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Federal Finance

PRI reporting framework 2018

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ESG incorporation in actively managed listed equities

Implementation processes

LEI 01. Percentage of each incorporation strategy

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate (1) which ESG incorporation strategy and/or combination of strategies you apply to your actively managed listed equities and (2) the breakdown of your actively managed listed equities by strategy or combination of strategies (+/- 5%)

ESG incorporation strategy (select all that apply)

Percentage of active listed equity to which the strategy is applied
100 %
Total actively managed listed equities 100%

01.2. Describe your organisation’s approach to incorporation and the reasons for choosing the particular ESG incorporation strategy/strategies.

All our equity portfolios and mandates benefit from a norm based screening. This screening is based on the UN Global Compact Principles.

We have a "Best in class" approach for our SRI funds. We want our SRI funds to invest in companies with the best ESG practices regarding their ESG issues.

Our main customer has a dedicated ESG process. It covers a large amount of our assets under management. The philosophy is to limit investment in companies that have a low ESG rating to 10% of investment flow.

Our non SRI funds benefit of our in-house ESG research process which is disclosed to all assets managers. This positive approach is adapted to the institutional investors needs and requirements. Secondly, this approach enables us to invest with a limited bias in terms of sector or geographical scope.


01.3. If assets are managed using a combination of ESG incorporation strategies, briefly describe how these combinations are used. [Optional]



LEI 02. Type of ESG information used in investment decision

02.1. Indicate what ESG information you use in your ESG incorporation strategies and who provides this information.

Type of ESG information

Indicate who provides this information  

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

02.2. Provide a brief description of the ESG information used, highlighting any different sources of information across your ESG incorporation strategies.

Federal Finance Gestion has developed an in-house best in class research covering the whole investment universe. The data mining is realized by three ESG research providers and the dedicated team of analysts. Federal Finance Gestion brokers produce ESG research that can be included in sector-related analysis and to determine ESG issues in each analysed sector.  Portfolio managers and credit analysts are part of the sectors ESG issues definition.

Federal Finance Gestion also has 2 screened stocks lists. The first is an exclusion list of companies involved in clusters bombs and landmines. An ESG ressearch provider delivers it to Federal Finance Gestion . The second is an intern list of companies in risk of breaching one of the UN Global Compact principles.

When relevant, the ESG analysts’ team looks into some ESG issues-specific analysis. For example, in 2017, Federal Finance Gestion produced a study on the coal industry and created a specific tool for carbon issues.

02.3. Indicate if you incentivise brokers to provide ESG research.

02.4. Describe how you incentivise brokers.

SRI team is part of the brokers review. ESG issues have the same voting weight as the financial sector. A qualititative SRI feedback is given to brokers.

When implementing MIFID 2 new regulation, the SRI team participated to the definition of a broker's list. All brokers asked by this team were selected on the final list.

02.5. Additional information.[Optional]

LEI 03. Information from engagement and/or voting used in investment decision-making

03.1. Indicate if your organisation has a process through which information derived from ESG engagement and/or (proxy) voting activities is made available for use in investment decision-making.

03.2. Additional information. [Optional]

(A) Implementation: Screening

LEI 04. Types of screening applied

04.1. Indicate and describe the type of screening you apply to your internally managed active listed equities.

Type of screening

Screened by


We exclude all companies involved in landmines and cluster bombs.

Screened by


We have a best in class approach. For each sector we assess the performance of every company on the 3 pillars : Environment, Social and Corporate governance. We rank them with the aim to identify companies with the best practices on each pillar. Then we compute a SRI score derived from each ESG score, with a various ponderation depending on the sector ESG issues. This assessment is carried out for 3 geographical areas : Europe, France (for small and mid caps) and the rest of World.

Screened by


We have identified a list of companies that don't give us the assurance that they strictly respect the UN Global Compact rules. The assessment is first quantitative. Then we analyse the short list to discriminate the worst performers.

04.2. Describe how the screening criteria are established, how often the criteria are reviewed and how you notify clients and/or beneficiaries when changes are made.

The screening criteria are established by our ESG team. They select criteria for each sector in accordance with the sector's ESG issues. Criteria are reviewed on an annual basis. Clients are notified through our Transparency code.

LEI 05. Processes to ensure screening is based on robust analysis

05.1. Indicate which processes your organisation uses to ensure screening is based on robust analysis.

05.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your ESG screening strategy.

05.3. Indicate how frequently third party ESG ratings are updated for screening purposes.

05.4. Indicate how frequently you review internal research that builds your ESG screens.

05.5. Additional information. [Optional]

LEI 06. Processes to ensure fund criteria are not breached

06.1. Indicate which processes your organisation uses to ensure fund criteria are not breached

06.2. If breaches of fund screening criteria are identified - describe the process followed to correct those breaches.

An internal audit is conducted every week. If breaches are identified, fund managers receive an alert. They have to sell the securities from the companies no more eligible to a SRI fund.

06.3. Additional information.[Optional]