ESG policy

Submission date: 16/09/2025

Overview

Law Debenture (‘the Company’) represents a unique proposition, a FTSE250 investment trust, with a material operating business (IPS). While the Company is governed holistically, with a set of central values and objectives, by its very nature, the operating business provides an additional opportunity to demonstrate our approach to ESG over and above most Investment Trusts.

ESG considerations when investing

Whilst we are not positioned as an ESG investment trust, our investment managers integrate ESG factors as part of their fundamental stock analysis. The investment managers consider ESG risks that are material and could impact a company’s prospects. These risks would be likely to have a significant impact on the financial condition or operating performance of a business, and have the potential to influence investment decisions. Our investment managers also evaluate a company’s ability to manage these risks when choosing to invest or divest in a company. ESG factors are considered to be material if omitting, obscuring or misstating them could be reasonably expected to influence investment decisions.


Whilst ESG data is considered, the managers’ approach to ESG is more qualitative which means that companies with weaker ESG risk profiles are not automatically excluded from the portfolio. The managers do not explicitly exclude any stocks or sectors, but they will divest or not invest in companies where company management are not considered to be appropriately managing risks, or where they believe companies do not present an attractive
risk reward proposition.


The team proactively engages with senior management on key ESG issues and risks, assessing their responses and subsequent actions. Typically, the managers meet at least annually with the companies held in the Portfolio with part of the discussion covering material ESG concerns.

Additional Information

Information on the Company’s approach to ESG can be found in the latest annual report (please see pages 53 to 61) https://media.umbraco.io/lawdebenture/j24kw45x/law-debenture-annual-report-and-accounts-2024.pdf .  

The Manager’s ESG Principles are available on its website.  

The Company’s appointed investment manager:

- supports the Stewardship Code

- is a signatory of the Principles for Responsible Investment