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Stichting Spoorwegpensioenfonds

PRI reporting framework 2018

Export Public Responses

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.

We want our investment policy to be in line with the long-term horizon of pension funds. This means we are looking for stable returns on the long-term. We believe that inefficiencies are part of every market, wherefore an active investment policy can pay off. Diversification is key and an extra reward for illiquidity and long-term investment exists. Additionally, we only want to invest in investment categories that are transparent and understandable.

For us, these beliefs have resulted in the management of a largely active, long-term investment portfolio. Our focus is on the quality of a company instead of its valuation. Quality is expressed in both stable financial returns as well as an adequate management of ESG. ESG is therefore an intrinsic part of our selection process. To really get to know our companies, as a shareholder we are very much involved with the companies we invest in and engage in regular dialogue with these companies.

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]

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].

All these descriptions and documents are simplified in order to make them more accessible to our participants and the general public.

Additionally, we have consciously decided not to publish our detailed guidelines on E, S and G factors. This would result in an overload of information to our participants. Much of these guidelines are comparable with the items mentioned in our proxy voting policy. The formalized guidelines on environmental, social and corporate governance factors are available upon request.

Currently, we do not specifically report on climate-related issues. It is however high on our agenda to change this. In the most recent annual report of our clients, we did report on the carbon footprint of our investment portfolio.

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.

The Spoorwegpensioenfonds only has a board. The content of the conflict of interest policy of the board of SPF is:

- Every (potential) conflict of interest has to be reported to the compliance officer.

- Transactions with an/or gifts received from (potential) clients and/or relations of SPF have to be reported.

- Personal investment transactions can in no means be executed based on insider information. The compliance officer  has the right to research all personal investment transactions of board members.

- The compliance officer has the right to research any transaction, gift and (potential) conflict of interest. The results of this research will be reported to the CEO and, if necessary, the Supervisory Board. Sanctions (from warnings to immediate dismissal) are involved for not complying with the conflict of interest policy.

- The conflict of interest policy, jointly with the code of conduct, have to be reviewed and signed every year by all board members.

SPF Beheer, where all of our transactions and the manager selection is done, also has a conflict of interest policy. For more information, see the transparency report of SPF Beheer.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)