage and strengthen corporate governance mechanisms to incentivize andmonitor the implementation of the integrated SDG strategy and investments (board oversight, internal controls
and audit, executive remuneration and disclosure.”Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Allocate and equip staff with relevant mandates and skill sets toenforce the above processes.”37

Principles for Responsible Banking (developed by UN Environment Finance Initiative), Principle 5: Governance andCulture – We will implement our commitment to these Principles through effective governance and a culture of
responsible banking.
Capitals Coalition’s Human and Social Capital Protocol and Natural Capital Protocol (developing integrated
thinking and decision-making capabilities through application of the Protocols)
OTHER RESOURCES:
SDG Ambition Benchmark Reference Sheets (developed by the UN Global Compact). The SDG Ambition
Benchmark Reference Sheets, provide illustrative details on the steps a company can take to integrate actions
related to achieving the SDGs into its business systems. There are at least 10 reference sheets covering topics
such as Gender Balance Across All Levels of Management, Zero Discharge of Hazardous Pollutants and Chemicals,
and 100% of Employees Across the Organization Earn a Living Wage. https://unglobalcompact.org/library/5790
What does it take to go big? Management practices to bring inclusive business to scale by Business Call to Action
The Inclusive Business Management Practices Tool by Business Call to Action
Oxfam Women’s Economic Empowerment
Framework https://oxfamilibrary.openrepository.com/bitstream/handle/10546/620269/gt-framework-womenseconomic-empowerment-180118-en.pdf?sequence=7
SEAF Gender Equality Scorecard Manual – https://www.seaf.com/ges-manual/
2X Challenge Financing for Women – https://www.2xchallenge.org/criteria

Choices, options, and trade-offs
Decision making means making choices between options, addressed in the PE fund’s approach tointernal reporting and summarising data (2.2.7), generating options for increasing that contribution(2.3.1), and assessing the risk in making decisions (2.2.4). The choices will invariably involve making
trade-offs. There may be trade-offs between positive and negative impacts within an option as wellas trade-offs between the positive and negative impacts in different options, or potentially impacts
experienced by different people. Although the thresholds represent minimum levels, there may besituations where all the options include impacts that do not meet thresholds and the choice is the‘least bad.’
The indicator focuses on transparency and maximizing. Transparency requires those trade-offs to betransparent and transparency requires that those involved in the decision start with a common
measure, informed by the people that will or have experienced the impacts. 2.2.4.1 refers tovaluation using well-being as a common measure. Maximizing the contribution means that thedecisions consider the positive and negative impacts in the round and the implications for any
positive contribution where options include impacts that do not meet thresholds.
PE funds should recognize these challenges, have a documented approach to trade-offs, anapproach to a common measure of valuing what is important to the people who experience impacts,and ensure that decisions made have considered trade-offs.
REFERENCE FRAMEWORKS:

38

Social Value International (SVI), Principle 3: Value what matters – “Making decisions about allocating resources
between different options needs to recognize the values of stakeholders. Value refers to the relative importanceof different outcomes. It is informed by stakeholder preferences.”
Social Value International (SVI) Standard for applying Principle 3: Value the things that matter – guidance to value
impacts from the perspective of affected stakeholders, emphasizing the importance of using data collected
directly from stakeholders.
Social Value International (SVI) Principles of Social Value, Principle 8: Be Responsive – (work in progress) “making
decisions that optimize value for all stakeholder groups materially affected. Consideration of risks and rigour ofdata in context of decisions being made”.
The Capitals Coalition Natural Capital Protocols and Social and Human Capitals Protocols are the internationallyaccepted harmonized framework for identifying, measuring and valuing the impacts and dependencies on naturaland social and human capital and outline a series of actions that will help organizations integrate sustainable
development and impact management into management decision-making. See also Capitals Coalition, Principles
of Integrated Capitals Assessments.
OTHER RESOURCES:

Guidance note 2.1.3 The Fund implements mechanisms to proactively monitor its
performance and conformance with its responsible business and impact management
policies and practices, and embeds a culture of continuous improvement
No additional guidance is needed.

Guidance note 2.1.4 complies with local and international laws and regulations,striving to comply with the highest possible level of industry best practice, particularly
in cases where there is a lack of local regulation or the standard is comparatively low
and identifying (and finding solutions for) where local and international lows andregulations are in conflict39

No additional guidance is needed.

Guidance Note 2.1.5. The Fund has effective mechanisms to identify Stakeholders
materially affected (or likely to be affected) by its (and its Investees) activities andpromotes Stakeholder involvement in decisions that impact them, including:
2.1.5.1 having (and ensuring Investees have) transparent mechanisms for involving
those Stakeholders and ensuring they have meaningful agency in decisions relating to
the Fund and its’ investments that impact them, including in identifying material
impacts, designing solutions, developing impact data collection processes, selecting
metrics, and participating in collecting and assessing impact data
2.1.5.2 transparently keeping Stakeholders informed of actions, progress, and lessons
through the lifecycle of the investment, directly or indirectly through its Investees
2.1.5.3 supporting Stakeholder involvement with adequate budget and resources(including capability and local leadership) Stakeholder engagement/involvement
Stakeholders involvement
Involving stakeholders and giving them meaningful agency in decisions that impact them (noting thatinaction is also a decision) is an overarching theme throughout the Standards. Decisions will be
more robust if the perspective and input from those experiencing the impacts of the PE fund’s
actions and decisions is incorporated into the investees decision-making for instance:•

In the design process for products and services•

In determining what impacts matter and to understand and quantify the relative
importance (value) of those impacts on their well-being along the whole PE fund supply
and value chain, its products, and services•

In understanding Stakeholders’ tolerance for unexpected outcomes and the impacts onthem if impacts do not occur as expected•

In collecting and analyzing impact data (while not being overly burdensome or intrusive)•

In identifying effective consultation mechanisms and reporting•

In identifying communication channels between stakeholders and the PE fundThis necessitates the involvement being sought from those that experience the impacts, that thosestakeholders feel comfortable to share their perspectives, and that the information received isinterpreted objectively.
Stakeholder involvement requires the allocation of financial and non-financial resources and thus
should be included in budgets, resource plans and job descriptions/KPIs and a systematic approach
supported by stakeholder management systems and communications plans.
Stakeholders should be kept informed about decisions, actions, execution progress and lessons
learned on matters impacting them.

40

Nature of engagement with Stakeholders
Engagement should be appropriate in context, for instance, if the investees’ relationship withstakeholders is direct, the engagement strategies employed by investees will include direct
engagement with stakeholders to understand their views.
The fund’s relationship with stakeholders is indirect so it is likely the PE fund will not engage withstakeholders directly, but it will consider it on its due diligence look to ensure that the relevant
entities have done so and also post due diligence as part of their operations. Where it can be shown
to be appropriate to do so and relevant in context, evidence-based proxies and information from
reputable civil society agencies may also be used, however should not diminish stakeholder’s rights,
including for meaningful agency.
Additional sectoral due diligence (and follow up impact evaluations) may be appropriate in high-risk
sectors (e.g., agri-business, apparel, housing, or land acquisition related activities that may result in
relocation or displacement), or when dealing with marginalized stakeholder groups (e.g., indigenous
peoples). Consideration should also be given to issues of provenance e.g., with respect to indigenous
land rights.
Assessing the impacts on different groups of Stakeholders separately is also important to ensure thatthe overarching objectives of the SDGs (to leave no one behind) are met – for example, benefits tostakeholders already above thresholds should not be at the expense of stakeholders currently
experiencing outcomes below threshold levels. Care should be taken to recognize that underrepresented stakeholder populations may not be aware of the negative impacts that business orother activities may have on their or others access to basic rights and services. However, this does
not impede informing them and engaging them.
Examples of organizations acting on behalf of those impacted that call out negative impacts oforganizations include Accountability Now, Corporate Responsibility Organization, Oxfam, among
others.
The PE fund should also consider how it corroborates information about stakeholders (e.g., bycollecting and analyzing various perspectives from different stakeholders as well as through third
party research or evidence – e.g., using data triangulation), and identifies and mitigates the risks
associated with using information received from different stakeholder groups (e.g., reliability, bias,
relevance to context).
REFERENCE FRAMEWORKS:
Social Value International, Principles of Social Value: Principle 1 Involve stakeholders – “inform what getsmeasured and how his is measured and valued in an account of social value by involving stakeholders (the people
who experience change as a result of your activity”.
Social Value International “Standard on applying Principle 1: Involve stakeholders” explains options and processes
for identifying stakeholders and meaningfully engaging stakeholders, including sample questions to ask. This
Standard talks about how speaking to and involving people who experience change is an essential part of theprocess. But they also acknowledge that speaking directly to stakeholders is not the only source of relevant
information. Third party research may be complementary to what you hear from stakeholders or may be a
substitute if your stakeholders are particularly difficult to reach, or if they do not feel comfortable sharing theiropinions. https://socialvalueint.org/wp-content/uploads/2019/03/Standard-on-Stakeholder-Involvement-V2.0FINAL-1.pdfILO convention 169: prior consultation and participation of indigenous peoples in decisions affecting
them, and in particular with regard to free and informed consent on private activities in their territories.

41

CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.
UNEPFI Principles for Responsible Banking, Principle 4: Stakeholders – We will proactively and responsibly consult,engage, and partner with relevant stakeholders to achieve society’s goals
OTHER RESOURCES:
OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, Feb 2017)
British Standards Institution, BS 8950 Social value – Understanding and enhancing – Guide (Draft, 2020).

Guidance Note 2.1.6. The Fund introduces robust, reliable and practical processes tocollect, manage and use its impact data, including:
2.1.6.1 systematically capturing results from across its impact management activities
2.1.6.2 presenting its impact data and information in a way that it can be integrated
with financial data and inform investment decision making
2.1.6.3 managing data ownership (i.e., Stakeholders) and privacy issues and ethicaland commercial issues regarding data gathering, use and disclosure
2.1.6.4 taking a risk-based approach to determine external verification and assurance
requirements for its impact data, impact assessments and evaluations, and externalreporting, and following up findings with suitable rectification measures in a timely
mannerImpact data collection and use
This guidance note covers several indicators relating to a number of activities that underpin the SDG
Impact Standards approach to impact management. These indicators refer to the data that would becollected to allow a PE fund to make decisions to increase its positive contribution to sustainability
and the SDGs at a rate commensurate with stakeholder expectations and the SDG targets. These
activities are data collection (2.1.6), reporting and summarizing data on impacts assessments (2.3.7),
generating options for increasing that contribution (2.3.8), assessing the risk in making decisions(2.3.6.4) and ongoing review of impact management approach (2.3.10).

Management practiceThis approach is based on the funds ability to set up a the right incentives, structure, capabilities andprocesses to deliver on its impact goals. This includes, developing an IMM framework to screen ex
ante, the investees sustainability practices and expected impacts, monitor and assess performanceand collect relevant data for decision-making both at the investee and portfolio levels. The
framework shall include mechanisms to capture and share lessons learned for continuous
improvement.
The requirements are:•a complete set of material impacts;
42

•
•

impacts defined as changes in well-being of people and planet caused by the activities of theorganization; andall the data points (or metrics) for each impact.

