Sustainability at Oakley Capital (OCI Investment Adviser)
Sustainability considerations remain an integral part of how Oakley, as Investment Adviser to OCI, seeks to protect and enhance long-term value. As a listed investment company, OCI’s approach is grounded in disciplined risk management, active stewardship and a clear focus on the issues most likely to influence resilience, performance and outcomes over time.
This letter provides context on how Oakley’s sustainability programme has continued to evolve during the year. It is intended to complement the section that follows, which sets out a more detailed overview of Oakley’s responsible investment approach.
Our approach
Oakley’s sustainability framework is designed to be practical, proportionate and value-led. It recognises the diversity of the portfolio while maintaining a consistent focus on issues that are most relevant to long-term value creation. Across the firm and portfolio, Oakley continues to prioritise three core areas: energy and climate change, employee culture and engagement, and cybersecurity and data protection.
These priorities are embedded throughout the investment life cycle – from origination and due diligence through ownership and exit – and are supported by annual data collection, targeted engagement and regular dialogue with management teams. The objective is not to apply uniform solutions, but to work constructively with portfolio companies to identify, prioritise and address the sustainability topics most relevant to their business models, risk profiles and growth plans.
Alongside portfolio engagement, Oakley continues to progress its own sustainability practices as a manager through strengthening governance, improving data quality and developing internal capability in line with evolving regulatory and stakeholder expectations.
Progress and focus during 2025
During 2025, efforts were focused on deepening the effectiveness of existing programmes and addressing emerging areas of risk and opportunity.
Cybersecurity and data protection remained a key area of focus. Building on the portfolio-wide monitoring programme launched in 2024, Oakley further strengthened its approach during the year through enhanced oversight, regular portfolio cybersecurity forums and clearer minimum expectations. This work supports regulatory readiness, including alignment with evolving requirements, while also helping portfolio companies protect operational continuity and stakeholder trust.
Supply chain management received increased attention in 2025, reflecting heightened regulatory scrutiny and growing expectations around environmental and social impacts. Oakley undertook a targeted review of supply chain management practices within a selection of its consumer businesses, with a particular focus on transparency, governance, labour and human rights, environmental impact as well as risk and resilience. This work is helping to improve visibility of supplier-related risks, strengthen controls and inform more structured engagement where exposure is higher.
Climate and emissions continued to be a priority at both manager and portfolio level. Oakley further improved the quality of its own emissions through use of activity-based data and continued portfolio climate risk assessment work to support prioritisation and engagement. This provides a stronger evidence base for decision-making and supports preparation for future climate-related disclosures, such as the Task Force on Climate-related Financial Disclosures (‘TCFD’) report, which is issued by Oakley each June.
An emerging area of focus during the year was artificial intelligence (AI). As AI becomes increasingly relevant across Oakley’s operations and portfolio companies, work progressed to develop an approach to responsible AI, considering governance, data, cybersecurity as well as human rights and ethical considerations alongside the opportunities AI presents for innovation and productivity.
Reporting and transparency
Oakley publishes an annual Responsible Investment Report each June, which provides further detail on governance, policies and portfolio engagement. Readers are encouraged to refer to the most recently published Responsible Investment Report, which covers 2024, for additional information on how Oakley works with portfolio companies. The next report, due for publication in June 2026, will include an update on portfolio company developments during 2025.
Looking ahead
Looking ahead to 2026, the focus remains on building consistently strong foundations in new investments, while using the progress made across the existing portfolio with respect to transparency to continue to support portfolio value creation.
As Oakley continues to make new investments on behalf of OCI, there remains a strong focus on embedding foundational sustainability practices early in the ownership period. Establishing appropriate governance, data collection and core controls from the outset is intended to support long-term resilience and provide a sound basis for sustainable growth.
Across the portfolio, improvements in data quality are increasingly enabling a more informed and targeted approach – moving beyond understanding and reporting sustainability risks towards identifying opportunities to enhance operational performance, manage costs and support growth, where appropriate. More decision-useful data is expected to continue informing engagement and prioritisation across environmental, social and governance (‘ESG’) topics.
