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SKY Harbor Capital Management

PRI reporting framework 2017

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

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

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]

From an investment perspective, SKY Harbor’s process is designed to identify, value and manage specific High Yield market risks, which inherently includes ESG factors. As is the case for our analysis of all risk factors, the goal of ESG analysis is best characterized by systematic identification and monitoring to manage how these risks affect issuers and industries over time. Specifically, we look for sustainability and responsible behavior in the companies we invest in, and their ability and willingness to service debt obligations.  Among other risks, ESG factors are incorporated in our fundamental credit analysis to assess, for example, environmental and product liabilities, employee training and retention, and corporate governance and legal risks. We recognize the potential for a high correlation between companies that manage ESG factors well and superior investment returns: companies that embark on sustainable and responsible business practices that promote diversity and inclusion, best practices in governance, responsible use of natural resources and moderate carbon emissions are companies best positioned for the future.

SKY Harbor utilizes a risk-based methodology for assessing and evaluating ESG factors pertinent to the issuers in which it invests.  This approach is applied across all strategies. Certain individual portfolios may be further defined by client-directed ESG criteria or regulatory requirements as in the case of UCITS funds for which SKY Harbor is the investment manager.


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.

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.

SKY Harbor recognizes that potential conflicts of interest may arise in conducting the business of an investment manager, and has clearly stated compliance policies and procedures designed to address potential conflict that may arise. Such policies and procedures include, but are not limited to, side-by-side management, trade allocation, brokerage practices and asset valuation and liquidity determinations. Operationally, systems and risk controls have been constructed to identify possible conflicts, which if detected, are escalated to the Chief Compliance Officer and Chief Risk Officer for appropriate mitigation. Conflicts of interest in personal trading are mitigated by the firm’s Code of Ethics, which does not permit employees to purchase any securities (even the equity securities) of an issuer whose below-investment-grade debt securities have been purchased by the firm for client portfolios. SKY Harbor’s Conflicts of Interest Policy is stated in our Compliance Manual and SKY Harbor conflicts of interest are disclosed in the Part 2A of the Firm’s Form ADV filed with the SEC.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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