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Swen Capital Partners

PRI reporting framework 2019

Basic information [OO 01 - 09] Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]

Strategy and Governance

Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Innovation [SG 18] Communication [SG 19]

Indirect – Manager Selection, Appointment and Monitoring

Selection [SAM 02 - 03] Appointment [SAM 04] Monitoring [SAM 05 - 07] Outputs and outcomes [SAM 08 - 09]

Confidence building measures

Confidence building measures [CM1 01 - 07]

Export Public Responses

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Asset class implementation not reported in other modules

SG 16. ESG issues for internally managed assets not reported in framework

Describe how you address ESG issues for internally managed assets for which a specific PRI asset class module has yet to be developed or for which you are not required to report because your assets are below the minimum threshold.

Asset Class	Describe what processes are in place and the outputs or outcomes achieved
Fixed income - Corporate (non-financial)	The same responsible investment policy applies for each asset class. SWEN CP always acquires minority stakes in each invested company. De facto, the implementation of advanced RI initiatives requires approval of the controlling shareholder. Due diligence process Any investment opportunity must comply with SWEN CP's exclusions policy: application of the international conventions of Ottawa and Oslo (prohibition of landmines and cluster bombs), exclusion of weapon (sales and production) and coal-related activities. Reputation surveys are conducted to identify any past incident or non-financial controversy. For its direct investment activities, the analysis focuses on the most material ESG issues and takes into account the sector and the size of the companies / infrastructure assets thus financed. This analysis highlights development and questioning points that are complemented by interviews or questionnaires. Holding period The ESG analysis of the portfolio companies is ensured on the basis of answers to questionnaires completed online (through the controlling shareholder), via an ESG data collection and management tool. A follow-up of the information collected is then carried out over time. Direct investments benefit from an ongoing monitoring of ESG incidents. Reporting ESG practices of direct investments are shown in annual ESG reporting communicated to SWEN CP’s clients.
Private equity	The same responsible investment policy applies for each asset class. SWEN CP always acquires minority stakes in each invested company. De facto, the implementation of advanced RI initiatives requires approval of the controlling shareholder. Due diligence process Any investment opportunity must comply with SWEN CP's exclusions policy: application of the international conventions of Ottawa and Oslo (prohibition of landmines and cluster bombs), exclusion of weapon (sales and production) and coal-related activities. Reputation surveys are conducted to identify any past incident or non-financial controversy. For its direct investment activities, the analysis focuses on the most material ESG issues and takes into account the sector and the size of the companies / infrastructure assets thus financed. This analysis highlights development and questioning points that are complemented by interviews or questionnaires. Holding period The ESG analysis of the portfolio companies is ensured on the basis of answers to questionnaires completed online (through the controlling shareholder), via an ESG data collection and management tool. A follow-up of the information collected is then carried out over time. Direct investments benefit from an ongoing monitoring of ESG incidents. Reporting ESG practices of direct investments are shown in annual ESG reporting communicated to SWEN CP’s clients.
Infrastructure	The same responsible investment policy applies for each asset class. SWEN CP always acquires minority stakes in each invested company. De facto, the implementation of advanced RI initiatives requires approval of the controlling shareholder. Due diligence process Any investment opportunity must comply with SWEN CP's exclusions policy: application of the international conventions of Ottawa and Oslo (prohibition of landmines and cluster bombs), exclusion of weapon (sales and production) and coal-related activities. Reputation surveys are conducted to identify any past incident or non-financial controversy. For its direct investment activities, the analysis focuses on the most material ESG issues and takes into account the sector and the size of the companies / infrastructure assets thus financed. This analysis highlights development and questioning points that are complemented by interviews or questionnaires. Holding period The ESG analysis of the portfolio companies is ensured on the basis of answers to questionnaires completed online (through the controlling shareholder), via an ESG data collection and management tool. A follow-up of the information collected is then carried out over time. Direct investments benefit from an ongoing monitoring of ESG incidents. Reporting ESG practices of direct investments are shown in annual ESG reporting communicated to SWEN CP’s clients.

16.2. Additional information [Optional].

SG 17. ESG issues for externally managed assets not reported in framework

17.1. Describe how you address ESG issues for externally managed assets for which a specific PRI asset class module has yet to be developed or for which you are not required to report because your assets are below the minimum threshold.

Asset Class

Describe what processes are in place and the outputs or outcomes achieved

Fixed income - Corporate (non-financial)

Due diligence process

Any investment opportunity must comply with SWEN Capital Partners' sectoral exclusion policy: application of the international conventions of Ottawa and Oslo (prohibition of anti-personnel mines and cluster bombs), exclusion of weapon-related activities (sales and production) and coal-related activities. These ESG requirements are specified in side letter agreements signed between SWEN CP and its fund managers. Moreover, reputation surveys are conducted to identify as early as possible any past incident, litigation or non-financial controvers that potentially have affected the fund manager or its underlying portfolio companies.

For its investment activities in funds, whether primary or secondary, the ESG analysis is applied to all the management companies studied, regardless of their investment strategy or size. The cornerstone of this analysis is based on the study of the management companies' response to the annual ESG due diligence questionnaire and available documentation.

Holding period

A constant monitoring of the ESG practices of the General Partners and their underlying the portfolio companies is ensured on the basis of answers to questionnaires completed online, via an ESG data collection and management tool.

Reporting

All the ESG data collected are used to prepare and deliver annual ESG reporting to SWEN CP’s clients.

17.2. Additional information.

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