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PM Capital

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.

PM CAPITAL defines Responsible Investment (RI) as follows, RI is an investment process that considers the governance, social and environmental consequences of investments, both positive and negative, within the context of rigorous financial analysis.

In our RI policy, we address:

PM CAPITAL'S Philosophy on RI; and

How ESG matters are incorporated into investment and voting decisions.

The following factors should be given due consideration (but are not limited to) in the context of overall assessment of a company's risk management framework, including ESG matters.

Key issues identified during the research process should be referenced and, if significant, discounted in the company valuation or target entry/exit price.

Significant ESG issues should be incorporated in Key Issues & Questions and the Investment Summary documents for active monitoring and engagement with the company.


1. Board Structure

2. Operational Risk Management / Monitoring (among others)

3. Directors Remuneration

4. Executive Remuneration


1. Sustainability Management Practices

2. Carbon Emission Reduction Policy


1. Occupational Health& Safety Standards

2. Child Labor Risk Management

3. Other - define in need

For further details, please see on PM CAPITAL's Responsible Investment Policy which is available publicly via:

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].

PM Capital's Corporate Responsibility section of the website can be accessed from the following URL:

Within this page is where we make our Responsible Investment Policy available for download.

General information on PM Capital's overall investment philosophy is described here:


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.

PM CAPITAL maintains a Conflicts of Interest & Related Party Policy.

Our policy requires investments to be managed in a manner necessary to promote the interests, objectives and strategies of the investment portfolio. The Company will comply with the Execution and Trade Allocation Policy.

In summary, the Company will consider any actual, apparent or potential related party and conflict of interest issues in its management of the portfolio’s assets, particularly where an entity related or associated within the PM CAPITAL Group is involved.

  • always act in the best interests of the party it is representing
  • where participating in an arrangement in more than one capacity, it must fulfil each of its roles diligently and with due care;
  • agreement setting out the terms of the arrangement provides capacity for any potential conflict of interest arising to be dealt with and a process stipulated for the arbitration
  • where a transaction involves a trade of an asset from one portfolio/fund to another the transaction must be conducted either:
    • on market; or
    • on a demonstrable arms-length basis and in the best interest of each portfolio/fund with supporting documentation


03.3. Additional information. [Optional]

The 3 mechanisms that PM CAPITAL will use to manage conflicts of interest will involve one or a combination of the following:
1. controlling conflicts of interest

  • Identifying - report the actual, apparent or potential conflict of interest to the Compliance Officer in the first instance.
  • assess and evaluate - determine in each case if the conflict:
    • 1. can be controlled; and
    • 2. should be disclosed; or
    • 3. should be avoided.
  • Implement an appropriate response:
    • disclose conflict;
    • provide an alternative source of service and treatment of a client or member;
    • initiate internal disciplinary action; or
    • take any other action the Compliance Officer, CEO, or the Board, considers appropriate
  • Monitoring Conflicts Management
    • Compliance Officer will maintain a Conflict of Interest register
    • Compliance Measures - keep monitoring records
    • Records - at least 7 year

2. avoiding conflicts of interest; and

3. disclosing conflicts of interest.


PM CAPITAL seeks to encourage good ESG practices and where we believe appropriate, we engage the management of the companies that we own around the improvement of ESG practices.
Failing a suitable outcome, we may approach the boards of listed companies directly, as well as taking our case to the press.
We will generally oppose proposals where we see:
§The election of inappropriate directors, particularly where there is not a majority of independent directors or where there has been excessive turnover of board / senior executives
§Excessive management remuneration arrangements, or a lack of alignment between executive incentive structures and a company’s operating performance
§The appointment of auditors who are not independent.
Agitating for change in this way helps us to unlock the inherent value in a company in order to achieve a better outcome for our investors.
One example involved Austar which, as part of their Employee Share Plan, provided $43 million in interest-free loans to 13 senior managers and an $8.2 million interest-free loan to their chief executive.
As a minority shareholder, we were unable to block the employee share plan and so raised our concerns with management. We then voiced our views in the press to ensure that the new Employee Share Plan had more appropriate incentives in place.

SG 04. Identifying incidents occurring within portfolios (Private)