The fund shall seek to ensure its investments are allocated on investees with highest likelihood of
having positive impacts in line with fund impact goals. Thus, its IMM approach shall be designed toreduce the risk that the best option is not chosen and to increase the universe of potential insightsthat drive options to contribute positively to sustainability and the SDGs. Whilst many approaches to
impact measurement focus on accurate measure of each impact, few recognize the importance ofdata that does not relate to intended impacts but is critical to increasing performance.
Where data relates to proxies for impacts this also increases the risk that the wrong decision may bemade. This risk may still be within the risk appetite of the organization and the tolerance of those
who will experience the impacts.
Good decision-making is based on a combination of factors including the approach to data collection(what is collected from which source, how often, etc), the rate at which decisions are being made,the PE fund’s understanding of risk, both to the PE fund and those experiencing the impacts, and therequirement to increase the likelihood that the PE fund is contributing positively to sustainability
and the SDGs (and reduce the risk that it is not to an acceptable level). A fast rate of decisions based
only on data relating to expected material impacts would not be sufficient. A low rate based on datarequirements referenced in the Standards would not be sufficient.
The central risks are that the set of expected material impacts is incomplete (2.1.2.2), the data oneach impact is incomplete or the data is inaccurate or not timely. In each of these situations the risk
is that if the impacts or the data on impacts were complete, or if the inaccuracies were corrected,
then a different decision would be made.

Measurement practice
The purpose of collecting data is to enable evidence-based decisions. Decisions are between options
and the merit of each option are assessed in terms of their potential to increase the positive
contribution to sustainability and the SDGs. Options are generated from the data. No PE fund cansay that its approach to impact management is perfect or that it is making as much of a positive
contribution to sustainability and the SDGs as possible (with existing resources). The PE fund should
always be striving to improve its effectiveness and making changes across the business model.
The main means for generating options that lead to changes is by making comparisons, against
targets, against past performance and against peers but also, critically, by comparing data fordifferent data points between individuals with different characteristics but from the same
stakeholder group. Evidence is required that the data is reported in a format that allows thesecomparisons to be made, the comparisons being made lead to insights and options and then to
choices between options. Then the PE fund will monitor how the selected option is implemented
and whether it is on track to achieving the expected results and impacts. An PE fund making
comparisons but not subsequently making changes to its activities as a result would satisfy 2.1.2.2
but not 2.1.3.
Making decisions then requires a balance between the rate at which decisions are made and thedata available to support the decisions. Where the available data does not cover all therequirements or where data relates to proxies for impacts, this increases the risk that the wrong
decision may be made. This risk may still be within the risk appetite of the PE fund and the toleranceof those who will experience the impacts.
43

This does not mean a choice cannot be made. It means that the risk that the wrong decision may bemade has increased.

Minimum data requirements
The PE fund should collate (2.1.7) and review its performance in generating insights and learning
lessons from the data and acting on the results (2.1.3).
Whilst the balance of focus is towards decision making and responsiveness, there is nonetheless aminimum threshold for data collection. This is that:•

All expected material impacts are identified, i.e., in the sequence inputs, outputs, outcomes,
aspects of wellbeing, at least outcomes and preferably aspects of well-being are the basis formeasurement•

Where these are prioritized, the priorities relate to aspects of well-being (taking into
consideration inequality within and between stakeholder groups) and include climate action,
gender equality and decent work and also negative and positive expected impacts•

Data is collected for all metrics for those impacts expected to be most significant within context
of the PE fund’s resources together with a plan for collecting data on the others, which may
include incomplete data or measurement at an earlier point in the above sequence•

Where output data has been used as the basis for decisions, this is appropriate in the context ofthe decisions recognizing the risk that this may not result in the optimal or even any positive
contribution, for example a measured reduction in climate change emissions but with a nonmeasured increase in gender inequality.

•

The assumptions are reviewed and updated when context changes.

•

In deciding the balance between collecting statistically rigorous data (random samples) for the
metrics for the most significant impacts and collecting some data for the metrics of all material
impacts, the balance is on the risk associated with the intended decision. For many operational
decisions at the rate required this is on some data on more metrics across more impacts. For
strategy, business model and significant decisions this is on statistically rigorous data across all
metrics and all material impacts.

•

Impact data shall be complemented by the investees practices in regards to sustainability,
impact and the SDGs (see SDG Impact Standards for Enterprises).

As an example, the fund might identify ten expected material impacts, decide to measure all metrics
for four, only the change without considering duration, causation, and relative importance for threeand only the change in the outputs for the final three. Here an ambitious plan for addressing thedata gaps together with an assessment of the risk of using this data in decision should be put inplace.

Human Rights Based Approach to data collection
The Danish Institute for Human Rights, a leading organization in the field of Business and Human
Rights, stresses the importance of using a Human Rights Based Approach to data collection, basedon the precepts of participation, data disaggregation, self-identification, transparency, privacy, andaccountability.

Data ownership
The confidentiality, privacy and ethical considerations of collecting, using and sharing data involving
or pertaining to stakeholders should be carefully and responsibly managed in line with human rights
standards and the United Nations System Organization principles. This starts with the recognition
44

that the data belongs to the provider (i.e., the people experiencing the impacts) and that the PE fundis a steward of that data on their behalf. This includes informed consent or the International
Standard of free, prior, and informed consent (FPIC) in relation to indigenous peoples where
relevant, and taking into consideration cultural norms, legal requirements, personal data, safety,
education, and literacy levels.

Disaggregated data
In accordance with the Fundamental Principles of Official Statistics (General Assembly resolution
68/261) indicators – where feasible, data is disaggregated by income, sex, age, race, ethnicity,
migratory status, disability and geographic location, or other pertinent characteristics that
contribute to exclusion, inequality, or discrimination. Inclusive data sources may need to be
expanded to counter shortcomings in available data sets and factors that might inadvertently
compound disadvantage or discriminatory approaches.

Data quality
Impact data is actively managed, and its accuracy and completeness assessed to determine
implications for decision-making, including:•

Determining the most appropriate data sources for the decisions that need to be made (i.e.,enough precision for the decision)•

Where necessary, collecting data using more than one method or source (data triangulation,
third party research and evidence) to corroborate findings and reduce risk (e.g. reliability,
bias, relevance to context)•

Systematically checking assumptions and calculations and incorporating impact evidencerisks such as checking data for double counting, drop-off rates and failure rates. This includes
doing updates as needed.

•

Ensuring the utility of the underlying raw data is not lost by taking it out of the context ofother dimensions of impact (for example, not knowing the stakeholder group an outcome
indicator relates to), or by aggregating the data in a way that may impede clear
interpretation of the data and ensuring data can be compared on a period-to-period basis.

•

ensuring transparent documentation and audit trails for impact data collected (including
data sources, inferences and assumptions made, proxies used and any limitations) andincluding periodical reviews•

Assessing confidence in the data and documenting and factoring this risk into account indecision-making where confidence is low and making plans to improve confidence in future.

External assurance
Where there is external assurance, the approach to assurance should be consistent as set out in theStandards. It should•

address the approach to stakeholder engagement and the material completeness of the positive
and negative impacts resulting from the activities of the PE fund.

45

•refer to an existing assurance standard or equivalent approach as a basis for determining thework carried out providing assurance against a documented reporting framework or existing
reporting standard.

Where this is not the case, or where there is no assurance, the PE fund, in giving its reasons:•recognizes the risks of self-reporting or restricted assurance on the completeness of the positive
and negative impacts experienced as a result, and•that these risks include suboptimal impact including higher levels of negative impact than could
be caused, including impacts that exceed international norms or planetary boundaries.

••

REFERENCE FRAMEWORKS:
Social Value International (SVI) Principles of Social Value, Principle 7: Verify the results – “Ensure appropriate
independent assurance”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened
CFO Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG
STRATEGY AND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize
and monitor the implementation of the integrated SDG strategy and investments (board oversight, internal
controls and audit, executive remuneration and disclosure.”; Principle 4, INTEGRATED SDG
COMMUNICATION AND REPORTING “Business should engage in proactive investor communications about
their SDG impact thesis, strategy, and investments, including through investor calls and engagement, annual
financial disclosures, and integrated financial and sustainability reports.”; “Enhance integrated reporting
practices with key elements of SDG-aligned investments and finance, including impact measurement andvaluation, alignment of investments with strategy, and accounting and monitoring performance.”
OTHER RESOURCES:

•

•

46

Guidance Note 2.1.7. The Fund employs a dynamic approach to ensuring its impact
management practices remain fit for purpose by:
2.1.7.1 incorporating lessons from its impact management activities and impact
performance, including analyzing deviations from expected outcome/impact
performance
2.1.7.2 incorporating sector advances, new and updated research/evidence, andlessons from its engagement with partners and other Stakeholders
2.1.7.3 periodically reviewing and refining its impact management practices
considering changes in the sustainable development context and its impact
performance, impact thesis, investment strategy, and/or portfolio level impact goals.
See also Guidance note – Impact data collection and use
REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Review and update processes as appropriate on an on-going basis.”
OTHER RESOURCES:The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas and guide them on their performance assessment which can bemonitored over time. The Tools also enable users to update the outputs of the impact analysis based on thechanges of their business, their performance, and the sustainable development context.

Guidance Note 2.2. The Fund establishes criteria and pre-screens potential
investments to assess strategic alignment with its purpose and strategy, including its
impact thesis and portfolio level impact goals. The Fund:2.2.1 establishes investment pre-screening criteria to assess alignment with its
purpose, impact thesis/theses, investment strategy, portfolio level impact goals(including its portfolio composition) and its responsible business and impact
management policies and practices
2.2.2 pre-screens potential investments against its pre-screening criteria
2.2.3 for investments it intends to advance to the due diligence phase that have any
material gaps or shortcomings against its pre-screening criteria:
2.2.3.1 communicates these to potential investees
2.2.3.2 documents these for rectification (as conditions precedent or overtime post
investment close) through negotiation of impact terms and plans47

No additional guidance is needed48

Guidance Note 2.3 The Fund conducts ex ante impact assessments of potential
investments that pass its pre-screening criteria, to assess relevant and material
impacts, make informed choices between investment options, and so optimize its
impact performance in line with its portfolio level impact goals.
2.3.1 develops its impact thesis for each potential investment (see Impact thesis),
informed by its ex-ante impact assessment (see below)
2.3.2 develops impact assessment criteria for pre-screened investments that reflect
its portfolio level impact goals, and assesses all material (positive, negative, intended,and unintended) impacts systematically and consistently, incorporating the Five
Dimensions of Impact and associated data categories
2.3.3 engages with the local context to substantiate the relevant local or national SDG
and/or the sustainable development outcome thresholds, giving precedence tointernational norms where locally set thresholds are lower than international norms
2.3.4 assesses how the Investee is acting to avoid harm by preventing, reducing or
mitigating all material negative impacts in its direct operations and supply and value
chains (and if not the case, actions that can be introduced to do so)
2.3.5 determines the (positive and/or negative) contributions the Fund expects tomake (through its own actions) to the impact performance of each investment (seeInvestor contribution(s) to impact)
2.3.6 considers which metrics to use and how much data is sufficient to make adecision
No additional guidance is needed

Guidance Note 2.3.7. The Fund seeks to define the results from its impact
assessments consistently (e.g. using a common measure and defining outcomes interms of wellbeing) to facilitate systematic, evidence- and risk-based valuation anddecision making
See also Guidance note – Impact data collection and use

Using wellbeing as a consistent measure to value impacts
Impacts are the desired changes in wellbeing stakeholders experience resulting from the PE fund’s
decisions and actions. Aspects of wellbeing are economic, social, or environmental. Valuing impacts
in a systematic way is important because it helps decision-makers make more objective decisions –generating options, choosing between those options, and making trade-offs in a consistent way.
Without valuation, those decisions are often made based on underlying unconscious biases andassumptions which often reinforce existing inequities.
Using wellbeing to value and measure impacts requires taking into consideration:•

Stakeholders’ views of the relative importance (value) of the outcomes they experience inmaking those trade-offs,•

material impact risks and stakeholders’ risk appetite and tolerance for unexpected outcomes
and
49

•

interdependency of impacts and across the SDGs

The OECD Framework for Measuring Well-Being and Progress is an established framework formeasuring wellbeing built around three components: current well-being, inequalities in well-being
outcomes, and resources for future well-being.
There are a variety of qualitative, quantitative, and monetary approaches available for valuing
impacts – or changes in aspects of wellbeing. The Standards do not prescribe one approach overanother, rather expecting the decision-maker to select the most appropriate approach, taking into
account the nature of the decision and the amount of precision required.

