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SPF Beheer

PRI reporting framework 2018

Export Public Responses

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


LEI 01. Percentage of each incorporation strategy


01.1. 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%

01.2. 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 ESG incorporation strategy is based on a portfolio that is as sustainable as possible, while generating a sufficiently high financial return to fulfill all our (future) commitments. The concentrated nature of our so-called SAP portfolio, where we are not bound by any benchmark and carefully scrutinize every company we invest in, renders it possible to truly integrate ESG issues in every investment decision.

The entire portfolio is subject to an exclusion list. On this list are companies that are involved in the production of controversial weapons. We consider cluster munitions, anti-personnel mines, nuclear, biological and chemical weapons as being controversial. White phosphorous is considered a chemical weapon. Additionally, companies that do not meet our engagement criteria are placed on the exclusion list. Companies that are on the exclusion list can under no circumstances be invested in. Companies that are added to the list are given the opportunity to respond to our investigation. When a company denies allegations, however, we will balance their answer with the proof we have, to determine whether a company will stay on the exclusion list or be removed.

Whenever an investment proposal is made (for a company that is not on the exclusion list), the company is screened against the ESG policy of the funds. The Global Compact principles are leading; but also the Ruggie Framework and the OECD guidelines are taken into consideration. From these general guidelines, SPF Beheer, on behalf of its clients, has distracted its own policy guidelines. Specific focus is placed on the topics human rights, child labour and the environment; however, this does not mean that other issues are not being looked at. Depending on the company's we focus our attention on specific sector risks. Companies have to comply with a minimum standard, otherwise investment will not take place.

After investment smaller issues and potential areas for (ESG) improvement at the company are addressed via regular dialogue with the company. When breaches of our ESG standards are discovered, an engagement process will start. We will demand change within a predefined period of time (depending on the nature of the issue, but usually 1 year to see initial progress). If change is not seen, the company will be divested from and placed on our exclusion list.

Since 2012 we do no longer invest in tobacco companies in this actively managed portfolio. This decision was based on ESG criteria. Tobacco is the only sector that the portfoliomanagers of this portfolio have specifically decided not to invest in. Some other sectors, however, are subjected to further analysis. The fossil fuel sector is  an example of a sector that is intensively scrutinized by us on ESG aspects.

SPF Beheer does employ a thematic strategy, yet not in the actively managed listed equity portfolio. A separate part of the portfolio is fully dedicated to such investments. Themed-like investments (sustainable energy, green bonds, etc.) do also occur in other portfolios, yet not by a pre-determined percentage. We just select the best investments from a combined financial-ESG perspective.

01.3. 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]



LEI 02. Type of ESG information used in investment decision (Private)

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

A) 実施:スクリーニング

LEI 04. Types of screening applied

04.1. 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。




Controversial weapons are part of the standard exclusion lists of our clients. This list applies to all asset classes. In addition to this exclusion list, we do think that certain sectors are irresponsible in general. For this reason, tobacco producing companies have not been invested in the internally managed equity portfolio since 2012. For other sectors we are extremely hesitant to invest in them. We have, for example, no investment in the defense sector in our internally managed listed equity portfolio.

Furthermore, the conduct of a company is reviewed. When we investigate a company and it turns out that it is involved in, for example, the most polluting activities of the fossil fuel sector, we can make the decision not to invest (irrespective of whether the company is on our exclusion list). Companies that breach human rights or pollute the environment can be excluded based on their specific conduct after a process of engagement.

Lastly, we exclude countries that are on the UN sanction list. Also businesses that are more than 20% state owned in these countries are excluded.



The above-mentioned conventions are at the basis of our RI policy. They are used as reason to engage with companies, as a factor of ESG-integration and as input for our exclusion list.

We do not specifically endorse the Convention against Corruption. However, the topic is included in other conventions (such as the Global Compact principles) and we do not support corruption. Therefore, a breach of these principles can still result in SPF Beheer not investing in a company.

04.2. 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。

Screening criteria are established by the Board of the pension funds in collaboration with SPF Beheer. Certain key criteria were established at the start of the ESG policy. Over time these criteria were expanded with other issues that deserve our attention. Criteria, for example, depend upon what is deemed important in our sector, the public transport sector. A clear example is union/collective bargaining rights (exclusion of Walmart).

The screening criteria are reviewed at least once a year, at the time that also the entire ESG policy is reviewed. The results of this review are reported to our clients in a Board meeting. From time to time an extra thorough review is planned together with the pension funds. Whenever other (innovative) issues reach us or the pension funds throughout the year, the issue is discussed in a meeting with the boards of the funds.

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

05.1. 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。

05.2. ESGスクリーニング戦略の一環で包括的なESG調査の対象となるアクティブ上場株式ポートフォリオの割合を示してください。

05.3. 第三者のESG評価がスクリーニング目的で更新される頻度を示してください。

05.5. 補足情報 [任意]

Besides the annual update of third party ESG ratings, controversies are monitored continuously.

LEI 06. Processes to ensure fund criteria are not breached (Private)

C) 実施: 統合

LEI 08. Review ESG issues while researching companies/sectors

08.1. 投資分析の一部として体系的に調査するESG要因と、この分析の影響を受けるアクティブ戦略の上場株式ポートフォリオの割合を記載してください。






Corporate Governance


08.2. 補足情報 [任意]

Every ESG investment analysis focusses on all three factors. The focus is placed on those issues that are relevant for a given sector. Additionally, it is checked whether a company complies with our focus points (human rights, child labour and environment). Lastly, a check is performed on whether the company severely underperforms or has controversies on any of the other indicators.

LEI 09. Processes to ensure integration is based on robust analysis (Private)

LEI 10. Aspects of analysis ESG information is integrated into (Private)