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Claritas Administração de Recursos LTDA

PRI reporting framework 2019

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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, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

The ESG questions are evaluated on a qualitative basis, duting the analysis of the companies. The team reads official documents such as referrence reports, has contact with Senior Management and collects information with providers. Once this analysis is concluded, this can reflect in a higher discount or a potential contingency that needs to reflected in the company´s valuation.

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]

The company, as a PRI signatary, takes into considerartion in the assessment process the social/environmental conditions. The abalysis is divided in 3 parts: 9I) qualitative aspects, (ii) valuation and (iii) catalysers.

01.6. Additional information [Optional].

          
        
I confirm I have read and understood the Accountability tab for SG 01 I confirm I have read and understood the Accountability tab for SG 01

SG 01 CC. Climate risk (Not Applicable)


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. 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.

Claritas’ performance is based on transparency with clients, ethics, compliance with legislation, and segregation of commercial and operational activities in order to avoid conflicts of interest.  If any conflict of interest is verified, Claritas will not exercise the right to vote at general meetings of the companies issuing the assets held by the funds.  Exceptionally, Claritas may exercise the right to vote in a situation of a conflict of interest, provided that it gives notice to the shareholders of the content and a brief explanation of the vote.

The management team, under the responsibility of CIO, performs the control and execution of this policy and coordinates the decision, registration, and formalization of exercise voting rights on behalf of funds managed by managers.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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