Guidance note 2.3.8. The Fund makes (relative and absolute) choices between
investment options accounting for trade-offs and impact risks to optimize impact
performance and contribution to sustainable development and achieving the SDGs
Making decisions in context
Making decisions in context means thinking holistically (informed by stakeholder perspectives andfocusing on all material impacts in the investees direct operations and through business
relationships, as well as through upstream and downstream supply and value chains).
Making decisions in context requires an understanding of interdependency across the SDGs as
actions in one area can impact other areas.
It also means taking into consideration where you are starting from (establishing baselines),
understanding where you need to get to (what is needed in order to reach or exceed required
thresholds in a timely way) and understanding what will happen anyway irrespective of what the PE
fund does – or in other words, what contribution or difference the PE fund’s decisions are making.

Leaving “no-one” behind
The PE fund should consider heterogeneity among stakeholders and seek to identify those most in
need as this would potentially allow to maximize positive contribution to the SDGs.
Assessing the impacts on different groups and sub-groups of stakeholders separately is important toensure the overarching objectives of the SDGs (to leave no one behind) are met – for example, by
including previously excluded stakeholders, or by not creating benefits for one group of stakeholders
at the expense of other stakeholder groups. This concept is linked to guidance note 2.3.2 on using
sufficiently disaggregated data to make decisions.
REFERENCE FRAMEWORKS:The OECD Framework for Measuring Well-Being and Progress, an established framework for measuring wellbeing
built around three components: current well-being, inequalities in well-being outcomes, and resources for future
well-being https://www.oecd.org/statistics/measuring-well-being-and-progress.htm
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed to50

achieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
Impact Management Project (IMP), five dimensions of impact, provides guidance on the types of data needed tounderstand and assess impact performance. The IMP community of 2,000+ practitioners identified fivedimensions of impact, which can be broken down into 15 more detailed data categories. Organizations can use
the five dimensions as a checklist to ensure the information gathered is sufficient for the decision it will inform(see also the ABC methodology and SDG Impact Standards Glossary).
https://impactmanagementproject.com/impact-management/how-PE funds-manage-impact/ and Five
Dimensions of Impact (Impact Management Norms), https://impactmanagementproject.com/impactmanagement/impact-management-norms/
The Fundamental Principles of Official Statistics (General Assembly resolution 68/261) – where feasible, data
should be disaggregated (i.e., segmented) by income, sex, age, race, ethnicity, migratory status, disability andgeographic location, or other characteristics pertinent to the PE fund’s impact goals.
ILO convention 169: prior consultation and participation of indigenous peoples in decisions affecting them, andabout free and informed consent on private activities in their territories.
Social Value International (SVI): A Discussion Document on The Valuation of Social Outcomes
Social Value International (SVI) Principles of Social Value, Principle 1: Involve stakeholders – “Inform what getsmeasured and how this is measured and valued in an account of social value by involving stakeholders (thepeople who experience change as a result of your activity”.
Social Value International “Standard on applying Principle 1: Involve stakeholders” explains options and processes
for identifying stakeholders and meaningfully engaging stakeholders, including sample questions to ask. This
Standard talks about how speaking to and involving people who experience change to understand actual andpotential significant impacts. It also acknowledges that speaking directly to stakeholders is not the only source of
relevant information. Third party research may be complementary to what you hear from stakeholders or may be
a substitute if your stakeholders are particularly difficult to reach, or if they do not feel comfortable sharing theiropinions. https://socialvalueint.org/wp-content/uploads/2019/03/Standard-on-Stakeholder-Involvement-V2.0FINAL-1.pdf
Social Value International (SVI), Principles of Social Value: Principle 2 Understand what changes – “Articulate howchange is created and evaluate this through evidence gathered, recognizing positive and negative changes aswell as those that are intended and unintended”.
Social Value International (SVI) Standard for applying Principle 2: Understand what changes, Part One: Creating
well defined outcomes. This practice standard sets out how to engage with stakeholders to collaboratively agree
on which outcomes to measure and contains guidance on how an organization can examine “chains of events”
and engage with stakeholders to decide the most appropriate point of measurement to support management
decision-making (framed as “well-defined” outcomes)
Social Value International (SVI) Principles of Social Value, Principle 3: Value what matters – “Making decisions
about allocating resources between different options needs to recognize the values of stakeholders. Value refers
to the relative importance of different outcomes. It is informed by stakeholders’ preferences”.
Social Value International (SVI) Standard for applying Principle 3: Value the things that matter – guidance to value
impacts from the perspective of affected stakeholders, emphasizing the importance of using data collected
directly from stakeholders.
Social Value International (SVI) Principles of Social Value, Principle 4 – “Determine what information and evidence
must be included in the accounts to give a true and fair picture, such that stakeholders can draw reasonableconclusions about impact”.

51Social Value International (SVI) Standard for applying Principle 4: Only include what is material – “Determine what
information and evidence must be included in the accounts to give a true and fair picture, such that stakeholders
can draw reasonable conclusions about impact”. This standard provides guidance on collecting information toassess the impacts that matter most to stakeholders, in order to decide which to continue measuring andmanaging. https://socialvalueint.org/social-value/standards-and-guidance/standard-applying-for-principle-4only-include-what-is-material/
Social Value International (SVI) Principles of Social Value, Principle 8: Be Responsive – (work in progress) “making
decisions that optimize value for all stakeholder groups materially affected. Consideration of risks and rigour ofdata in context of decisions being made”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Implement specific processes, criteria and methodologies to identify
Positive Impact. The analysis should cover activities, projects and programmes but also underlying companies; Apply
regular ESG risk management before determining Positive Impact eligibility.”
UNEPFI Principles for Responsible Banking, Principle 2: Impact & Target Setting – We will continuously increase
our positive impacts while reducing the negative impacts on, and managing the risks to, people and theenvironment resulting from our activities, products, and services. To this end, we will set and publish targets
where we can have the most significant impacts.
Capitals Coalition Natural and Social and Human Capital Protocols outline a process that organizations should
follow to identify, measure and value their impacts and dependencies on the natural environment and on socialand human capital respectively and can be used to value impacts and dependencies on natural and social andhuman capital respectively. This framework draws on organizational data, data collected from stakeholders, andpublicly available country- or sector-level data.
British Standards Institution, BS 8950 Social Value – Understanding and enhancing – Guide (Draft, 2020).
OTHER RESOURCES:
Social Value International: A Discussion Document on The Valuation of Social OutcomesOECD Due Diligence Guidance for Responsible Business Conduct helps organizations comply with the OECD
Guidelines for Multinational PE funds providing guidance on setting up due diligence processes to identify andaddress principal adverse impacts in operations, supply chain and business relationships.
SDG Action Manager (developed by B Lab and the United Nations Global Compact) is a tool designed to helporganizations measure and manage their impacts in relation to the Sustainable Development Goals.
Organizations can fill in the online questionnaire to get a quick read on the Sustainable Development Goals likely
to be the most relevant to manage, based on the organization’s size, sector, and geography. The questionnairedraws from B Lab’s B Impact Assessment, which is developed through research and public consultation and so
provides an evidence-based starting point for identifying sustainability topics to measure.
Impact Lab (developed by Business Call to Action, BCtA) is an online tool/resource that aims to guide companies
on their impact measurement. Through this lab, BCtA aims to help both BCtA members and non-members in theprocess of identifying the right tools for collecting and analyzing data on their social and environmental
performance to inform their business decisions. The online Lab comprises four modules 1) assess their impact

52

measurement readiness 2) design their impact measurement frameworks 3) monitor their impact and 4) analyze
their collected data.
The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas based on the nature of their business and the sustainable
development needs of the countries in which they operate. Moreover, they guide users on their performanceassessment based on which meaningful targets can be set.
EU Taxonomy by the European Commission is a rating methodology that sets out performance thresholds fororganizations to classify their economic activities as “sustainable:" according to European policy objectives.
Organizations can use the EU Taxonomy to find the economic activities that correspond to the organization andreview what the taxonomy says about likely impacts on sustainability. This can be an input into identifying
sustainability topics to measure. This regulation is based on research connecting NACE economic activities tolikely significant impacts on six environmental objectives. Currently, research related to objectives of climatechange mitigation and adaptation are most developed.
UNCTAD core indicators for entity reporting on contributions towards implementation of the Sustainable
Development Goals (GCI). The GCI is a set of core universal baseline indicators common to all businesses of all
types and sizes aimed to facilitation harmonization and comparability of SDG reporting by companies. The GCI
has been endorsed by UNCTAD member states, are selected based on main reporting frameworks and PE fundpractices and aligned with the SDG indicators monitoring framework. https://unctad.org/webflyer/guidance-coreindicators-entity-reporting-contribution-towards-implementation-sustainable
UNCTAD GCI Training Material https://isar.unctad.org/wp-content/uploads/2020/04/UNCTAD_DIAE_2020_2.pdf
HIPSO indicators (Harmonized Indicators for Private Sector Operations) are a list of reporting indicators set acrossvarious sectors and industries (including cross-cutting). They have definitions that have been agreed upon by 28
different development finance institutions from around the world, all of whom have signed the MoU on
harmonized indicators. These indicators may be used by any entity wishing to use them.
Global Reporting Initiative (GRI) is developing Sector Standards for 40 sectors to complement their current topic
standards that will provide a list of topics for each Sector Standard as an input when identifying sustainability
topics to measure https://www.globalreporting.org/capitals-approach/social-human-capital-protocol/
GRI Universal Standards (Exposure draft) are multi-stakeholder sustainability reporting standards that can be used
to help conduct a materiality assessment to help identify sustainability topics to measure and manage
https://www.globalreporting.org/standards/standards-development/review-of-the-universal-standards/
IRIS+ System by Global Impact Investing Network (GIIN) is a tool designed to help impact investors translate
intentions into results (hence investors may request businesses they invest in to report using these metrics, andthey may be useful to businesses looking to select appropriate metrics to measure, manage and report theirimpacts). IRIS+ metrics and metric sets are aligned to the SDGs and five dimensions of impact and work isunderway to map various investor metric sets and corporate disclosure standards with a view to achieving global
consistency, including IRIS+-GRI, B Lab-IRIS+, HIPSO-IRIS+. It starts by helping investors frame their impact goals
in a common way (linked to an SDG or Impact Category) and offers a set of metrics (Core Metrics Sets) to assess
performance against set goals, together with an evidence base (Navigating Impact) and implementation
guidance.
CDP Questionnaires are a tool to measure and disclose on climate change, forests, and water security impacts.
These online questionnaires provide a framework for companies to provide environmental information to theirstakeholders covering governance and policy, risks and opportunity management, environmental targets andstrategy, and scenario analysis. The questionnaire can provide a quick read on the climate change, forests and53

