Our complete negative screening process implemented on the exclusion of Cluster Bombs and Anti-personnel landmines
Edmond de Rothschild Asset Management (France) has implemented a policy excluding issuers involved in the production of cluster bombs and anti-personnel mines from all of the UCITS/AIF and mandates it manages.
The list of issuers involved in the production of cluster bombs and anti-personnel mines is drawn up at least once a year by the RI management team, in cooperation with the Chief Investment Officer. This list is based on internal research and publicly-available lists (PGGM, Norwegian pension fund, Australian pension fund, etc.)
At the Voting and Engagement Committee, which meets at least twice a year, this list is submitted by the RI investment team and reviewed and validated, as appropriate, by the Committee. The Committee's minutes include the validation of the list and its composition. It is circulated to all the Investment teams, to the Executive Board and to Internal Control and Compliance.
After validation by the Voting and Engagement Committee, the list is e-mailed by Internal Control and Compliance to the Risk Department so that the latter can update the setting of the pre-trade limit in the Dimension front office tool. This limit applies to all of the portfolios managed by Edmond de Rothschild Asset Management (France). It lists the stocks prohibited from the investment universe of the funds managed by Edmond de Rothschild Asset Management (France). Once the list has been programmed, the fund manager may no longer transmit an order on this issuer.
Our complete negative screening process implemented for both the corporate and sovereign debt issuers
Edmond de Rothschild Asset Management (France) has drawn up a list of banned countries for which it is necessary to obtain prior approval from Internal Control and Compliance Department of the Edmond de Rothschild Asset Management (France) before making any investments. As a result, this list of banned countries has an impact in the authorisation of our investment for the equities, corporate and sovereign debt.
Nearly 30 countries appearing on this list are subject to an embargo put in place by the United States and Europe or have been subject to financial sanctions or to asset freezes.
Some countries are formally prohibited (5 countries under embargo, i.e. Cuba, Iran, Syria, North Korea and Sudan), while others are placed under a close monitoring: this triggers an analysis on a case by case basis by the internal control and compliance department which authorizes or prohibits the investment within the day.
In order to enforce this screening, systematic pre-trade blocking limits have been set up in the Dimension front office tool: this pre-trade block limit is set in all cases, except for the sovereign debt of the following countries (i.e. Ukraine, Russia, Egypt, Iraq, Tunisia, Bosnia & Herzegovina) due to a lack of sanctions.