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INOCAP Gestion

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.


Since its creation in 2007, INOCAP Gestion has a committed conception of its activities. Working closely with entrepreneurs in the real economy, the company is very attentive to the challenges faced by innovative companies. ESG policies (social, environmental and governance) are among those. They are now a major concern for the players in an ambitious, forward-looking economy. As a responsible, independent and transparent management company, INOCAP Gestion seeks to ensure the satisfaction of its customers, through the financial performance of its products but also through extra-financial commitments. By giving new meaning to investment, the adoption of a responsible approach is part of this qualitative and demanding conception of our businesses. INOCAP Gestion is therefore convinced that companies and their management have a good understanding of ESG issues, enriching the internal dialogue and creating the conditions for sustainable success.
 

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

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.


Conflict of interest prevention is based on the principles outlined in INOCAP Gestion's Rules of Procedure and the provisions of the AFG Code of Ethics. Each employee acknowledges having read these Internal Rules of the Code of Ethics and Procedures upon his entry into the company.
In application of these Internal Rules, the employees of the Management Company undertake to:
- Respect the principle of transparency in relations with fund unitholders and principals;
- Respect the professional secrecy and the confidentiality of the information held;
- Respect the principle of market integrity;
- Respect the obligation to refrain from holding privileged information;
- Refrain from engaging in activities that are incompatible with their duties;
- Respect a principle of non-competition with the activities of the Management Company and the companies resulting from the portfolios of holdings of funds and management mandates;
- Refrain from accepting gifts or benefits that may compromise their independence of decision;
- Perform personal transactions only in accordance with the limiting rules set by the Management Company;
- Refrain from providing paid consulting services to partner companies, unless this service is provided on behalf of the Management Company.
 

03.3. Additional information. [Optional]


Members of the Fund Advisory Committee managed by the Management Company undertake to:
- Respect the confidentiality of information held;
- Respect the obligation to refrain from holding privileged information;
- Inform the Management Company of transactions carried out in a personal capacity in relation with partner companies;
- Report to the RCCI of the Management Company any conflict of interest situation that they would be faced with, as soon as a Managed Fund, a partner company or the Management Company itself is involved
 


SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within portfolio companies.

04.2. Describe your process on managing incidents

INOCAP Gestion puts in place a procedure allowing all of its employees to inform the compliance and internal control officer of their concerns about dysfunctions they have noticed in the effective implementation of the compliance obligations.

An incident is a fortuitous and unpredictable event that occurs and changes the expected and normal course of events. It is the materialization of an operational risk. Operational risk is defined by the Basel Committee as "the risk of loss from inadequate or failed internal processes, people and systems or external events".

In particular, it covers operational risk, incidents resulting from human errors, fraud and malfeasance, information system failures, problems related to personnel management, commercial disputes, accidents, fires, floods.

Any employee or officer undertakes to communicate the incidents noted whether or not they are involved in the event, as soon as possible to the RCCI.

The incident is deemed significant in the following cases:

- incidents that by their nature must be reported to the regulatory authorities;

- incidents arising from an alert from a regulatory authority, the custodian or auditors;

- proven valuation incidents;

- incidents that could have significant consequences for an employee;

- Incident that could jeopardize the activity;

- incidents affecting the interest of the holders;

- claim addressed to the management company;

- incidents whose financial impact represents more than 1% of the net assets.


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