water security impacts that are likely relevant to measure, based on the organization’s size, sector, andgeography.
World Benchmarking Alliance (WBA) Benchmark Methodologies are benchmarks that rank companies based on
their impact across seven systems that require transformation to achieve a sustainable future. Organizations canuse the list of topics in the relevant ‘system’ to help identify sustainability topics to measure.
B Impact Assessments (developed by B Lab) is a tool designed to help organizations measure and manage theirimpacts on workers, community, environment, and customers. Organizations can get a quick read on
performance on sustainability topics that are likely relevant to manage, based on the organization’s size, sector,
and geography. B Lab’s questionnaire is developed through research and public consultation, and so provides anevidence-based starting point for identifying sustainability topics to measure.
IFC’s Anticipated Impact Measurement and Monitoring (AIMM) framework
OECD’s Policy Brief on Social Impact Measurement for Social PE funds, Policies for Social Entrepreneurship
UN Global Compact Guidelines on Supply Chain Sustainability
OECD Due Diligence Guidance for Meaningful Stakeholder Engagement in the Extractive Sector, Feb 2017)
UNRISD with r3.0 its Three-Tiered Typology, introduced in the Compared to What? Paper a framework thatcompares the PE funds’ impact with thresholds, divided into three tiers:
Tier One: Incrementalist Numeration: Numerator indicators focus on actual impacts, including absolute indicators,
as well as relative or intensity indicators that are non-normative, and therefore incrementalist.
Tier Two: Contextualized Denomination: Denominator indicators contextualize actual impacts against normative
impacts. Also known as “Context-Based” indicators, denominator indicators take into account sustainability
thresholds in ecological, social, and economic systems, as well as allocations of those thresholds to organizations
and other entities.
Tier Three: Activating Transformation: Transformative indicators add the element of implementation and policy tonormative denominator indicators to instantiate change within complex adaptive systems
Source: r3.0
A guide to social return on investment (developed by Social Value International, SVI) – follow methodology tomonetize the social value an organization creates, preserves, erodes for stakeholders (society).
Impact-Weighted Accounts Initiative is research on impact valuation published in the form of case studies andwhite papers which organizations can use to learn about key considerations when monetizing impact using
publicly available information https://www.hbs.edu/impact-weighted-acccounts/Pages/default.aspx
Maximise Your Impact, A Guide for social entrepreneurs provides organizations with guidance on whether it has
all of the information it needs to assess impact. The guidance contains ten questions that guide impact
assessment, and function as a checklist to ensure all necessary contextual information is collected.
https://socialvalueint.org/wp-content/uploads/2018/05/MaximiseYourImpact.24.10.17.pdf
The Science Based Targets initiative by CDP, the World Resources Institute (WRI), WWF and the UN Global
Compact, which is developing tools and methodologies for companies to set targets that align with the prevailingscientific consensus that global temperatures should not rise above two degrees Celsius.

54

The Future-Fit Benchmarks developed by Natural Step which identify a set of ‘absolute’ goals that are based onsocial and natural science and that all companies must ultimately strive to reach, irrespective of the products andservices they offer.
WBCSD’s Action2020 which sets the agenda for business to take action on sustainable development to 2020 andbeyond. Action2020 defines societal targets, ‘Societal Must-Haves’ and around nine Priority Areas, based on ascientific review led by the Stockholm Resilience Centre.
The United Nations website which contains public commitments to goals and targets announced by companies.
PivotGoals by Winston Eco-Strategies which allows users to browse goals and targets set by Global 500
companies.

Guidance note 2.3.9. The Fund determines whether comprehensive ex ante or ex post(independent third party) impact evaluations in line with international guidance are
required for certain investments
Comprehensive independent impact evaluations
Comprehensive impact evaluations are generally third-party independent assessments undertaken
by qualified evaluators. These are additional to the regular impact assessment and monitoring
activities conducted internally by management. An independent comprehensive impact evaluation
may be appropriate where the potential impacts (especially risks to stakeholders) are especially high(for example, a large mining operation situated on indigenous lands). They won’t be feasible (on acost-to-value basis) for many activities, nor relevant to many types of impact decisions PE funds willneed to make.
The criteria to undertake comprehensive and independent impact evaluations should be defined,
transparent and based on:•

the size of the investment (in absolute and relative terms)•

the expected impact and impact risk (including with respect to human rights)•

the country and sector risk•

the learning potential (e.g., activities/projects in new markets and sectors)•

the strategic importance of the activity/project•

the newness of the intervention (e.g., pilots)

Results of any comprehensive impact evaluations should also be made available to stakeholders.
REFERENCE FRAMEWORKS:
Social Value International (SVI) Principles of Social Value, Principle 7: Verify the results – “Ensure appropriate
independent assurance”.
Social Value International (SVI) Principles of Social Value, Principle 8: Be Responsive – (work in progress) “making
decisions that optimize value for all stakeholder groups materially affected. Consideration of risks and rigour ofdata in context of decisions being made”.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,55

and/or entities to be financed or invested in. “Seek second opinions and/or third-party assurances on theimplementation of the above processes as appropriate.”
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Assessment, Principle 4:
The assessment of Positive Impact Finance delivered by entities (financial or non-financial), should be based on
the actual impacts achieved. The assessment of Positive Impact Finance can be internally processed, i.e., forinternal monitoring and evaluation purposes, or undertaken by qualified third parties (i.e., auditing companies,
research providers, and rating agencies), for certification and/or rating purposes.
OTHER RESOURCES:
OECD Due Diligence Guidance for Responsible Business Conduct helps organizations comply with the OECD
Guidelines for Multinational PE funds providing guidance on setting up due diligence processes to identify andaddress principal adverse impacts in operations, supply chain and business relationships.
OECD’s Better Criteria for Better Evaluation: Revised Evaluation Criteria, Definitions and Principles for Use
OECD/DAC’s Network on Development Evaluation, 2019

Guidance note 2.3.10. The Fund captures the results from its impact assessments(including documenting its calculation methodologies and assumptions applied) in its
impact management system so it can be connected to its decision making andongoing impact management activities.
Risk-based approach to data verification or assurance
Decision makers will always need assurance that the information they have to inform their decisions
is good enough for the decision. There is always a risk and this will need to be within the decision
maker’s risk appetite. If the consequences to stakeholders of decisions based on the data being
wrong are high, for instance, the decisions have a big impact on stakeholders and are not easily
reversed, more data and more formal assurance of the impact data being relied upon to make thosedecisions may be needed.
This may include collecting data using more than one method or source (data triangulation, third
party research and evidence) to corroborate findings and reduce risk (e.g., reliability, bias, relevanceto context) or seeking third party verification or assurance of the data.
Established criteria should be in place to guide when more data or third-party data validation or
assurance of that data is required. Investing in organizations that get assurance on practice, data
quality and undertake evaluations is encouraged.
REFERENCE FRAMEWORKS:The Fundamental Principles of Official Statistics (General Assembly resolution 68/261) – where feasible, data
should be disaggregated (i.e., segmented) by income, sex, age, race, ethnicity, migratory status, disability andgeographic location, or other characteristics pertinent to the PE fund’s impact goals.
United Nations System Organization principles (for data management).
International Standard of free, prior, and informed consent (FPIC)

56

Social Value International (SVI) Principles of Social Value, Principle 7: Verify the results – “Ensure appropriate
independent assurance”.
Social Value International (SVI) Principles of Social Value, Principle 8: Be Responsive – (work in progress) “making
decisions that optimize value for all stakeholder groups materially affected. Consideration of risks and rigour ofdata in context of decisions being made”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria”; “Leverage and strengthen corporate governance mechanisms to
incentivize and monitor the implementation of the integrated SDG strategy and investments (board oversight,
internal controls and audit, executive remuneration and disclosure.”Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Implement specific processes, criteria and methodologies to identify
Positive Impact. The analysis should cover activities, projects and programmes but also underlying companies.”
OTHER RESOURCES
Danish Institute for Human Rights, ‘Human Rights Impact Assessment Guidance and Toolbox’
Corporate Human Rights Benchmark, https://www.corporatebenchmark.org/who-we-are, last accessed 2
September 2020, measures progress on business adherence to international human rights standards.
Capitals Coalition Protocols (see Step 08) and the Capitals Checker – additional guidance on selecting andassessing the usefulness and confidence levels required of impact data.
Impact Lab (developed by Business Call to Action, BCtA) is an online tool/resource that aims to guide companies
on their impact measurement. Through this lab, BCtA aims to help both BCtA members and non-members in theprocess of identifying the right tools for collecting and analyzing data on their social and environmental
performance to inform their business decisions. The online Lab comprises four modules 1) assess their impact
measurement readiness 2) design their impact measurement frameworks 3) monitor their impact and 4) analyze
their collected data
SDG Compass Guide (developed by UN Global Compact, GRI, and WBCSD) provides guidance for companies on
how they can align their strategies as well as measure and manage their contribution to the realization of theSDGs https://sdgcompass.org/
Maximise Your Impact: A Guide for Social Entrepreneurs. https://socialvalueint.org/wpcontent/uploads/2018/05/MaximiseYourImpact.24.10.17.pdf
The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The tools guideusers in their data collection process of the identification and assessment phases.
IMP Using self-reported data for impact measurement,
Data governance and data policies at the European Commission

57

Data Privacy, Ethics and Protection Guidance Note on Big Data for Achievement of the 2030 Agenda by the
UNSDG
International Standard of free, prior, and informed consent (FPIC)
outcomes map created by Social Value International.
The Guide to the Assessment of Socio-Environmental Impact, produced by Insper Metricis in Brazil
UNCTAD core indicators for entity reporting on contributions towards implementation of the Sustainable
Development Goals (GCI). The GCI is a set of core universal baseline indicators common to all businesses of all
types and sizes aimed to facilitation harmonization and comparability of SDG reporting by companies. The GCI
has been endorsed by UNCTAD member states, are selected based on main reporting frameworks and PE fundpractices and aligned with the SDG indicators monitoring framework. https://unctad.org/webflyer/guidance-coreindicators-entity-reporting-contribution-towards-implementation-sustainable
UNCTAD GCI Training Material https://isar.unctad.org/wp-content/uploads/2020/04/UNCTAD_DIAE_2020_2.pdf
HIPSO indicators (Harmonized Indicators for Private Sector Operations) are a list of reporting indicators set acrossvarious sectors and industries (including cross-cutting). They have definitions that have been agreed upon by 28
different development finance institutions from around the world, all of whom have signed the MoU on
harmonized indicators. These indicators may be used by any entity wishing to use them.
GRI Sustainability Reporting Standards are designed to help organizations understand and report their impacts ina way that meets the needs of multiple stakeholders. There are a set of Universal Standards that apply to allorganizations, and 35 Topic Standards that contain disclosures for impacts related to economic, environmental,
and social topics. Organizations can use the standards to report to stakeholders on “material” topics that reflect
the organization’s most significant impacts.
IRIS+ System by Global Impact Investing Network (GIIN) is a tool designed to help impact investors translate
intentions into results (hence investors may request businesses they invest in to report using these metrics, andthey may be useful to businesses looking to select appropriate metrics to measure, manage and report theirimpacts). IRIS+ metrics and metric sets are aligned to the SDGs and five dimensions of impact and work isunderway to map various investor metric sets and corporate disclosure standards with a view to achieving global
consistency, including IRIS+-GRI, B Lab-IRIS+, HIPSO-IRIS+. It starts by helping investors frame their impact goals
in a common way (linked to an SDG or Impact Category) and offers a set of metrics (Core Metrics Sets) to assess
performance against set goals, together with an evidence base (Navigating Impact) and implementation
guidance.

