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Banco BTG Pactual S.A.

PRI reporting framework 2019

Export Public Responses

You are in Strategy and Governance » Investment policy


SG 01. RI policy and coverage


01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類と対象範囲を示してください。


01.3. 投資ポリシーが以下のどの項目をカバーしているか明示して下さい:

01.4. 組織の投資原則および全体の投資戦略、受託者義務(または同等のもの)の解釈、ならびに、ESGファクターおよび実体経済の影響をどのように考慮に入れているかについて説明してください。

BTG Pactual has a global Environmental, Social and Governance (ESG) Policy applicable to all business units and activities development by the Bank. This Policy set ESG principles and guidance that should be follow by each employee during the decision make process and during daily routine at the Bank.

BTG Pactual has a huge structure of policies concerning others matters, as proxy voting policy, compliance policy, responsible investment policy and a Code of Conducts and Ethics. As example, the responsible investment policy for timberland investments set nine main principles that drives the decision making process in this specific asset strategy, we highlight some of them: 

Strictly comply with environmental, social, health and safety laws, regulations and standards

Strictly comply with anti-corruption and bribery regulations

Promote ESG awareness amongst employees by developing and providing specific training programs and

Report ESG performance with clarity and transparency.  

01.5. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。[任意]

BTG Pactual’s approach to sustainability is based on an understanding of our responsibility towards our partners, society and the environment as a complete financial service provider.

The main fundamentals behind BTG Pactual ESG approach are: (i) BTG Pactual’s requirement to adopt sustainable social and environmental practices, especially because management recognizes the importance of disseminating ESG practices; (ii) the Brazilian Central Bank’s new regulation on ESG risk management; (iii) the need for an area to provide technical advice on ESG matters, centralizing relevant information and data required by stakeholders as evidence of ESG risk controls; and (iv) the need to appoint ESG spokespersons who are aware of ESG controls, initiatives and activities and can adequately disseminate information to our clients, shareholders, staff members and regulators.

Our ESG Global Policy reflects our long-term ambition and unconditional commitment to responsible and sustainable development. We consistently focus on the long-term implications and results of our actions, prioritizing these long-term benefits over short-term gains, always looking into ESG risks and opportunities. We believe that sound business practices and corporate responsibility are long-term drivers that must be applied daily to create shareholder value through sustainable growth, attractive recurring revenue streams and business perpetuity.


01.6. 補足情報 [任意]

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SG 01 CC. Climate risk (Not Applicable)

SG 02. Publicly available RI policy or guidance documents (Not Completed)

SG 03. Conflicts of interest

03.1. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

BTG Pactual Code of Business Principles and Ethics sets ethical behaviour and professional conduct that must be followed by BTG Pactual partners, employees, interns, consultants, contractors and temporary workers ("Staff") when interacting with each other, with Clients or with counterparties and any other third parties related to our business. Also, our Global Policy on Conflicts of Interests sets out BTG Pactual’s overall approach to ensure the appropriate identification and management of conflicts of interests relating to BTG Pactual and its Clients. Our Global Compliance Manual concentrates on conflicts of interests involving Staff Members. Some of these conflicts are further controlled through specific policies (e.g.: Global Personal Investment Policy; Global Information Barriers Policy; Global Outside Directorship and Other External Functions Policy, etc.). Staff should avoid business conflicts. If the conflict cannot be avoided it should be reported to Senior Management and Compliance, mitigated and, if applicable, disclosed to Clients or other affected parties.

In 2018, BTG Pactual established a new Integrity Program to improve the Group's integrity, transparency and ability to escalate issues. To oversight this program, a new Compliance Committee was implemented and is chaired by Nelson Jobim. The Committee meets monthly and reports to Board of Directors. 


03.3. 補足情報 [任意]

BTG Pactual's Code of Business Principles and Ethics sets ethical behaviour and professional conduct that must be followed by BTG Pactual partners, employees, interns, consultants, contractors and temporary workers ("Staff") when interacting with each other, with Clients or with counterparties and any other third parties related to our business.  We are oriented to conduct business on a Client focused maner, which means our mission is to serve Clients in an innovative, cost-effective and transparent manner, understanding their needs, optimizing solutions and establishing long term relationships. This means that in BTG Pactual we "Identify and avoid, or manage, conflicts of interest, always using the utmost transparency. In general, our Clients have priority over BTG Pactual, and BTG Pactual has priority over staff members". We also strive to deliver quality results that exceed expectations effectively taking responsibility for our action, which means that we "Identify, manage and escalate concerns and/or conflicts of interest promptly to management or control functions as appropriate" as established in our Cofe of Business Principles and Ethics. 

Compliance Committee is chaired by Nelson Jobim - graduated in 1968 with a Bachelor in Legal and Social Sciences from the Law School of Universidade Federal do Rio Grande do Sul (Federal University of Rio Grande do Sul). He held other positions as member and President of the Federal Supreme Court (STF), from 1997 to 2006, Minister of Justice, Minister of Defense, President of the National Council of Justice and Minister and President of the Superior Electoral Court. Mr. Jobim acted as a lawyer from 1969 to 1994; from 2006 to 2007; and from 2011 to 2016.

SG 04. Identifying incidents occurring within portfolios (Private)