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Sp-Fund Management Company Ltd

PRI reporting framework 2017

Basic Information [OO 01 - 09] Gateway asset class implementation indicators [OO 10 - 12]

Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Implementation not in other modules [SG 12 - 16] Innovation [SG 17]

Direct - Listed Equity Active Ownership

Engagement [LEA 01 - 16] Overview [LEA 01 - 02] Process [LEA 03 - 10] Process for engagements run internally [LEA 03 - 04] General processes for all three groups of engagers [LEA 09 - 10] Outputs and outcomes [LEA 11 - 15] Communication [LEA 16]

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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.

Yes

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

Select all that apply

Policy components/types	Coverage by AUM
Policy setting out your overall approach Formalised guidelines on environmental factors Formalised guidelines on social factors Formalised guidelines on corporate governance factors Asset class-specific RI guidelines Sector specific RI guidelines Screening / exclusions policy Engagement policy (Proxy) voting policy Other, specify (1) Other, specify(2)

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

UN Global Compact Principles

UN Guiding Principles on Business and Human Rights

Universal Declaration of Human Rights

International Bill of Human Rights

International Labour Organization Conventions

United Nations Convention Against Corruption

OECD Guidelines for Multinational Enterprises

Other, specify (1)

Other, specify (2)

Other, specify (3)

None of the above

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]

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.

Policy setting out your overall approach

URL/Attachment

URL

URL http://sp-rahastoyhtio.fi/varainhoito/sijoitustoiminnan-vastuullisuus/

Attachment (will be made public)

Formalised guidelines on environmental factors

Formalised guidelines on social factors

Formalised guidelines on corporate governance factors

Asset class-specific RI guidelines

Screening / exclusions policy

Engagement policy

(Proxy) voting policy

We do not publicly disclose our investment policy documents

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.

Yes

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

We have internal governance and risk management procedures where we monitor the integrity of our investment process. One part of this is the Best Execution -reporting, which covers all asset classes. We do not have investment banking operations in the Savings Banks Group, which reduces the possibility of situations where conflicting interests might arise.

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.

Yes

04.2. Describe your process on managing incidents

          Our portfolio managers and portfolio analysts constantly monitor the incidents of the companies of our fund holdings. For systematic screening we use an external service provider to make sure that our investments comply with the ESG criteria that we have described in our investment guidelines. If we identify an incident within the portfolio companies we analyse together with our service provider the case and the company's response and activities for the incident. Finally, we decide internally how we proceed. That can include engagement with the company and/or sell decisions if we do not see that the company's operations are in line with our investment and ESG policy.

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