Guidance Note
2.4 The Fund engages openly, proactively, and collaboratively with limited partners andpotential Investees during the due diligence and investment structuring phase, to agree on
how to embed impact considerations within the investment terms, and so optimize future
impact performance.
2.4.1 The Fund is transparent with potential Investees and limited partners about its
investment strategy, impact thesis and portfolio level impact goals and communicates
its expectations about impact management, impact reporting, transparency andgovernance2.4.2 The Fund satisfies itself of potential Investees’ commitment to sustainable
development and impact management and their:58

2.4.2.1 strategic alignment with sustainable long term value creation and theFund’s impact thesis relating to the investment, or where there aredifferences or gaps, these have been accounted for in the Fund’s impact risk
assessment (see below)
2.4.2.2 adequacy of systems in place (orto be put in place)to manage
impact(including impact risk) appropriately (no additional guidance is needed)
2.4.2.3 ability and willingness to improve, adapt and learn, including to rectify
shortcomings and/or change direction based on results (no additional guidanceis needed)

2.4.2.4 governance practices, including independent oversight from a bodycomprising competencies concerning sustainable development issues andimpact management (no additional guidance is needed)
Selecting metrics
Collecting, monitoring, and evaluating data and metrics requires a resource commitment – fromboth the PE fund and those it collects data from. Therefore, data and metrics selection should focus
on information that is decision-useful and proportionate to the decision being made (i.e., enoughprecision for the decision), including taking into consideration the risks to stakeholders if decisions
based on that data and metrics results in outcomes that are different from what is expected.
When selecting metrics, there are benefits of choosing standardized metrics as they allow
aggregation for portfolio analysis and comparison (not only between options but also vis a vis
external organizations). Standardized metrics are more likely to be clearly defined and use the same
unit of measure. There is also more data publicly available for standardized indicators. However, firstand foremost, the focus should be on selecting data and metrics that are decision-useful, which may
require the use of internally generated, non-standardized or bespoke metrics.
When it is not possible to obtain reliable impact metrics, proxies (activity or output metrics) areoften used instead. When using proxies, it is important to determine whether there is a strong
enough and evidence-based causal link between the activities or outputs and the intended impacts
and take into account additional risks that using proxies may present in decision-making.
REFERENCE FRAMEWORKS:
Social Value International (SVI) Principle 2: Understand what changes – “Articulate how change is created andevaluate this through evidence gathered, recognizing positive and negative changes as well as those that are
intended and unintended”.
SVI’s Standard on Applying Principle 2: Understand what changes Part Two: Designing indicators (metrics) tomeasure the outcomes. This practice standard builds on the previous “Part One”, outlining how to design custom
metrics to measure a “well defined” outcome.
Social Value International (SVI) Principles of Social Value, Principle 8: Be Responsive – (work in progress) “making
decisions that optimize value for all stakeholder groups materially affected. Consideration of risks and rigour ofdata in context of decisions being made”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.

59Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Implement specific processes, criteria and methodologies to identify
Positive Impact. The analysis should cover activities, projects and programmes but also underlying companies.”
UNEPFI Principles for Responsible Banking, Principle 2: Impact & Target Setting – We will continuously increase
our positive impacts while reducing the negative impacts on, and managing the risks to, people and theenvironment resulting from our activities, products, and services. To this end, we will set and publish targets
where we can have the most significant impacts.
(The Capitals Coalition Natural Capital Protocols and Social and Human Capitals Protocols are the internationallyaccepted harmonized framework for identifying, measuring and valuing the impacts and dependencies on naturaland social and human capital and outline a series of actions that will help organizations integrate sustainable
development and impact management into management decision-making (see Measure and Value Stage). See
also Capitals Coalition, Principles of Integrated Capitals Assessments.
OTHER RESOURCES:UN Sustainable Development Knowledge Platform https://sustainabledevelopment.un.org/vnrs/ contains thesustainable development goals, targets and indicators and information from the Voluntary National Reviews ofprogress towards achieving the SDGs conducted by member states.
the Fundamental Principles of Official Statistics (General Assembly resolution 68/261) - i.e. where feasible, data
should be disaggregated (i.e. segmented) by income, sex, age, race, ethnicity, migratory status, disability andgeographic location, or other characteristics pertinent to the PE fund’s impact goals
SDG Compass Guide (developed by UN Global Compact, GRI, and WBCSD) provides guidance for companies on
how they can align their strategies as well as measure and manage their contribution to the realization of theSDGs https://sdgcompass.org/
UNCTAD core indicators for entity reporting on contributions towards implementation of the Sustainable
Development Goals (GCI). The GCI is a set of core universal baseline indicators common to all businesses of all
types and sizes aimed to facilitation harmonization and comparability of SDG reporting by companies. The GCI
has been endorsed by UNCTAD member states, are selected based on main reporting frameworks and PE fundpractices and aligned with the SDG indicators monitoring framework. https://unctad.org/webflyer/guidance-coreindicators-entity-reporting-contribution-towards-implementation-sustainable
UNCTAD GCI Training Material https://isar.unctad.org/wp-content/uploads/2020/04/UNCTAD_DIAE_2020_2.pdf
HIPSO indicators (Harmonized Indicators for Private Sector Operations) are a list of reporting indicators set acrossvarious sectors and industries (including cross-cutting). They have definitions that have been agreed upon by 28
different development finance institutions from around the world, all of whom have signed the MoU on
harmonized indicators. These indicators may be used by any entity wishing to use them.
GRI Sustainability Reporting Standards are designed to help organizations understand and report their impacts ina way that meets the needs of multiple stakeholders. There are a set of Universal Standards that apply to allorganizations, and 35 Topic Standards that contain disclosures for impacts related to economic, environmental,
and social topics. Organizations can use the standards to report to stakeholders on “material” topics that reflect
the organization’s most significant impacts.
IRIS+ System by Global Impact Investing Network (GIIN) is a tool designed to help impact investors translate
intentions into results (hence investors may request businesses they invest in to report using these metrics, andthey may be useful to businesses looking to select appropriate metrics to measure, manage and report theirimpacts). IRIS+ metrics and metric sets are aligned to the SDGs and five dimensions of impact and work isunderway to map various investor metric sets and corporate disclosure standards with a view to achieving global

60

consistency, including IRIS+-GRI, B Lab-IRIS+, HIPSO-IRIS+. It starts by helping investors frame their impact goals
in a common way (linked to an SDG or Impact Category) and offers a set of metrics (Core Metrics Sets) to assess
performance against set goals, together with an evidence base (Navigating Impact) and implementation
guidance.
The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas based on the nature of their business and the sustainable
development needs of the countries in which they operate. Moreover, they guide users on their performanceassessment based on which meaningful targets can be set. The Tools have an in-built indicator library which
provides a compilation of impact-related indicators and metrics, useful for assessing the performance and forsetting meaningful targets. This is a
B Impact Assessments by B Lab can be used as asset of metrics. The questionnaire enables organizations toquickly get started collecting information on performance on sustainability topics that are likely relevant tomeasure and manage based on the organization’s size, sector, and geography.
CDP Questionnaires are a tool to measure and disclose on climate change, forests and water security impacts andcan also be used as a set of metrics.
GRI Sustainability Reporting Standards are designed to help organizations understand and disclose their impacts
in a way that meets the needs of multiple stakeholders. The standards can be used to provide guidance on
identifying metrics to measure each significant impact and provide guidance on what to report. Using
standardized metrics can help the organization and its stakeholders compare performance with others.
the World Benchmarking Alliance (whose benchmarks are constructed of metrics for measuring companies’
performance against the SDGs)
UN RISD’s Sustainable Development Performance Indicator research project
Maximise Your Impact, A Guide for social entrepreneurs provides organizations with guidance on whether it has
all of the information it needs to assess impact. The guidance contains ten questions that guide impact
assessment, and function as a checklist to ensure all necessary contextual information is collected.
https://socialvalueint.org/wp-content/uploads/2018/05/MaximiseYourImpact.24.10.17.pdf
Measuring Social Change, Alnoor Ebrahim of Tufts University
The Guide to the Assessment of Socio-Environmental Impact, produced by Insper Metricis in Brazil.
SVI’s Standard on Applying Principle 3: Value the things that matter
Beneficiary Assessment: An Approach Described | Better Evaluation

61

Risk management
Risk is unavoidable when making choices between options designed to increase positive contribution
to sustainability and the SDGs. Risk as referred to in the Standards covers both the risk that theresult will be less than expected and the uncertainty implicit within the impact management
approach. There is uncertainty:•••

that all the expected changes in aspects of well-being for people and planet have been
identified;
about the expected change (magnitude, duration, direction of the change) for each and in
subsequent measurement; andabout the extent to which proxies are good enough approximations, for example using outputs
as proxies for impacts.

When making decisions between options it will often be a comparison between an existing way of
doing things and a projected or forecast way of doing things. Choosing the option that is a forecast
will be based on forecast data and not on actual data where there is more uncertainty. Approaches
to impact measurement based only on measuring past impact could reduce an PE fund’s willingness
to choose options based on expected impact and reduce the rate of decision making and therefore
are unlikely to be sufficient.
The approach to impact management is designed to reduce measurement uncertainties to an
acceptable level. The PE fund should consider options, and its approach to forecasting should beconsistent with the approach to measurement, informed by past experience or other research and,depending on risk assessment, supported by sensitivity.
Within 2.1.6, the PE fund needs to understand the risk that the impact will be less than expected has
consequences, potentially both for the PE fund and for the people experiencing the impacts. This
could range from slightly lower positive impact than expected to a negative impact. It could include
a positive impact for the majority of the group in line with expectations but a negative impact for aminority of the group. Forecasts and scenario planning should consider these risks, that the actual
impacts do not occur as and when expected. It should also include risk tolerance from those thatwould experience the negative impacts.

