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PRI reporting framework 2020

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.

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.

EDM’s investment process is characterized by in-depth research, analysis and knowledge of target
companies. It uses a rigorous approach to identify quality companies that should be capable of
generating above average growth on a sustained basis and it is reflected in concentrated portfolios
and essentially high risk aversion.
EDM needs to identify material Environmental, Social and Governance (ESG) risks and
opportunities of investee companies. This approach offers a broader and complementary
assessment of companies in addition to information provided by the traditional fundamental
financial analysis.

In signing the principles, Principal Global Investors publicly commits, where consistent with our fiduciary responsibilities, to the following:

I. To incorporate ESG issues into our investment analysis and decision-making processes
II. To be active owners and incorporate ESG issues into our ownership policies and practices
III. To seek appropriate disclosure on ESG issues from the entities we invest in
IV. To promote acceptance and implementation of the principles within the investment industry
V. To work with other signatories to enhance effectiveness in implementing the principles
VI. To report on our activities and progress towards implementing the principles


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]

As asset managers, we must invest on behalf of others with a clear sense of fiduciary duty. We consider that Responsible Investment is part of this fiduciary duty. We look to preserve the long-term interests of our clients by investing in companies where we believe the financial returns are sustainable over the long term.This includes to follow the social and environmental impact of our investee companies to evaluate whether they support conditions for sustainable growth.

1) We believe that time horizons are critical. The ultimate objective is the creation of sustainable, long-term investment returns not just short-term returns.

2) Responsible Investment requires that we follow changes happening at the level of social ecosystems, we believe in the ability of companies to transform social problems into economic opportunities. 

3) Being an active investor is not only about selecting a few companies as measured by an active share, it also means facilitating positive impacts for civil society and the environment.


EDM's responsible investment policy does not make any a priori exclusions of the definition of investment universes.

New incorporations in the investment universe will be discussed on a case-by-case basis in the investment team meetings.

01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

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.

EDM has implemented procedures in order to mitigate the risk of conclict of interest in connection with a responsible investment matter:

- Personal transactions has to be reported to the Compliance Officer.

- The cash of the company is managed independently from portfolio managers and is not invested in listed shares.

- Orders are pre-allocated and the system used does not allow ex-post changes. Group orders must be allocated on a prorata basis in case of partial execution.

- Best execution and best selection policies have been implemented. As an independent company, EDM has no ownership or capital link with any broker or counterparty. Therefore, brokers and counterparties are exclusively chosen in the best interest of investors.




03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Not Completed)