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PRI reporting framework 2020

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

          LFR Partnership - methodology
          Own ESG report on portfolio

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.

The management and control of investments requires the operating procedures and procedures for establishing and tracking risk limits, tracking returns and the reporting function to be written down and collected in a procedures guide.

Investment management within the MAPFRE Group should be governed by ethics and alignment with the values which represent the company. (The Code of Ethics and Good Governance) In addition the investment policy of MAPFRE Group should be geared toward achieving sustainable development, incorporating ESG criteria (social, environmental and good corporate governance). In this regard, we should put forth our best efforts to align ourselves with the United Nations' Principles for Responsible Investment, fulfilling and developing the following points in the upcoming years.

The Securities Investment Plan & Property Investment 2018, included, among others, the following principles:  Prudence, Responsibility, Sustainable Investment, Relationships with intermediaries and external collaborators in general, and Energy efficiency and environmental sustainability (focus on property investments).

Regarding our investment strategy, we have developed a partnership with a specialised firm with which we are developing our own methodology in ESG investment research, as well as ESG focused products.

As well, MAPFRE ´s Sustainability Plan includes a specific chapter regarding responsible investments, described in next question

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]

We are still developing the implementation of our policy. In this sense, we have a twofold approach. On one hand, in order to integrate ESG elements as soon as possible, we use an "a posteriori" approach; at the same time, more oriented But the key elements are:

- "A posteriori" approach. First we examine the ESG score of all portfolios. Afterwards, we discuss, at the risk committee, the need to move any of them in order to improve its overall ESG level or to sell assets with a too low score. The goal of this approach is to have a tool as soon as possible so we can start implementing ESG criteria.

- "A priori" approach. We integrate ESG in the research of possible investments. We are still developing and spreading the methodology, which nowadays is still in a early stage and focused only in just a few assets. We are using the Integral Value Approach methodology of our partners LFR, which has recently received several prizes from French authorities.

As a general approach, we acknowledge that, as investment managers, we need to develop our own understanding of ESG issues. So, we focus on the aspects of ESG risks and opportunities that are most material to our process: that is exactly what we are trying to implement.

All of these tools are part of the actions contained in the MAPFRE Sustainability Plan (2019-201) launched after the success of the  which includes a specific chapter regarding responsible investments. Its key remarks are:

  • Incorporate Environmental, Social, and Governance (ESG) criteria in MAPFRE investment processes, while ensuring such investments remain profitable or are restricted to parameters that can have a subjective component. The reputational risk of an investment is also incorporated in the process.
  • Review of the valuation methodology of publicly traded companies
  • To improve the valuation model of MAPFRE for valuation of publicly traded companies, incorporating both financial and non-financial components (environmental, social, and governance [ESG] factors)

The plan suggests the following actions:

  • Specific training course for MAPFRE professionals, primarily the Investment Area, at a global level.
  • Collaborate with leading universities from around the world specialized on ESG issues for the conducting of specific studies for MAPFRE
  • Dissemination of contents that position MAPFRE in this area
  • Creation of products ad hoc that incorporate ESG criteria.
  • Principles for Responsible Investment from United Nations (UNPRI) 2017.

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].

Athough we don't publish our investment policy, what we made public is our ESG assessment framework. You can find it at:, pages 62 to 65. Below, you can find an excerpt:

MAPFRE has its own ESG analysis framework that is reviewed periodically to incorporate best practices in this area. It also has a qualified SRI working group and, in addition, it has an Investment Risk Committee, which periodically analyzes the composition of the portfolios, its ESG evaluation and analyzes any controversies that may arise.

Within the scope of the SRI, the investment team has the following functions:

Regularly issues ESG reports, which are analyzed by the SRI team prior to their presentation by the Risk Committee.
Constant monitoring in order to alert on any controversies or risks in the ESG field that may arise during the normal course of operations, and to inform the Risk Committee.
The investment team is responsible for applying any grounds for exclusion approved by MAPFRE.

In the case of management delegation, the company that is managing the portfolios shall be informed so that the exclusions are applied, with the time limit of their implementation being determined by common agreement.

MAPFRE’s Corporate Investment Area is responsible for ensuring that the organization complies with the established responsible investment principles and submits an annual report to the Sustainability Committee, which is the most senior part of the aforementioned area.

With regard to SRI strategies, MAPFRE supports the implementation of the integration strategies as a priority, although it does not rule out the use of other strategies such as exclusion, engagement, best-in-class or proxy-voting strategies.

In 2019, MAPFRE agreed to not invest in electricity companies that generate over 30 percent of their revenue from coal-produced energy. It incorporates this exclusion rule into its SRI framework, which reinforces the Group's climate strategy.

Furthermore, in 2019, MAPFRE joined Spainsif, (a prestigious forum in the area of sustainable and responsible investment in Spain) also becoming a member of its board of directors.

MAPFRE Asset Management also holds ISO 14001 and 50001 certification.

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.

You can find our policy at the URL:

There we have, among others, these three documents:

- Institutional, Business and Organizational Principles of the MAPFRE GROUP 

- Policy for Managing Conflicts of Interest and Operations related to Significant Shareholders and Senior Representative and Management Roles

- Internal code of conduct relating to listed securities

 - Corporate Ethical Whistleblower Channel 


03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)