Risk management – data gaps
The risk that impacts will not occur as and when expected increases where there are data gaps.
These arise when an PE fund is using predetermined lists of outputs, outcomes, or changes in
aspects of well-being instead of meaningful stakeholder engagement as the basis for measurement
or where data is not collected for all the data points for each material impact.
Predetermined lists increase the risk that relevant potential material impacts are not identified thus
affecting what is prioritized and what decisions are made. Missing data points also increase the risk
since having incomplete data could affect decisions.
Recognition of the risks to both quantity and quality of decisions and therefore for determining
whether there is a positive contribution to sustainability and the SDGs is needed and to the extent
there are significant gaps, an ambitious plan put in place for developing the approach subject to2.1.6.
62

REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Implement specific processes, criteria, and methodologies to monitor
the achievement of intended impacts throughout the life-time of the financial instrument.”
OTHER RESOURCES:The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas based on the nature of their business and the sustainable
development needs of the countries in which they operate. Moreover, they guide users on their performanceassessment which can be monitored over time and based on which meaningful targets can be set and action
points defined. Finally, the Tools enable users to update the outputs of the impact analysis based on the changesof their business, performance, and the sustainable development context

Guidance note 2.4.3 The Fund engages openly, proactively and collaboratively withpotential Investees and limited partners throughout the impact due diligence andinvestment structuring phase to align and set shared impact and financial objectives,terms and expectations.
No additional guidance is needed

Guidance note 2.4.4 The fund documents agreed impact and financial objectives,terms and expectations within the legal documents of the investment agreement.
No additional guidance is needed

63Guidance Note
The Fund2.5.1. develops an effective monitoring system to assess progress against its portfolio
level impact goals and investment level impact targets and relevant SDG and/or othersustainable development outcome thresholds, baselines and counterfactuals to
inform decision making
2.5.2 monitors and manages Investees’ adherence to impact terms (including toembed Stakeholder involvement in impact monitoring and management activities)
and progress against impact plans
Monitoring
Monitoring means comparing progress in the achievement of impact (performance) against theambitious and rigorous targets (targets based on the measurement requirements in 2.3.6).
The PE fund should have a framework to identify, analyze, and report internally on deviations fromexpected performance and the reasons why these happen as well as mechanisms in place to takecorrective actions to address any deviations. Potential actions include a justified change to targets, achange to aspects of the business model or a decision to accept the difference without further
action. Changes to the business model represent a subset of alternatives to be considered. Although
the focus should be on first addressing negative impacts (2.3.4), the PE fund should also collect dataon unexpected positive impacts to influence design of products and services and to increase futuretargets.
The deviations are opportunities for insights that lead to consider options for improved decisionmaking in 2.5.5.1. For the avoidance of doubt, mitigation plans include options to avoid negative
impacts and/or diminution or cessation of future positive impacts.
A critical source of insights is comparison of the impacts, across the dimensions, experienced by astakeholder group based on different characteristics within the group. Alternative characteristics orgroups of characteristics should be considered, differences reported, and insights generated, andoptions created, and choices made.
REFERENCE FRAMEWORKS:
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed toachieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
Impact Management Project (IMP), five dimensions of impact, provides guidance on the types of data needed tounderstand and assess impact performance. The IMP community of 2,000+ practitioners identified fivedimensions of impact, which can be broken down into 15 more detailed data categories. Organizations can use
the five dimensions as a checklist to ensure the information gathered is sufficient for the decision it will inform(see also the ABC methodology and SDG Impact Standards Glossary).

64https://impactmanagementproject.com/impact-management/how-PE funds-manage-impact/ and Five
Dimensions of Impact (Impact Management Norms), https://impactmanagementproject.com/impactmanagement/impact-management-norms/
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Implement specific processes, criteria, and methodologies to monitor
the achievement of intended impacts throughout the life-time of the financial instrument.”
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Assessment, Principle 4:
The assessment of Positive Impact Finance delivered by entities (financial or non-financial), should be based on
the actual impacts achieved. The assessment of Positive Impact Finance can be internally processed, i.e., forinternal monitoring and evaluation purposes, or undertaken by qualified third parties (i.e., auditing companies,
research providers, and rating agencies), for certification and/or rating purposes.
Capitals Coalition Natural and Social and Human Capital Protocols outline a process that organizations should
follow to identify, measure and value their impacts and dependencies on the natural environment and on socialand human capital respectively and can be used to value impacts and dependencies on natural and social andhuman capital respectively. This methodology draws on organizational data, data collected from stakeholders,and publicly available country- or sector-level data (see Apply Stage).
OTHER RESOURCES:
OECD Due Diligence Guidance for Responsible Business Conduct helps organizations comply with the OECD
Guidelines for Multinational PE funds providing guidance on setting up due diligence processes to identify andaddress principal adverse impacts in operations, supply chain and business relationships.
Impact Lab (developed by Business Call to Action, BCtA) is an online tool/resource that aims to guide companies
on their impact measurement. Through this lab, BCtA aims to help both BCtA members and non-members in theprocess of identifying the right tools for collecting and analyzing data on their social and environmental
performance to inform their business decisions. The online Lab comprises four modules 1) assess their impact
measurement readiness 2) design their impact measurement frameworks 3) monitor their impact and 4) analyze
their collected data.
SDG Action Manager (developed by B Lab and the UN Global Compact) is a tool designed to help organizations
measure and manage their impacts in relation to the Sustainable Development Goals. Organizations can fill in thequestionnaire to track change in performance over time. Each question is scored – some with reference to social
or ecological thresholds – to help the organization determine whether it is performing sustainably on that topic.
B Impact Assessments by B Lab are a tool designed to help organizations measure and manage their impacts on
workers, community, environment, and customers. Organizations can fill in the questionnaire to track change inperformance over time. Each question is scored – some with reference to social or ecological thresholds – to help
the organization determine whether it is performing sustainably on that topic.
The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas based on the nature of their business and the sustainable65

development needs of the countries in which they operate. Moreover, they guide users on their performanceassessment which can be monitored over time and based on which meaningful targets can be set and action
points defined.
UNCTAD core indicators for entity reporting on contributions towards implementation of the Sustainable
Development Goals (GCI). The GCI is a set of core universal baseline indicators common to all businesses of all
types and sizes aimed to facilitation harmonization and comparability of SDG reporting by companies. The GCI
has been endorsed by UNCTAD member states, are selected based on main reporting frameworks and PE fundpractices and aligned with the SDG indicators monitoring framework. https://unctad.org/webflyer/guidance-coreindicators-entity-reporting-contribution-towards-implementation-sustainable
UNCTAD GCI Training Material https://isar.unctad.org/wp-content/uploads/2020/04/UNCTAD_DIAE_2020_2.pdf
HIPSO indicators (Harmonized Indicators for Private Sector Operations) are a list of reporting indicators set acrossvarious sectors and industries (including cross-cutting). They have definitions that have been agreed upon by 28
different development finance institutions from around the world, all of whom have signed the MoU on
harmonized indicators. These indicators may be used by any entity wishing to use them.
GRI Sustainability Reporting Standards are designed to help organizations understand and report their impacts ina way that meets the needs of multiple stakeholders. There are a set of Universal Standards that apply to allorganizations, and 35 Topic Standards that contain disclosures for impacts related to economic, environmental,
and social topics. Organizations can use the standards to report to stakeholders on “material” topics that reflect
the organization’s most significant impacts.
IRIS+ System by Global Impact Investing Network (GIIN) is a tool designed to help impact investors translate
intentions into results (hence investors may request businesses they invest in to report using these metrics, andthey may be useful to businesses looking to select appropriate metrics to measure, manage and report theirimpacts). IRIS+ metrics and metric sets are aligned to the SDGs and five dimensions of impact and work isunderway to map various investor metric sets and corporate disclosure standards with a view to achieving global
consistency, including IRIS+-GRI, B Lab-IRIS+, HIPSO-IRIS+. It starts by helping investors frame their impact goals
in a common way (linked to an SDG or Impact Category) and offers a set of metrics (Core Metrics Sets) to assess
performance against set goals, together with an evidence base (Navigating Impact) and implementation
guidance.
CDP Questionnaires are a tool to measure and disclose on climate change, forests, and water security impacts.
Organizations can fill in the questionnaire to track change in performance over time. Each question is scored –some with reference to social or ecological thresholds – to help the organization determine whether it isperforming sustainably on that topic.
A guide to social return on investment (developed by Social Value International, SVI) – follow methodology tomonetize the social value an organization creates, preserves, erodes for stakeholders (society).
Impact-Weighted Accounts Initiative is research on impact valuation published in the form of case studies andwhite papers which organizations can use to learn about key considerations when monetizing impact using
publicly available information https://www.hbs.edu/impact-weighted-acccounts/Pages/default.aspx

Guidance Note 2.5.3. The Fund uses data, results and evidence-based learning to
inform its decision making and benchmark its impact performance.
Additional guidance not needed.

66Guidance Note 2.5.4. The Fund seeks to fill relevant and material impact data gaps
and establish an evidence base to test the validity of any assumptions made andreplace proxies used in its ex ante impact assessments with outcome measures
Additional guidance not needed.

Guidance Note 2.5.5. The Fund identifies and analyzes the reasons for deviations fromexpected impact performance, and where necessary, acts to optimize impact andmanage negative impacts, emergence of additional impact risks and impact
underperformance, including:
2.5.5.1 developing mitigation plans
2.5.5.2 addressing the immediate and sustained impact(s) on Stakeholders
2.5.5.3 where actual impact performance underperforms expected impact
performance, giving precedence to actions that may improve impact performance
ahead of considering early exit options
Additional guidance not needed.

Guidance Note 2.5.6 The Fund engages proactively with its Investees to share lessons
and continuously improve their responsible business and impact management
policies, practices, and performance throughout the lifecycle of each investment
Additional guidance not needed.

Guidance Note 2.5.7 The Fund accounts for the positive and negative impacts fromexited investments in its overall assessment of the Fund’s impact performance
Additional guidance not needed.

Guidance Note 2.5.8. The Fund incorporates lessons into its strategy and management
approach, and shares lessons with limited partners.
See also Guidance note – Impact data collection and use

Guidance Note.
2.6.1 The Fund monitors and reassesses its exit options and pathways throughout theinvestment’s lifecycle to optimize impact on sustainable development and achieving
the SDGs post exit
2.6.2 The Fund assesses the overall impact of each investment at exit relative to theFund’s portfolio level impact goals, investment level impact targets and contribution
to sustainable development and achieving the SDGs, taking into account baseline
performance and relevant SDG and/or other sustainable development outcome
thresholds
2.6.3 Where possible, the Fund follows up on investments post exit to understanddrivers for sustaining and optimizing impact post exit, and incorporates lessons in its
impact management practices and decision making.

67

At exit, the Fund will consider not only the expected impact after exit but also the investee
sustainability management practices (see SDG Impact Standards for Enterprises).
REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Adopt investment criteria and decision-making processes based on SDG impact alongside
financial risk and return investment criteria.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Frameworks, Principle 2:
To promote the delivery of Positive Impact Finance, entities (financial or non-financial) need adequate processes,
methodologies, and tools, to identify and monitor the positive impact of the activities, projects programmes,
and/or entities to be financed or invested in. “Implement specific processes, criteria, and methodologies to monitor
the achievement of intended impacts throughout the life-time of the financial instrument.”
OTHER RESOURCES:The UNEP FI Impact Analysis Tools have been designed open source for banks, investors and their corporateclients and investee companies. They enable practitioners to implement a holistic approach to impact analysis
and management. The Corporate Impact Analysis Tool helps banks and investors gain a cross-cutting view of the
impact status and possibilities of their clients and investee companies but can also be used as a self-assessment
Tool by corporates themselves. The other Tools are specifically designed for banks and investors. The Tools help
users identify their most significant impact areas based on the nature of their business and the sustainable
development needs of the countries in which they operate. Moreover, they guide users on their performanceassessment which can be monitored over time and based on which meaningful targets can be set and action
points defined.

