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Sparinvest S.A.

PRI reporting framework 2017

Export Public Responses

You are in Direct - Listed Equity Incorporation » ESG incorporation in actively managed listed equities » Implementation processes

Implementation processes

LEI 03. Percentage of each incorporation strategy

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03.1. 以下を記載してください。(1)組織でのアクティブ運用上場株式にどのESG組み入れ戦略や組み合わせを使用しているか(2)アクティブ運用している上場株式の戦略または戦略の組み合わせ別内訳

ESG組み入れ戦略 (当てはまるものをすべてお選びください)
アクティブ運用される上場株式に戦略が適用される割合 (推定 +/- 5%)
100 %
アクティブ運用している上場株式の合計 100%

03.2. 組織が実施しているESG組み入れアプローチ、および、特定のESG組み入れ戦略を選択している場合はその理由を説明してください。

Our equity fund range includes active fundamental stock-selecting funds, active quantitative funds, and passive funds.

ALL FUNDS: All funds (active and passive) apply an exclusionary screen for controversial weapons and securities in breach of EU sanctions.

ACTIVE FUNDAMENTAL FUNDS: In our active fundamental funds, our aim is to understand the long-term intrinsic value of company, and any risks to that value. Indeed, we aim to assess the downside risk before the upside potential. Consequently, issues which may impact a company in the short or long-term are considered highly relevant to our analysis, and this includes many environmental, social and governance issues. As such, we integrate ESG considerations into our security analysis, alongside other fundamental factors. We also engage with companies as deemed appropriate (see separate section on engagement).

In addition, certain of our equity funds (labelled ‘Ethical’) use a negative screen to exclude companies. The exclusionary criteria for these funds result from ongoing consultation with clients, but are broadly categorised as norm-based and sector-based criteria:

  • Norm-based screen for violations of global norms: environmental protection, human rights, labour standards and anti-corruption.
  • Sector-based screen for companies with certain exposures to sectors such as: alcohol, tobacco, gambling, pornography, weapons and thermal coal & oil sands.


PASSIVE FUNDS: with regards to our Passive funds, we work on the understanding that the concept of ESG incorporation in investment decision-making (Principle 1) does not apply to funds whose sole objective is to replicate an index - unless the index itself is focused on ESG considerations. Accordingly, we only apply active ownership (Principle 2) to these funds which, as a result, participate in voting and engagement.


ACTIVE QUANTITATIVE FUNDS: With our quantitative funds, there is an aim that the portfolio’s ESG score gradually improves over time, so that at rebalancing quantitative ESG information is integrated into portfolio construction decisions on a ceteris paribus basis. As it is for the passive funds, we only apply active ownership (Principle 2) to these funds, specifically proxy voting.

03.3. ESG組み入れ戦略の組み合わせを使用して資産を運用している場合、ESG戦略の組み合わせをどのように使用しているかを簡単に説明してください。 [任意]

As noted above in 03.2, ESG risk factors are integrated into our investment process and investment decisions, across all active equity funds. This extends to ongoing monitoring of existing holdings, exercise of proxy voting, and engagement with holdings, and supra-holding engagements. We use certain external service providers for ESG research and proxy voting advice, while ultimate decisions are made internally.

All funds are subject to the controversial weapons and EU sanctions exclusionary screen.

In addition, the Ethical fund range has sector and norm-based exclusions, as detailed in 03.2. Research for these screens is provided by an external service provider, ISS-Ethix. Note that negative results from these screens may result in a company being excluded from our Ethical funds, but not excluded from other active funds. Where the exclusion is based on normative issues, we choose to engage with the company in order to seek improvement and the prevention of recurrence. We find that the research provided by ISS-Ethix in this regard has useful crossover application in our ESG integration strategy.

LEI 04. Type of ESG information used in investment decision (Private)

LEI 05. Information from engagement and/or voting used in investment decision-making (Private)

(A) Implementation: Screening

LEI 06. Types of screening applied

06.1. 組織内でアクティブ運用している上場株式に適用するスクリーニングの種類を記載し、説明してください。




Across all funds, we exclude companies involved in controversial weapons and securities in breach of EU sanctions. (We note that on occasion, certain sanctions may have the effect of excluding specific countries, but we have no direct country exclusion screens ourselves).

In addition, we provide certain funds which add an additional focus on “Ethical Investment”, which is based on negative screening to exclude companies from the investment universe or investment shortlist, on certain specific grounds. These equity funds are easily identified by the label “Ethical” within the fund name, and are primarily used to meet client needs. The exclusionary criteria for these funds result from ongoing consultation with clients, but are broadly categorised as norm-based and sector-based criteria:

  • A norm-based screen for violations of global norms: environmental protection, human rights, labour standards and anti-corruption.
  • A sector-based screen for companies operating within sectors such as: alcohol, tobacco, gambling, pornography, weapons, thermal coal and oil sands.

(In the above checklist, we reflect this latter sector-based screen as "Product", "Activity" and "Sector". Note that we do not have any broad GICS sector-level exclusions).


          Paris Agreement on Climate Change


Note that our Norm-Based screening is a negative exclusionary screen, as detailed above. It assesses companies’ adherence to international norms for human rights, the environment, labor standards and anti-corruption. It adheres to the UN Global Compact Principles.

06.2. スクリーニング基準の設定方法、基準の見直し頻度、基準の変更を顧客や受益者に通知する方法について説明してください。

A key role of the RI Committee is to be aware of potentially relevant new screening requirements. Any potential review to screening criteria is informed by ongoing consultation with clients, other industry participants and general industry trends.

Clients are notified of changes vial both direct communication such as presentations or coverage in our Responsible Investment Review, and via our website. 

LEI 07. Processes to ensure screening is based on robust analysis

07.1. スクリーニングが徹底した分析に基づいていることを確実にするために、組織が使用しているプロセスを選択してください。

07.2. 補足情報。 [任意]

Normative and sector-based screens are researched and implemented by an external service provider (ISS-Ethix). Internal staff, including both dedicated RI staff and portfolio managers and analysts will review the analysis alongside their own findings based on information from the company in question. Where necessary, more detailed or up-to-date analysis will be requested from the service provider. 

LEI 08. Processes to ensure fund criteria are not breached (Private)

(C) Implementation: Integration of ESG issues

LEI 10. Review ESG issues while researching companies/sectors

10.1. アクティブ戦略において企業やセクターを調査する際、ESG問題を見直しているかどうかについて記載してください。








Corporate Governance

10.2. 補足情報。 [任意]

LEI 11. Processes to ensure integration is based on robust analysis (Private)

LEI 12. Aspects of analysis ESG information is integrated into (Private)