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HSBC Global 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.

Our primary responsibility as an investment management firm is to try to add value over the long term. Potential conflicts of interest are addressed by the over-riding principle that client interests are put first.

HSBC Global Asset Management (AMG) businesses have established procedures to identify and manage conflicts between the interests of the AMG business, its affiliates, employees and conflicts between clients.

We have strict procedures to ensure that the integrity of confidential information is maintained and suitable controls are in place to prevent its misuse.

Votes in situations where there may be a conflict of interest are considered in the context of our voting guidelines.  Whilst our process allows for departure from vote recommendations based upon our guidelines, special review procedures and an entry in the conflict of interest register are required where we intend to depart from the external recommendation in a conflicted situation.

AMG businesses conduct reviews at least annually on all operations to identify new conflicts of Interest.

AMG businesses present its register of conflicts to the local Risk Management Committee or appropriate governance forum at least quarterly to review the conflicts and agreed mitigation actions.

This policy is described in our Functional Instruction Manual

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 in-house ESG rating system, called the MineSweeper, generates ESG scores for c.9,000 issuers. This scoring determines the ESG risk status – either High, Medium or Low Risk - for each of these issuers. We review this status every 6 months and subsequently communicate to all our investment teams globally. We impose a systematic Enhanced Due Diligence on all High Risk companies already held in the funds we manage or if we are considering them for potential investment.