68

TRANSPARENCY
Guidance Note 3.1. The Fund 3.1 discloses relevant information about the Fund andthe Fund Manager in its legal and offering documentation to enable potential
Investees, limited partners and Stakeholders to make informed decision
External reporting
External reporting should cover narrative reporting on how the PE fund integrates sustainability andthe SDGs into its decision making, and impact performance consistent with the requirements about
performance, including measurement of progress against ambitious and rigorous targets. Where any
material gaps have been identified, the report should include a plan for addressing these gaps.
The report should address the principles of SDG disclosure in the Sustainable Development Goal
Disclosure Recommendations, which are embedded in the relevant practice indicators through-out
the Standards. The recommendations cover sustainability issues which for the purposes of the SDG
Impact Standards refer to changes in well-being of people and planet caused by the activities of thereporting PE fund. The risk of using other metrics for decision making should also be disclosed aspart of the connectivity principle.
REFERENCE FRAMEWORKS:
Sustainable Development Goal Disclosure (SDGD) Recommendations
Social Value International (SVI) Principles of Social Value, Principle 4 – “Determine what information and evidence
must be included in the accounts to give a true and fair picture, such that stakeholders can draw reasonableconclusions about impact”.
Social Value International (SVI) Standard for applying Principle 4: Only include what is material – “Determine what
information and evidence must be included in the accounts to give a true and fair picture, such that stakeholders
can draw reasonable conclusions about impact”. https://socialvalueint.org/social-value/standards-andguidance/standard-applying-for-principle-4-only-include-what-is-material/
Social Value International (SVI) Principles of Social Value, Principle 6: Be Transparent – “Demonstrate the basis onwhich the analysis may be considered accurate and honest and show that it will be reported and discussed withstakeholders”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize and monitor the
implementation of the integrated SDG strategy and investments (board oversight, internal controls and audit,
executive remuneration and disclosure.”; Principle 4, INTEGRATED SDG COMMUNICATION AND REPORTING“Business should engage in proactive investor communications about their SDG impact thesis, strategy, andinvestments, including through investor calls and engagement, annual financial disclosures, and integrated
financial and sustainability reports.”; “Enhance integrated reporting practices with key elements of SDG-aligned
investments and finance, including impact measurement and valuation, alignment of investments with strategy,
and accounting and monitoring performance; “Work with peer companies
UNEPFI Principles for Responsible Banking, Principle 6: Transparency & Accountability – We will periodicallyreview our individual and collective implementation of these Principles and be transparent about and accountablefor our positive and negative impacts and our contribution to society’s goals.

69

Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Transparency, Principle 3:
Entities (financial and non-financial) providing Positive Impact Finance should provide transparency anddisclosure on: the activities, projects, programs, and/or entities financed considered Positive Impact, the intended
positive impacts thereof (as per Principle1); The processes they have in place to determine eligibility, and tomonitor and to verify impacts (as per Principle 2); the impacts achieved by the activities, projects, programs,
and/or entities financed (as per Principle 4).
OTHER RESOURCES:GRI Sustainability Reporting Standards are designed to help organizations understand and report their impacts ina way that meets the needs of multiple stakeholders. There are a set of Universal Standards that apply to allorganizations, and 35 Topic Standards that contain disclosures for impacts related to economic, environmental,
and social topics. Organizations can use the standards to report to stakeholders on “material” topics that reflect
the organization’s most significant impacts.

70

Guidance Note 3.2. The Fund reports publicly at least annually on the Fund’s impact
performance
Applying the ABC impact classifications to individual impacts not aggregated impacts
Within the context of these Standards, the ABC impact classifications are applied to describe andsummarise the nature and depth of each impact – not to combine several material impacts tocategorize the PE fund as a whole or portfolio subset.
REFERENCE FRAMEWORKS:
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed toachieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
Impact Management Project (IMP), five dimensions of impact, provides guidance on the types of data needed tounderstand and assess impact performance. The IMP community of 2,000+ practitioners identified fivedimensions of impact, which can be broken down into 15 more detailed data categories. Organizations can use
the five dimensions as a checklist to ensure the information gathered is sufficient for the decision it will inform(see also the ABC methodology and SDG Impact Standards Glossary).
https://impactmanagementproject.com/impact-management/how-PE funds-manage-impact/ and Five
Dimensions of Impact (Impact Management Norms), https://impactmanagementproject.com/impactmanagement/impact-management-norms/
Social Value International (SV) Principles of Social Value, Principle 5: Do not overclaim – “Only claim the value that
activities are responsible for creating. Understanding the role of your activities in a system of change”.
Social Value International (SVI) Principles of Social Value, Principle 6: Be Transparent – “Demonstrate the basis onwhich the analysis may be considered accurate and honest and show that it will be reported and discussed withstakeholders”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize and monitor the
implementation of the integrated SDG strategy and investments (board oversight, internal controls and audit,
executive remuneration and disclosure.”; Principle 4, INTEGRATED SDG COMMUNICATION AND REPORTING“Business should engage in proactive investor communications about their SDG impact thesis, strategy, andinvestments, including through investor calls and engagement, annual financial disclosures, and integrated
financial and sustainability reports.”; “Enhance integrated reporting practices with key elements of SDG-aligned
investments and finance, including impact measurement and valuation, alignment of investments with strategy,
and accounting and monitoring performance; “Work with peer companies
UNEP FI Principles for Responsible Banking, Principle 6: “TRANSPARENCY & ACCOUNTABILITY We will
periodically review our individual and collective implementation of these Principles and be transparent about andaccountable for our positive and negative impacts and our contribution to society’s goals”.
Principles for Positive Impact Finance (developed by UN Environment Finance Initiative), Transparency, Principle 3:
Entities (financial and non-financial) providing Positive Impact Finance should provide transparency anddisclosure on: the activities, projects, programs, and/or entities financed considered Positive Impact, the intended
positive impacts thereof (as per Principle1); The processes they have in place to determine eligibility, and to71monitor and to verify impacts (as per Principle 2); the impacts achieved by the activities, projects, programs,
and/or entities financed (as per Principle 4).
OTHER RESOURCES:UNCTAD core indicators for entity reporting on contributions towards implementation of the Sustainable
Development Goals (GCI). The GCI is a set of core universal baseline indicators common to all businesses of all
types and sizes aimed to facilitation harmonization and comparability of SDG reporting by companies. The GCI
has been endorsed by UNCTAD member states, are selected based on main reporting frameworks and PE fundpractices and aligned with the SDG indicators monitoring framework. https://unctad.org/webflyer/guidance-coreindicators-entity-reporting-contribution-towards-implementation-sustainable
UNCTAD GCI Training Material https://isar.unctad.org/wp-content/uploads/2020/04/UNCTAD_DIAE_2020_2.pdf
HIPSO indicators (Harmonized Indicators for Private Sector Operations) are a list of reporting indicators set acrossvarious sectors and industries (including cross-cutting). They have definitions that have been agreed upon by 28
different development finance institutions from around the world, all of whom have signed the MoU on
harmonized indicators. These indicators may be used by any entity wishing to use them
GRI Sustainability Reporting Standards are designed to help organizations understand and report their impacts ina way that meets the needs of multiple stakeholders. There are a set of Universal Standards that apply to allorganizations, and 35 Topic Standards that contain disclosures for impacts related to economic, environmental,
and social topics. Organizations can use the standards to report to stakeholders on “material” topics that reflect
the organization’s most significant impacts.
GRI/UN Global Compact Action Platform – Reporting on the SDGs, including (i) Integrating the SDGs into
Corporate Reporting – A Practical Guide, https://www.unglobalcompact.org/library/5628; (ii) An analysis of theGoals and Targets; and (iii) Addressing Investor Needs in Business Reporting on the SDGs.
IRIS+ System by Global Impact Investing Network (GIIN) is a tool designed to help impact investors translate
intentions into results (hence investors may request businesses they invest in to report using these metrics, andthey may be useful to businesses looking to select appropriate metrics to measure, manage and report theirimpacts). IRIS+ metrics and metric sets are aligned to the SDGs and five dimensions of impact and work isunderway to map various investor metric sets and corporate disclosure standards with a view to achieving global
consistency, including IRIS+-GRI, B Lab-IRIS+, HIPSO-IRIS+. It starts by helping investors frame their impact goals
in a common way (linked to an SDG or Impact Category) and offers a set of metrics (Core Metrics Sets) to assess
performance against set goals, together with an evidence base (Navigating Impact) and implementation
guidance.
World Benchmarking Alliance (WBA) Benchmark Methodologies are benchmarks that rank companies based on
their impact across seven systems that require transformation to achieve a sustainable future. Organizations canuse the list of topics in the relevant ‘system’ to help identify sustainability topics to report on to enable
comparability and comparison through benchmarking.
Impact-Weighted Accounts Initiative is research on impact valuation published in the form of case studies andwhite papers which organizations can use to learn about key considerations when monetizing impact using
publicly available information https://www.hbs.edu/impact-weighted-acccounts/Pages/default.aspx

72

Guidance Note 3.3. The Fund considers and implements reporting mechanisms best
suited to meeting the needs of Stakeholders affected by its activities and the civilsociety organizations that act on their behalf, including considering where appropriate
to use additional non-public, tailored reporting or changes to existing public reportingto make it more relevant and accessible to a broader range of Stakeholders
Reporting reflects stakeholder needs
The PE fund’s reporting process should explain how the needs of stakeholders have been reflected
for both completeness and accessibility of the information. Materiality identifies what is material toa group of people for a purpose so the report must be clear on the intended audience and their
purpose and what is material to them. Recognizing that other groups may access and use theinformation, the report should address the risks of other uses. This includes the investees
stakeholders.
The primary user for the SDG Impact Standards is the UNDP acting in the interests of people’s
human rights and well-being. The purpose is to contribute positively to sustainability and the SDGs
and to increase that contribution. The implications of any variation from that audience and purposemust be addressed in the report together with a plan for addressing the variation.
REFERENCE FRAMEWORKS:
Social Value International (SVI) Principles of Social Value, Principle 6: Be Transparent – “Demonstrate the basis onwhich the analysis may be considered accurate and honest and show that it will be reported and discussed withstakeholders”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 4, INTEGRATED SDG
COMMUNICATION AND REPORTING “Business should engage in proactive investor communications about their
SDG impact thesis, strategy, and investments, including through investor calls and engagement, annual financial
disclosures, and integrated financial and sustainability reports.”; “Enhance integrated reporting practices with key
elements of SDG-aligned investments and finance, including impact measurement and valuation, alignment ofinvestments with strategy, and accounting and monitoring performance; “Work with peer companies andstandard setters to harmonize practices and maximize the utility of integrated reporting, by promoting
simplification, readability, and a balance between innovation and comparability.”
OTHER RESOURCES:73

Guidance Note 3.4. The Fund makes publicly available the Fund’s and Fund Manager’s(and any parent and/or holding company’s – including its ultimate holding company’s)
human rights and other responsible business policies.
Public policies and disclosure
Disclosure on both policies and performance should be consistent with the remainder of theseStandards. Any gaps should be reported as outlined in 3.2.4, 2.3.6.3 and 2.5.4 together with a plan
for addressing those gaps and the implications of any gaps for decision making should be recognized.
The Fund assesses the risk that actual impacts do not occur as and when expected, taking into
account: (i) the likelihood and magnitude of the risks, (ii) the tolerance for unexpected outcomes(including by those experiencing the impacts), and (iii) any risk mitigation measures
The Fund fills data gaps, including by: (i) replacing proxies with outcome measures, where possible,and (ii) testing the validity of any assumptions made and updating them as needed (e.g., as thecontext changes).
REFERENCE FRAMEWORKS:
Social Value International (SVI) Principles of Social Value, Principle 6: Be Transparent – “Demonstrate the basis onwhich the analysis may be considered accurate and honest and show that it will be reported and discussed withstakeholders”.
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize and monitor the
implementation of the integrated SDG strategy and investments (board oversight, internal controls and audit,
executive remuneration and disclosure.”; Principle 4, INTEGRATED SDG COMMUNICATION AND REPORTING“Business should engage in proactive investor communications about their SDG impact thesis, strategy, andinvestments, including through investor calls and engagement, annual financial disclosures, and integrated
financial and sustainability reports.”; “Enhance integrated reporting practices with key elements of SDG-aligned
investments and finance, including impact measurement and valuation, alignment of investments with strategy,
and accounting and monitoring performance.
OTHER RESOURCES:
Annual Communication on Progress (COP) to the United Nations Global Compact website on progress made to
implement the Ten Principles of the Global Compact. The COP is the UN Global Compact’s reporting framework.
It serves as the initiative’s main accountability measure based on commitments from companies to makecontinuous progress on the Ten Principles.

