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PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)

SG 02. Publicly available RI policy or guidance documents (Not Completed)

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Comgest has implemented rules, policies and procedures in order to mitigate the risk of conflict of interest:

Personal transactions

The Compliance Officer prior approval is needed.
The request won’t be approved if an order has been executed on the relevant security on behalf of a portfolio managed within the last two days or if an order is currently been executed or planed for execution for the two following days.

The cash of the company is managed independently from portfolio managers and is not invested in listed shares.

Orders are pre-allocated and the system used does not allow ex-post changes.
Group orders must be allocated on a prorata basis in case of partial execution.
Any different allocation must be justified in the system and must be in the interest of the relevant investors.

Best execution and best selection policies have been implemented.
As an independent company, Comgest has no ownership or capital link with any broker or counterparty. Therefore, brokers and counterparties are exclusively chosen in the best interest of investors.

Despite these rules, policies and procedures, if a conflict of interest occurs, Comgest will manage it in the interest of the investors and will inform the relevant investors.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within portfolio companies.

04.2. Describe your process on managing incidents

          We monitor on an ongoing basis ESG controversies affecting our investee companies. We may engage with the affected company to collect more information and request improvements and mitigation measures. If company's answer is not satisfactory we may revise our ESG opinion on the company and the ESG quality level we assigned to the company. In this case there is an impact on company's valuation.