Active engagement with portfolio companies remains central to Oakley’s stewardship approach. Oakley continues to work constructively with management teams to support practical, sustainable improvements that reflect each business’s maturity, sector and risk profile, while maintaining a focus on issues that Oakley has determined to be most relevant to long-term value and resilience.
Building on the momentum from 2025, Oakley expects to continue developing its work on cybersecurity and supply chain management, recognising their growing importance to operational resilience, regulatory readiness and stakeholder confidence. Oakley also anticipates further development of its approach to artificial intelligence, both within the firm and across the portfolio, with a focus on responsible adoption, appropriate governance and the potential to support innovation and efficiency over time.
Through this work, sustainability continues to form part of disciplined investment management and active ownership, supporting more resilient businesses and contributing to durable long-term outcomes for OCI shareholders.
Aga Siemiginowska
Head of Sustainability
Oakley
Oakley’s responsible investment process
Responsible investing principles form an integral part of the life cycle of an investment, from origination to due diligence, and subsequently throughout Oakley’s period of ownership and exit. Oakley seeks to ensure that material sustainability factors are considered in all steps of the investment process.
1. Initial
screening
Preliminary assessment of sustainability risks and opportunities
Scorecard assessment
2. Due
diligence
Due diligence carried out using internal resources, or external consultants as appropriate, including:
Red flag assessment
Materiality assessment – identification of (company-specific) sustainability-related risks and opportunities
* Investment decision made
Stewardship
3a. Onboarding
programme
Sustainability onboarding with Oakley team
Addressing urgent issues identified as part of due diligence
3b. Engagement and support
Ongoing support and guidance provided by the Sustainability Team
3c. Monitoring
Active stewardship, including:
Engagement with company management on sustainability topics
Annual ESG monitoring and review of progress
Company KPI reporting to Oakley
Sustainability topics and progress discussed at Board meetings
4. Exit
Support in preparing for sustainability due diligence from prospective investors
ESG vendor due diligence as appropriate
Oakley’s sustainability strategy
Building on foundations established by Oakley in previous years, Oakley’s sustainability approach focuses on issues determined to be most material to the firm and its portfolio. While every business is distinct, certain themes are consistently relevant to value creation. Accordingly, Oakley’s sustainability programme continues to prioritise three core areas – energy and climate change, employee culture and engagement, and cybersecurity and data protection – embedded across firm operations and investment processes to support resilience and long-term value. As part of this approach, we align our work with evolving regulatory expectations and transparency requirements.
Regulatory disclosures
OCI is a Bermuda-incorporated closed-ended investment company and is not subject to the UK’s mandatory TCFD-aligned disclosure requirements, Streamlined Energy and Carbon Reporting (‘SECR’) or the UK Modern Slavery Act. Oakley, as OCI’s Investment Adviser, is in scope of each of these regimes and publishes annual TCFD disclosures, integrated in the Responsible Investment Report, and SECR disclosures included in the Group of companies’ accounts filed at Companies House, as well as an annually reviewed Modern Slavery Act Statement on Oakley’s website.
Our sustainability programme prioritises three key themes
Energy and climate change
In 2025, Oakley continued to measure its full operational carbon footprint (Scope 1, Scope 2 and relevant operational Scope 3) and further improved data quality by increasing the use of primary consumption and activity-based data. Oakley’s latest published operational carbon footprint data (FY24) is available in the Responsible Investment Report.
At portfolio level, Oakley continued to support portfolio companies to measure and manage emissions, including through its recommended carbon accounting platform and expert support. Portfolio emissions for the FY25 reporting period are currently being calculated and, based on progress to date, Oakley expects 78% of its portfolio companies to measure their carbon footprint using Oakley’s recommended carbon accounting platform and expert or an external consultant (compared with 65% in FY24).
Oakley also progressed updates to its portfolio climate risk assessment in preparation for its third TCFD report (scheduled for publication in June 2026) and hosted a follow-up climate risk webinar in H2 2025 focused on understanding and managing climate-related risks.