74

GOVERNANCE
Guidance Note 4.1. The Fund has active oversight from its governing bodies(depending on structure, the board and/ or the investment committee) of mattersrelating to:
4.1.1 organizational culture
4.1.2 its policies on respect for human rights and other responsible business andimpact management policies, including its grievance and reparation mechanisms
for affected Stakeholders (including for the avoidance of doubt, whistleblowing
safeguards)
4.1.3 performance and conformance (including progress on and process forcontinuous improvement) with its responsible business policies and practices
4.1.4 process of Stakeholder identification and involvement in decision making
4.1.5 Stakeholder complaints and remedial actions taken (ensuring no instances ofadverse findings without adequate remedies being in place)
4.1.6 relevant and material sustainable development issues, including risks andopportunities
4.1.7 its purpose and approach to creating sustainable long term value, impact
thesis (including its impact risk appetite and tolerance), portfolio level impact
goals and investment strategy and the compatibility of its impact thesis andportfolio level impact goals with its investment strategy (including its financial
return targets, and financial risk appetite and tolerance)
4.1.8 performance and conformance with its impact management policies andpractices, and progress against its portfolio level impact goals and investment
level impact targets and related relevant SDG and/or other sustainable
development outcome thresholds, baselines and counterfactuals
4.1.9 adequacy of budget and resources to manage Stakeholder involvement
effectively and deliver its impact thesis and portfolio level impact goals
4.1.10 impact and sustainable development related disclosures and external reporting
Board leadership and oversight
Boards send a strong message to their workers and stakeholders about what’s important by virtue ofwhat does and does not make it to the Board agenda and gets airtime during board meetings. The
CEO and senior executives that engage directly with the Board take their cues from what they see isimportant to the Board. If the Board isn’t engaged and actively driving the agenda on – and taking
ownership of – respect for human rights and other responsible business practices, operating
sustainably and making positive contributions towards achieving the SDGs, it’s unlikely that thesewill be embedded in the culture, purpose, and strategy of the organization.

75

Intent is insufficient. Sound governance policies and oversight practices – including consequences forbreaches – are needed to ensure the Board’s intent is realized and to create a culture ofaccountability for decisions and actions in line with stated policies and commitments.
For small funds, there may not be a formal board however there should be opportunities to create
additional accountability by forming a group of advising trustees, an advisory board or the like.
Organizations like Accountability Counsel and SHIFT create resources that make it easier and more
efficient to incorporate human rights and other responsible business practices into policies andpractices. In many countries, options now exist for organizations to participate in cost effective
external complaints and dispute resolution schemes that support accountability to stakeholders.
A board comprises Directors legally registered as required by national legislation. A minimum of 25%
of all directors or higher for rounding (i.e., 5 directors means 2 non-executive directors) should be
non-executive directors, and there should be regular, minuted board meetings.

REFERENCE FRAMEWORKS:
UN Guiding Principles on Business and Human Rights
https://www.ohchr.org/documents/publications/guidingprinciplesbusinesshr_en.pdf
The Ten Principles of the UN Global Compact https://www.unglobalcompact.org/what-is-gc/mission/principles
The UN Women’s Empowerment Principles https://www.weps.org/
The International Labour Organization’s 8 fundamental conventions for labor standards
https://www.ilo.org/global/standards/introduction-to-international-labour-standards/conventions-andrecommendations/lang--en/index.htm
OECD Guidelines for Multinational PE funds sets out principles and standards for responsible business conductconsistent with applicable laws and internationally recognized standards, including setting objectives withreference to minimum safeguards on topics such as: human rights, labour relations, employment practices, publichealth and safety, bribery and extortion, science and technology and taxation.
Office of the United Nations High Commissioner for Human Rights, Free and Prior Informed Consent for
Indigenous Peoples,
www.ohchr.org/Documents/IssueFree_and_prior_informed_consent_for_indigenous_peoples/Peoples/FreePrioran
dInformedConsent.pdf
United Nations, Sustainable Development Goals (SDGs), are the world’s blueprint to achieve a better and moresustainable future for all. Adopted by all 193 UN Member States in 2015, the SDGs comprise 17 integrated andindivisible goals grounded in human rights balancing the three dimensions of sustainable development –economic, social, and environmental. Supported by 169 targets and 230 indicators, the SDGs focus on mostpressing issues first with an overarching goal to “leave no-one behind” and are variously referred to as the world’s
strategy and the most comprehensive map of need, risk, and opportunity. US$5-7 trillion per year needed toachieve the global goals – requiring both public and private
capital.https://sustainabledevelopment.un.org/topics/sustainabledevelopmentgoals
Impact Management Project (IMP), five dimensions of impact, provides guidance on the types of data needed tounderstand and assess impact performance. The IMP community of 2,000+ practitioners identified fivedimensions of impact, which can be broken down into 15 more detailed data categories. Organizations can use
the five dimensions as a checklist to ensure the information gathered is sufficient for the decision it will inform(see also the ABC methodology and SDG Impact Standards Glossary).

76

https://impactmanagementproject.com/impact-management/how-PE funds-manage-impact/ and Five
Dimensions of Impact (Impact Management Norms), https://impactmanagementproject.com/impactmanagement/impact-management-norms/
Social Value International, Principles of Social Value: Principle 1 Involve stakeholders – “inform what getsmeasured and how his is measured and valued in an account of social value by involving stakeholders (the people
who experience change as a result of your activity”.
Social Value International “Standard on applying Principle 1: Involve stakeholders” explains options and processes
for identifying stakeholders and meaningfully engaging stakeholders, including sample questions to ask. This
Standard talks about how speaking to and involving people who experience change is an essential part of theprocess. But they also acknowledge that speaking directly to stakeholders is not the only source of relevant
information. Third party research may be complementary to what you hear from stakeholders or may be a
substitute if your stakeholders are particularly difficult to reach, or if they do not feel comfortable sharing theiropinions. https://socialvalueint.org/wp-content/uploads/2019/03/Standard-on-Stakeholder-Involvement-V2.0FINAL-1.pdfILO convention 169: prior consultation and participation of indigenous peoples in decisions affecting
them, and in particular with regard to free and informed consent on private activities in their territories.
Social Value International (SVI) Principles of Social Value, Principle 4 – “Determine what information and evidence
must be included in the accounts to give a true and fair picture, such that stakeholders can draw reasonableconclusions about impact”.
Social Value International (SVI) Standard for applying Principle 4: Only include what is material – “Determine what
information and evidence must be included in the accounts to give a true and fair picture, such that stakeholders
can draw reasonable conclusions about impact”. https://socialvalueint.org/social-value/standards-andguidance/standard-applying-for-principle-4-only-include-what-is-material/
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize and monitor the
implementation of the integrated SDG strategy and investments (board oversight, internal controls and audit,
executive remuneration and disclosure.”
UNEPFI Principles for Responsible Banking, Principle 4: Stakeholders – We will proactively and responsibly consult,engage, and partner with relevant stakeholders to achieve society’s goals
UNEPFI Principles for Responsible Banking, Principle 5: Governance and Culture – We will implement ourcommitment to these Principles through effective governance and a culture of responsible banking.
OTHER RESOURCES:
OECD Due Diligence Guidance for Responsible Business Conduct helps organizations comply with the OECD
Guidelines for Multinational PE funds providing guidance on setting up due diligence processes to identify andaddress principal adverse impacts in operations, supply chain and business relationships
https://www.oecd.org/investment/due-diligence-guidance-for-responsible-business-conduct.htm
Accountability Counsel’s Accountability Mechanisms: Benefits and Best Practices
What’s Stopping Boards from Turning Sustainability Aspirations into Action? By N. Craig Smith, INSEAD and Ron
Soonieus, Camunico, INSEAD, The Corporate Governance Centre,
https://www.insead.edu/sites/default/files/assets/dept/centres/icgc/docs/whats-stopping-boards-from-turningsustainability-aspirations-into-action-july2019.pdf

77

Guidance Note 4.2. The Fund has governing bodies (depending on structure, theboard and/or the investment committee)
4.2.1 have competencies concerning sustainable development issues and impact
management
4.2.2 prioritize gender and other dimensions of diversity (as demonstrated bycomposition and culture, including openness to hearing and including different voices
and perspectives in decision making)
4.2.3 recognize the implications of low accountability to those impacted and the needto act on their behalf in decisions
4.2.4 hold the CEO/Managing Director accountable for the Fund positively
contributing to sustainable development and the SDGs, including operating inaccordance with its culture, responsible business and impact management policies
and practices and delivering on its strategy, including its impact thesis and portfolio
level impact goals
4.2.5 meets the national minimum corporate governance standards, as appropriate
Board competencies
With respect to board competencies, the board may consider including humanrights/sustainability/impact skills in its board skills matrix, implementing a ‘fit and proper’ test for
new board members/directors, human rights and sustainability training for existing
members/directors, including appropriately skilled Stakeholders or individuals with relevantscientific or social sustainability expertise – especially in the SDGs most relevant to the PE fund’scontext, nominating an independent director/member to have responsibility for championing
human rights/sustainability/SDG/impact management issues, creating an independent
sustainability/SDG/impact management advisory committee of suitably qualified and experienced
personnel, and/or promoting diversity for example by including representation by women andunder-represented stakeholder groups.
Training for the whole board is another option to strengthen the board’s competencies in relation tosustainability matters and to ensure knowledge remains current.
REFERENCE FRAMEWORKS:
UN Guiding Principles for Business and Human Rights (UNGPs)
Ten Principles of the UN Global Compact
UN Women’s Empowerment Principles
International Labour Organization – 8 fundamental conventions for labour standards
International Standard of free, prior and informed consent (FPIC) in relation to Indigenous Peoples, where
relevant
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize and monitor the
implementation of the integrated SDG strategy and investments (board oversight, internal controls and audit,
executive remuneration and disclosure.”

78

OTHER RESOURCES:

Guidance Note 4.3. The Fund manager (and any parent and/or holding company –including its ultimate holding company) has policies, practices, and performance
relating to corporate governance, and respect for human rights and other responsible
business practices that are consistent with the requirements set out in theseStandards
Additional guidance not needed.
REFERENCE FRAMEWORKS:
CFO Principles on Integrated SDG Investments and Finance (developed by UN Global Compact convened CFO
Taskforce for the SDGs), https://www.unglobalcompact.org/library/5788 Principle 2: INTEGRATED SDG STRATEGYAND INVESTMENTS, “Leverage and strengthen corporate governance mechanisms to incentivize and monitor the
implementation of the integrated SDG strategy and investments (board oversight, internal controls and audit,
executive remuneration and disclosure.”
OTHER RESOURCES:79