February 2026
Overview
Cinven Limited (“Cinven” or the “Firm“) is authorised and regulated by the UK Financial Conduct Authority (“FCA“). The Firm’s principal activities involve providing investment management and advisory and arranging services with respect to Cinven’s funds which follow a private equity strategy.
This statement is made under COBS 2.2A.5R and 2.2B.5R of the FCA’s Handbook of Rules and Guidance.
Please direct any questions to Peter Moore (the Firm’s Head of Compliance) at peter.moore@cinven.com.
Stewardship Code
Background
The Firm is required under COBS 2.2.3(R) to disclose:
(1) the nature of its commitment to the Financial Reporting Council’s Stewardship Code (the “Code“); or
(2) where it does not commit to the Code, its alternative investment strategy.
The Code defines stewardship as the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
Cinven Limited’s approach
The Firm does not commit to the Code as it follows its own alternative investment strategy (in accordance with (2) above).
The Firm’s alternative approach to ensure effective stewardship includes:
• Signatory of the PRI. Cinven has been a signatory of the Principles for Responsible Investment (PRI) since 2009 and has agreed to its six Principles of Responsible Investment. Cinven typically makes an annual disclosure under the PRI Reporting Framework.
• Compliance with various stewardship industry frameworks. Cinven seeks to comply with the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights and the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work.
• Engagement with stakeholders. Cinven engages with relevant stakeholders including its investors, regulators, employees, portfolio companies, industry bodies and local communities. This includes the sharing of relevant information and contributing to industry initiatives. Cinven prioritises the entities on which to focus its stewardship efforts based on its strategy and priorities.
• Sustainability integration. Cinven integrates sustainability factors into its investment decision-making and stewardship activities, enhancing both the resilience and long-term performance of its investments. This includes through its Investment Selection Framework (ISF) and integration of sustainability into due diligence.
• Active ownership. Cinven engages proactively with management of its portfolio companies on relevant matters relating to sustainability. Cinven seeks to integrate sustainability into post-investment strategic planning and implementation early in the process to ensure that material sustainability risks and opportunities are identified and prioritised. As part of this, Cinven develops a sustainability-specific value creation plan, or integrates sustainability within the overall value creation plan, with new portfolio companies.
• Compliance with PERG. Cinven seeks to comply with the Private Equity Reporting Guidelines (PERG), an independent body which oversees transparency and disclosure within UK private equity. PERG is also responsible for monitoring Cinven for conformity with the Walker Guidelines, a set of enhanced rules on disclosure that apply to certain private equity firms and their larger portfolio companies in the UK.
• Compliance with FCA sustainability reporting requirements: Cinven seeks to comply with all relevant FCA sustainability reporting requirements including climate disclosure requirements aligned with the TCFD’s recommendations. Cinven’s annual climate disclosure is contained in its Sustainability Report, available on the Cinven website.
Shareholder Engagement
Background
The Firm is required under COBS 2.2B.5R to either:
(1) develop and disclose a shareholder engagement policy (with respect to the Firm’s investments on behalf of investors in relevant publicly traded shares) and further disclose on an annual basis how its policy has been implemented in accordance with the relevant FCA requirements; or
(2) disclose a clear and reasoned explanation of why it has chosen not to comply with the requirements under (1).
Cinven Limited’s approach
In accordance with (2) above, the Firm does not consider it appropriate to adopt a shareholder engagement policy, on the basis that it invests largely in private companies rather than publicly traded shares and any terms with respect to shareholder engagement will be governed by the relevant fund documentation.