Scope of this Policy
OrbiMed believes that there is a high congruence between companies that seek to act responsibly and those that succeed in building long-term shareholder value. This Responsible Investment (RI) Policy (this "Policy") lays out OrbiMed's approach to implementing the principles for responsible investment in its operations. OrbiMed seeks to integrate this RI Policy into its overall investment process, applying it to all of its private funds and client accounts ("Funds") under management, in order to maximize investment returns. Other than the explicit exclusions listed below, OrbiMed is not prohibited from investing its Funds in any particular investment.
Investment Focus
OrbiMed manages a variety of Funds that collectively invest globally across many aspects of the healthcare and life sciences sectors, including biopharmaceuticals, medical devices, diagnostics, and healthcare services. Additionally, OrbiMed Funds invest across the life cycle of the industry, from start-ups to large multi-national corporations, and across the capital structure, including equity, credit and hybrid instruments.
Exclusions
A core part of this Policy is to identify, and exclude from potential investment, business sectors which objectively lead to negative impacts on public health or well-being. The current list of excluded businesses in which OrbiMed Funds will not knowingly invest include companies which engage in any of the following activities:
Material ESG Considerations in Investment Due Diligence
OrbiMed makes investment decisions based on a variety of financial and non-financial company factors, including environmental, social and governance (ESG) information.
OrbiMed' s due diligence process for prospective and existing investments takes into account financially material ESG factors, where relevant and applicable. ESG factors do not form the sole, or primary, set of considerations for an investment decision.
OrbiMed considers sector-specific guidance from the Sustainability Accounting Standards Board to determine material ESG factors. Depending on the investment, all or a subset of the ESG factors that are financially material and relevant are considered in OrbiMed' s research. The evaluation of a company's performance on these ESG issues provide guidance for investment decisions and constitute part of the investment analysis. These factors are not exclusionary filters.
ESG Engagement
OrbiMed generally engages on a regular basis with its portfolio companies through meetings with management, proxy voting, and in some cases, through board representation.
Financially material ESG factors impacting valuation across OrbiMed's holdings are reviewed on a quarterly basis as part of the Valuation and Risk Committee meetings. Companies with potentially concerning ESG factors, as provided by third-party data services or as identified by OrbiMed's ESG screens, will be discussed by the Valuation and Risk Committee and may 'be referred to investment team members for further action. In these cases, OrbiMed may seek to engage with the portfolio company to promote changes in the relevant company conduct or policies or, ultimately, OrbiMed may determine to exit the investment. In some cases, OrbiMed may adopt an "activist" approach to advocate for change at the portfolio company, possibly including through a proxy campaign and/or through seeking representation on the company's board of directors or comparable body.
Revisions
Priya Malebennur, Vice President - ESG, is responsible for oversight, implementation, periodic review and updates of this Policy. Her role forms part of the Compliance team at OrbiMed, which is overseen by the Managing Partners of OrbiMed. This Policy will be updated and amended from time-to-time, as approved by OrbiMed's Managing Partners.