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PRI reporting framework 2018

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

01.3. Indicate if the investment policy covers any of the following

01.4. Describe your organisation’s investment principles and overall investment strategy, and how they consider ESG factors and real economy impact.

Investment principles and strategy of KEPLER can be found in question SG 01.5.

As far as real economy impact is concerned, our ethical investment approach preserved us from different risks. Sustainable ratings can be a good risk management tool. For example, as a client of oekom research, we were early warned of a misinvestment in companies like Worldcom, Parmalat, Lehman, Enron and AIG among others.

Moreover, KEPLER implemented a strategy to further combine ESG and real economy impact by including fossile fuels in the exclusion criteria: producers and processors of coal and oil with net sales >10 % and high-volume fracking are excluded (keyword: stranded assets).

For our equity mutual fund (KEPLER Ethik Aktienfonds), our equity eco-fund (KEPLER Öko Energien) as well as for the equity part of our ethical mixed fund we regularly measure and publish  the CO2-footprint. For details, please have a look at our homepage:


01.5. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

KEPLER's first sustainable equity fund - KEPLER Sustainability Aktienfonds - was issued in November 2000, therefore, 17 years ago. KEPLER was aware of the importance of sustainable investments quite early and also was aware of its responsibility to promote this kind of investment strategy. Two years later, KEPLER Ethik Aktienfonds, the first ethical (equity) investment fund in Austria, was issued and thus KEPLER led the ground for further ESG funds. Different special funds were issued for institutional investors and KEPLER Ethik Rentenfonds, an ethical bond fund for private clients, was incorporated. In 2014, KEPLER launched KEPLER Ethik Mix, a mutual fund with a mixture of ethical bonds and equities. High transparency, international and independent partners (such as oekom research AG) and an ongoing dialogue with the partners as well as a continuous development of the investment approach are vital for the success of KEPLER's ESG investment approach.

Ethical/sustainable investments with KEPLER can be described as an interaction between 4 parties and main thematic fields respectively: KEPLER fund management for the investment process, oekom research as external sustainable research provider, KEPLER ethical committee for discussion, dialogue and exchange of experience as well as the KEPLER engagement process to have a dialogue with issuers as far as the violation of exclusion criteria are concerned.

KEPLER interacts with companies on ESG issues in order to influence corporate practice on ESG issues and to encourage improved / increased ESG disclosure. So far, we do not engage via collaborative engagements and service provider engagements - this is in internal discussion and might be changed in the near future. KEPLER's engagement policy covers transparently environmental factors, social factors and governance factors.There is a formal process for identifying and prioritising engagement activities carried out by internal staff. These are exposure (holdings) and in reaction to ESG impacts with has already taken place. To monitor and evaluate the progress of your engagement activities, we define timelines of the milestones and goals and establish a process for when the goals are not met.

There is both a "positive" engangement process as well as a "negative" engagement process.

- Positive engagement: motivation for investability

The aim of positive engagement is to motivate companies via contacting them (letter) to take the necessary steps to be investable. These companies either do not violate any exclusion criteria, however, do not reach the investment threshold or they violate exclusion criteria but are above the investment threshold. KEPLER receives the potential for improvement for every company by oekom research AG. Positive engagement is done bi-annualy.

- Negative engagement: in case of any violation of exclusion criteria

oekom research AG quarterly sends the new investment universe including those companies which violate an exclusion criterion. KEPLER contacts these companies via letter, including an explanation of the violation as well as the consequence: sale of stocks (equities or bonds). In case the company answers, oekom research AG undertakes the following dialogue with the company. The maximum period between publication of any breach and final sale is 4 months.

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.

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Indicate if your organisation’s investment principles, and overall investment strategy is publicly available

02.4. Additional information [Optional].

Concerning "Reporting":

We publish a large number of documents and information on our homepage, for instance exclusion criteria for companies and countries, current engagement activities, daily reports including all assets for any ethical funds etc. This would be too many URLs. Details can be found on different pages of our homepage.

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.

Unfortunately, KEPLER's Conflicts of Interest Policy is only available in German. We can make it available on demand.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)