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Pengana Capital Group

PRI reporting framework 2018

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.

(Note: this section covers the investment principles of the Pengana International equity strategy.  Most of the assets managed by Pengana that follow an ethical mandate are managed under this strategy.)

Fundamentally we believe:

  • Listed equities are the best path towards healthy returns with moderate risk
  • Risk and return need to be married and should not be managed separately
  • Stock selection is best achieved through the application of logical, common sense criteria that are widely proven to work
  • The portfolio is a mosaic of the 30-50 ideas that work best together, not the 30-50 best ideas
  • Conviction is good.  Conviction with sensible diversification and discipline is better
  • Disciplined flexibility is essential – knowing what to look for within a broad opportunity set
  • Not to confuse data accumulation with analysis – our competitive advantage lies in correctly identifying and understanding the key drivers 

 

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]

(Note: this section covers the investment principles of the Pengana International equity strategies that are managed with ethical mandates.)

The Pengana international equity strategies that have ethical mandates use a negative ethical screen, and seek to avoid investing in businesses that are, in our opinion, currently involved in activities that are unnecessarily harmful to people, animals or the environment.  These activities include:

  • the manufacture or sale of weapons and weapons components
  • tobacco manufacture
  • gambling outlets or systems
  • intensive animal farming
  • animal testing for cosmetics
  • activities that give rise to human rights violations
  • unremediated destruction of the environment
  • uranium mining and nuclear reactors
  • fossil fuel exploration, production, refining, storage and transportation.

ESG factors are also considered as part of the bottom-up analysis undertaken on each stock and form part of the qualitative assessment.  They are seen primarily as a risk management tool, with ESG issues considered for both their short term and long term impact and hence their materiality to a stock.  Pengana employs a specialist ESG research database to assist with company analysis, business involvement and ESG related controversies.


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.

URL/Attachment

URL/Attachment

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

URL/Attachment

02.3. Indicate if your organisation’s investment principles, and overall investment strategy is publicly available

02.4. Additional information [Optional].

 

 


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.

Conflicts are managed in accordance with the company's Conflict of Interest Policy and regulatory obligations (Corporations Act and AFSL license requirements).

Employees, including investment professionals are required to notify the COO or one of the other Responsible Managers of any actual or potential Conflicts of Interest. The COO assesses each conflict and makes a determination on whether the conflict is manageable or unmanageable.

With respect to manageable conflicts the COO will comunicate the conditions on how to proceed. Unmanageable conflicts must be avoided.

Conflicts are monitored and reported to the Board of the Responsible Entity on at least a quarterly basis.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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