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Stichting Spoorwegpensioenfonds

PRI reporting framework 2018

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

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.

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 of our (future) commitments. SPF Beheer manages for us the strategic equity portfolio (SAP). The concentrated nature of this 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, we distracted our 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.

We also 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. 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 (Private)

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

(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


Controversial weapons are part of our standard exclusion list. 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 reasons, tobacco producing companies have not been invested in via 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.

Screened by


The above-mentioned conventions are at the basis of our RI policy. They are used as a 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 not investing in a company.

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.

Screening criteria are established by SPF 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 by SPF Beheer at least once a year, at the time that also the entire ESG policy is reviewed. The results of this review are reported to us in a Board meeting. From time to time an extra thorough review is planned together with us. Whenever other (innovative) issues reach us or SPF Beheer 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. 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.

05.5. Additional information. [Optional]

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) Implementation: Integration of ESG issues

LEI 08. Review ESG issues while researching companies/sectors

08.1. Indicate which ESG factors you systematically research as part of your investment analysis and the proportion of actively managed listed equity portfolios that is impacted by this analysis.

ESG issues

Proportion impacted by analysis




Corporate Governance

Corporate Governance

08.2. Additional information. [Optional]

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 the 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)