Employee culture and engagement
Oakley believes that creating a supportive, engaging workplace culture will be an important component in long-term success and our ability to attract, retain and develop high-performing talent. As Oakley continues to grow, there is continued focus on building an environment where employees feel valued, motivated and equipped to succeed.
In 2025, Oakley continued to run an employee engagement survey, achieving an 83% participation rate (in line with 84% in 2024). Oakley also maintained strong engagement governance and dedicated workstreams to translate feedback into practical actions and continued our mentoring programme to support development and progression.
Across the portfolio, Oakley encourages portfolio companies to strengthen employee engagement in a way that reflects each business’s context and priorities. There has been increasing emphasis across our portfolio on employee development opportunities. Companies are implementing structured continuing professional development hours and launching innovative initiatives to support employee growth.
Cybersecurity and data protection
Cybersecurity remains a strategic priority for Oakley. In 2025, the firm continued to strengthen its cyber resilience, building on enhanced monitoring and security capabilities, and maintaining focus on regulatory readiness and ongoing alignment, including the EU Digital Operational Resilience Act.
Following the launch of Oakley’s portfolio-wide cybersecurity monitoring programme in 2024 – combining vulnerability scans, questionnaires and deeper assessments to provide clear visibility of cyber risks – Oakley continued to evolve the approach in 2025. This included the introduction of quarterly cybersecurity huddles, bringing portfolio companies together to share insights, discuss emerging threats and address common risks. Alongside the online portal that enables companies to track actions and improvements, this supports a more consistent, data-led approach to managing cybersecurity risk and informs longer-term, strategic decision-making across the portfolio.
Active stewardship
Oakley’s active stewardship approach is rooted in partnership with management teams throughout the ownership period. We aim to empower company management with the knowledge and tools to identify, prioritise and manage sustainability risks and opportunities most relevant to their business, while maintaining appropriate management agency and autonomy.
Recognising that every company is unique, we take a broad, materiality-led approach to engagement, focusing on the topics most relevant to each company’s operations, risk profile and value creation plan. For example, businesses with complex global supply chains may prioritise supply chain management and responsible sourcing, while businesses pursuing significant M&A or transformation agendas may place greater focus on people and wellbeing to support integration and performance. Depending on the context, we also engage on topics such as product quality and safety, pollution and waste, and fair and ethical conduct.
During 2025, Oakley continued to support portfolio companies in navigating evolving sustainability regulation. Following proposed amendments to the Corporate Sustainability Reporting Directive (‘CSRD’) under the EU’s Omnibus I package – including higher size thresholds that may change which companies are in scope – the Sustainability Team issued an update memo and held targeted one-to-one discussions with portfolio companies potentially remaining within scope. For investments likely to fall outside the revised requirements, Oakley has focused on ensuring ‘double materiality assessments’ remain a useful management tool to prioritise actions, strengthen risk management and support target-setting, even though formal CSRD reporting may no longer be required. Oakley also delivered a supply chain project for companies with more complex supply chains, strengthening supply chain risk and transparency through tailored action plans and practical toolkits.
To track progress and maintain momentum, Oakley launched its fourth annual sustainability survey in 2025 to collect data and monitor key sustainability KPIs. This was complemented by selected portfolio site visits – undertaken based on where Oakley believed it was most relevant to the company’s risk profile, maturity and value creation opportunities to review data in context and identify priorities – as well as the fourth annual Sustainability Forum in June 2025, which convened portfolio companies to share case studies, exchange best practice and participate in practical workshops.
For further details on Oakley’s approach to investing responsibly and more detailed examples of sustainability initiatives across the portfolio, please see Oakley’s latest Responsible Investment Report.
Oakley’s sustainability collaborations
Oakley partners
Oakley sustainability
Logos represent organisations/bodies of which Oakley and/or OCI is a recognised supporter, signatory or member. The above firm-level CSR and climate-related initiatives do not have a direct bearing on investment decisions made for OCI or for Oakley-managed funds. References to firm-level initiatives do not require OCI or Oakley to engage with portfolio companies. Oakley is also a member or contributor to other industry bodies and trade associations, which, at times, may adopt positions or undertake advocacy activities that are not consistent with the aims or ethos of the organisations and initiatives referred to above.