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PRI reporting framework 2017

Export Public Responses

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

          Green bonds policy

other (2) description

          Energy transition policy

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

other (1) description

          (UN) conventions on nuclear and other controversial weapons

other (2) description

          UNESCO World Heritage Convention, Ramsar Convention on Wetlands, other environmental conventions, including Paris Agreement.

other (3) description

          Ruggie Principles

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

ACTIAM has integrated sustainability into all its processes. We believe that financial and social return go hand in hand. Our Fundamental Investment Principles form the basis of our responsible investment policy. These principles are aligned with the UN Global Compact, focusing on human rights, labour rights, corruption, the environment, weapons and client and product integrity. Furthermore, we have several sector specific, issue specific and asset class specific policy documents, which can be found online:

The responsible investment policy is drafted by the in-house ESG team (7 FTE and 2 interns on average). All policies and exclusion decisions need to pass by the ACTIAM Selection Committee, which consists of the CEO (performing the role of Chair), CIO, Head of ESG Research and an external expert who is also a Professor of Ethics. This committee meets at least once every quarter. The policies are reviewed and updated on a regular basis.

The policies outline ACTIAM's criteria for responsive or proactive engagement and exclusion. ACTIAM prefers to enter into dialogue with a company (engagement), focusing on behavioural change. However, some clear cases directly lead to exclusion, which includes involvement in controversial weapon production, mountain top removal and riverine tailings disposal.

SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.



Other, specify (1) description

          Green bonds policy

Other, specify (2) description

          Energy transition policy

02.4. Additional information [Optional].

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.

There is a companywide policy on conflicts of interest and Chinese Walls. The goal of this policy is to limit the possibility of any potential conflicts of interest and respond properly if a conflict of interest does occur. Compliance to the policy is monitored by the responsible management of a business unit and an independent compliance officer. Besides that an internal audit committee provides an independent assessment on the overall effectiveness of the control measures of all business units. An example of a control measure is the development of so called 'Chinese Walls'.

With respect to conflicts of interests regarding exclusions, engagement or voting decisions, ACTIAM has a committee including an external expert that reviews RI policies and exclusion decisions. ACTIAM does not accept mandates of clients that want to invest in entities which are excluded based on the responsible investment policy.

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

          Our investment universe is screened on a quarterly basis. Please see FIP compliance process and ACTIAM Selection Committee proces in other parts of this questionnaire.
If any incidents occurred in the quarter, this will be reflected in the screening results. Depending on the severity of the incident, a proper response will be sought (could include engagement or exclusion). 
Next to this compliance process (compliance to Fundamental Investment Principles), we can manage incidents through our ESG scoring methodology. If an incident occurs, the ESG score of the company can be adjusted / downgraded. This is not mutually exclusive to the above process. A company’s ESG score can be downgraded while at the same time an engagement is set up.