Public HTML RI reports - PRI reporting framework 2019

Naxicap 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

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]

Direct – Private Equity

Overview [PE 01 - 02] Fundraising of private equity funds [PE 03 - 04] Pre-investment (selection) [PE 05 - 08] Post-investment (monitoring) [PE 09 - 13] Outputs and outcomes [PE 14 - 15] Communication [PE 16]

Confidence building measures

Confidence building measures [CM1 01 - 07]

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.

Yes

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

Policy setting out your overall approach

Formalised guidelines on environmental factors

Formalised guidelines on social factors

Formalised guidelines on corporate governance factors

Fiduciary (or equivalent) duties

Asset class-specific RI guidelines

Sector specific RI guidelines

Screening / exclusions policy

Other, specify (1)

          Implementation and oversight responsibilities

Other, specify(2)

          ESG monitoring and reporting standards

Applicable policies cover all AUM

Applicable policies cover a majority of AUM

Applicable policies cover a minority of AUM

01.3. Indicate if the investment policy covers any of the following

Your organisation’s definition of ESG and/or responsible investment and it’s relation to investments

Your investment objectives that take ESG factors/real economy influence into account

Time horizon of your investment

Governance structure of organisational ESG responsibilities

ESG incorporation approaches

Active ownership approaches

Reporting

Climate change

Understanding and incorporating client / beneficiary sustainability preferences

Other RI considerations, specify (1)

Other description (1) Scope of ESG policy

Other RI considerations, specify (2)

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.

As presented in its ESG Charter, Naxicap’s commitments for a responsible investment are as following:
- We undertake to make investments compliant with our values
- We undertake to examine ESG criteria before investing in a company
- We undertake to support and monitor our portfolio’s ESG initiatives from investment to exit
- We undertake to report our ESG actions transparently to our LPs
- We undertake to offer our associates the best possible work environment
- We undertake to be law compliant, internally well controlled and to limit our risks
- We undertake to promote responsible behavior within our profession
- We undertake to support initiatives related to economic progress, our expertise or our values

Naxicap has adopted a set of procedures aiming to integrate the consideration of ESG issues throughout the investment cycle (pre-investment, during investment and at exit, as well as developing best ESG practices within the management company (see ESG policy which is also publicly available at Naxicap's website).

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 ESG policy of Naxicap applies to portfolio companies in which the total amount invested by investment vehicles under management of Naxicap is superior to or equals €5m (covering 95% of AUM as of 31/12/2018). However, for companies not covered in the scope as described above, and in instances where Naxicap considers it appropriate, reasonable efforts will be made to encourage its portfolio companies to consider relevant ESG-related principles.

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 (Private)

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.

Policy setting out your overall approach

URL/Attachment

URL

URL https://www.naxicap.fr/en/commitments/

URL

URL https://www.naxicap.fr/en/commitments/

Attachment (will be made public)

Attachment

NAXICAP ANNUAL ESG REPORT 2018.pdf

Other, specify (1)

URL

URL https://www.naxicap.fr/en/portfolio-key-figures/

Attachment

File Attachment

NAXICAP ANNUAL ESG REPORT 2018.pdf [4039KB]

Climate change

URL/Attachment

URL

URL https://www.naxicap.fr/en/investment-process/

Attachment

File Attachment

Article 173 Report 2018.pdf [872KB]

Other RI considerations, specify (1)

We do not publicly disclose any investment policy components

02.3. Additional information [Optional].

Naxicap has an ESG policy (covering 95% of AUM as of 31/12/2018) describing its ESG approach and how ESG is integrated throughout the investment cycle. The ESG policy was adopted in 2016 and is fully implemented within the management company. The policy publicly available on Naxicap's website. The overall ESG approach of Naxicap is also described in the annual ESG report (pages 10-11, 20-21), available on Naxicaps website.

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

Yes

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

The Management Company complies with the provisions of the ethical regulations for private equity portfolio management companies adopted pursuant to Article 314-2 of the Règlement Général de l'AMF. These regulations are notably related to investment allocation, conditions of investment and divestments, transfer of investments between funds under management.
Allocation rule: Any Investment within the Investment Policy of a Fund will be allocated to the Fund, subject to the priority rights of the related structures and the allocation rules of the investments of the related structures.
Equivalent financial and legal conditions: One fund shall be entitled to benefit from equivalent financial and legal conditions and equivalent completion dates with other funds managed by the Management Company and/or Affiliated Enterprises
Conflict of interests clauses: all Funds' Bylaws include clauses related to conflicts of interest. An advisory committee must give a prior approval of any operation involving a potential conflict of interest.
The investment managers must declare the potential conflicts of interests they identify and explain how they will be prevented. The compliance director makes sure that the solution proposed respects the ethical regulations. Each declaration is listed and classified by Naxicap Partners.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)

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