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APG 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.

APG AM has adopted an internal Code of Conduct to detect and manage potential conflicts of interest, which is being monitored continuously and reviewed annually. Where a potential Conflict of Interest is apparent, APG AM can decide to refrain from engaging in a particular activity.

APG AM also has specific existing policies on Insider dealing, gifts, invitations and entertainment, and additional functions.

If for any reason pre-emptive measures have not been successful in mitigating a potential Conflict of Interest, APG AM will endeavour to make any information pertaining to such conflict available to all relevant stakeholders.

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

          All companies are screened on the basis of the UN Global Compact (UNGC) principles. APG procures services from several data vendors in order to identify issues at portfolio companies in relation to the UNGC principles and other ESG areas. For example, Wwe also expect third party private equity managers to promptly inform us in the event an incident occurs in a portfolio company. In addition, information from brokers and NGO’s can be used to identify issues at portfolio companies. 

When issues are identified, APG can reach out to the investee company or relevant external manager for clarification and fact checking purposes or initiate a longer term engagement.