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Lennox Capital Partners

PRI reporting framework 2019

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

Lennox recognises that ESG encompasses a broad range of issues which may have material impact on the risk and return of our investments and is explicitly assessed as part of Lennox’s investment decision-making process. All companies that Lennox considers for in-depth fundamental research must first pass a qualitative screening process that specifically measures and assesses a company’s governance structure and the environmental and social consequences of its business. Lennox recognises that ESG issues will change over time so regularly examines the following issues:

  • Environmental factors: Impact on local environment and risk management, carbon intensity and consequent exposure to carbon pricing, climate change, water supply and management, waste disposal, pollution and contamination, natural resource use and degradation, and energy use and renewal energy generation.

  • Social factors: Corporate culture and conduct, occupational health and safety, human rights and child labour, workplace relations and working conditions, community impact and engagement, workplace diversity and supply chain management.

  • Governance structure: Board independence and diversity, employee remuneration, bribery and corruption, shareholders’ rights, conflicts of interest, corporate accountability and compliance.

Lennox believes a company’s operations are unsustainable if they cause irreparable damage to the environment, workplace or end consumers, and will not knowingly invest in such 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]

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.

URL/Attachment

URL/Attachment

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.

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.

  • The Conflicts Register sets out those conflicts that are most likely to arise during the conduct of our business. All Staff are required to advise the Compliance Manager should they consider that a new conflict of interest has arisen. Upon review and consideration, the Conflicts Register will be updated as required. This includes a requirement that all Staff declare any outside directorships and business interests to the Compliance Manager, so that the Board can be informed and make an assessment of the likely impacts to our business, and how the conflict should be addressed.
  • Whenever we are entering into arrangements with a new client, or any other party, the Board must consider, as part of the business proposal, whether any conflicts of interest may arise, and if so, how they are to be managed.
  • Once identified, a conflict situation will be assessed by the Compliance Manager to determine its ability to significantly compromise the quality of the services provided to clients.
  • Once the impact of a conflict situation has been assessed, an appropriate response must be developed and implemented, which may consist of avoiding the conflict or managing it through putting in place controls and/or by disclosing it.

03.3. Additional information. [Optional]

Lennox's Governance, Risk and Compliance Framework outlines our conflicts policy in detail.  Included in this document is the Conflicts Register that notes details of the conflict situation, how the conflict will be managed and controls or evidence in place to avoid conflicts.  We can provide this document to you.


SG 04. Identifying incidents occurring within portfolios (Private)


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