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Sycomore Asset Management

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.

Sycomore AM's policy regarding potential conflicts of interest is endorsed and supervised by our compliance department, which is composed of 2 people.

Also, we have a specific section in our voting policy to prevent potential conflicts of interest. If a member of the supervisory board of a company, in which Sycomore AM is about to vote, is also an important client or partner of Sycomore AM, a special meeting with the fund management team is organized by the internal audit department to decide on the most appropriate decision in the best interest of our clients.

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

          Sycomore AM carries out a full monitoring of the controversies that affect the companies within its investment universe, based on around 60 sources including press, NGOs, unions, sell-side analysis. In addition to these primary sources, we use a news aggregator, which alerts us as soon as a portfolio company is associated with one of the negative keywords we defined in one of the thousands of sources screened. 
The monitoring is embedded in our ESG analysis process as it has a direct bearing on a company's ESG rating: every controversy point lowers the relevant stakeholder group's rating by 0.1 point. We assess the severity of controversies from 0 to -3 controversy points, based on the perimeter affected, the degree of certainty, the consequences, and the reaction of the company. Every company affected by a -3 rated controversy is excluded from our SRI investment universe.
Furthermore, a controversy will trigger an engagement action from our side if the company has not provided adequate answers or taken the necessary actions to manage the controversy.