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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.

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.