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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. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

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. 補足情報。 [任意]

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、ポートフォリオ対象企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

          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.