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SKY Harbor Capital Management

PRI reporting framework 2020

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。

          engagement as fixed income investors
          industry participation

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。

SKY Harbor’s investment process is built around the unique risks of the high yield market. We are guided by an investment philosophy that seeks superior long-term returns built through the compounding of income over time and the avoidance of principal losses. Our investment approach intends to capitalize on the inefficient pricing of risk in the high yield market by selecting fundamentally and technically secure securities that produce the desired income stream with less volatility than the high yield market. Our process targets issuers with sustainable business models, long-term operating potential and financial flexibility, transparent governance and management teams attentive to improving creditworthiness.

Fundamental to this process is the consideration and inclusion of ESG factors. In our view, companies which embark on sustainable and responsible business practices that promote diversity and inclusion, good governance principles, responsible use of natural resources and moderate carbon emissions are companies positioned for the future. Over time, companies that operate with higher standards are more likely to lower financial risks and generate excess returns.

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]

From an investment perspective, SKY Harbor's process is designed to identify, value and manage specific High Yield market risks, which inherently includes ESG factors. As is the case for our analysis of all risk factors, the goal of ESG analysis is best characterized by systematic identification and monitoring to manage how these risks affect issuers and industries over time. Specifically, we look for sustainability and responsible behavior in the companies we invest in, and their ability and willingness to service debt obligations. Among other risks, ESG factors are incorporated in our fundamental credit analysis to assess, for example, environmental and product liabilities, employee training and retention, and corporate governance and legal risks. We recognize the potential for a high correlation between companies that manage ESG factors well and superior investment returns.

SKY Harbor utilizes a risk-based methodology for assessing and evaluating ESG factors pertinent to the issuers in which we invest. This approach is applied across all strategies. Certain individual portfolios may be further defined by client-directed ESG criteria or regulatory requirements as in the case of UCITS funds for which SKY Harbor is the investment manager.

01.6. 補足情報 [任意]


SG 01 CC. Climate risk

01.6 CC. 投資期間において特定され、組織の投資戦略・商品に組み込まれている気候関連のリスクおよび機会について記述してください。

特定された気候関連の移行リスク・物理的リスクおよび機会、ならびに投資戦略・商品にそれらがどのように組み込まれているかを説明してください。(500 語以内で自由に記載)

As a boutique firm specializing solely in corporate high yield bond portfolios, SKY Harbor Capital is keenly attuned to identifying risks and opportunities in pursuit of our mission to provide superior risk-adjusted returns and world-class investment information to our clients and investors. Our investment teams and product working groups employ a variety of traditional techniques as well as proprietary quantitative investment models.  Together these methods, sometimes referred to as the "mosaic" approach to investment analysis, attempt to capture what we believe are all the relevant public, non-public, material and non-material information about a high yield issuer to determine the long term value of the securities that we include in our clients' investment portfolios.

We explicitly recognize that environmental and climate-related risks and opportunities (as well as social, governance and other environmental factors) are an important part of the mosaic in evaluating high yield issuers. For example, in 2015, we divested our client portfolios of securities in the business of coal mining after concluding that the damage to the climate from these activities were no longer sustainable within the investment time horizon of our flagship strategies and products (which generally range from 1 to 5 years). Beginning in late 2016 we also began to underweight investment in the fossil fuel industry and in December 2018 launched a product that, among other things, explicitly excludes companies in the coal and fossil fuel sectors.

Our research framework integrates macro economic and market themes into a dynamically weighted fundamental analysis, the key pillars of which are: Industry Outlook, Business Due Diligence, Financial Analysis, and ESG Risk Factors. Our in-house research analysts utilize this framework to present the key risks and opportunities of the credits we analyze. A key component of that analysis is the ESG pillar, which is specific climate-related transition and physical risk analysis.

While not every Issuer has the same degree of exposure to climate-related physical and transition risk, but where relevant we specifically evaluate physical risk factors such as extreme weather, environmental degradation or remediation, GHG emissions, water usage and waste. Transitioning to a lower-carbon economy needs to be a top management priority, which is often manifested by such data points as: public sustainability reporting, periodic sustainability commentary, emissions disclosure, and the presence or absence of products that contribute to a lower-carbon economy. Each of the foregoing items are factor inputs to our analysis that we apply to each company that our analysts cover.

We have embarked on a project, an enhanced framework, that will incorporate a more detailed rubric that is intended to take the analysis further by incorporating principles and concepts set forth by the TCFD and SASB. We expect to be working on this enhancement throughout the remainder of 2020.


01.7 CC. 組織はそれら気候リスクの可能性および影響を評価しましたか?


2014: inherit client portfolio with exposure to coal

2015: coal mining exclusion

2016: preliminary assessment of fossil fuel exclusion

2017: underweight fossil fuel, metals and mining, and energy sectors

2018: launched a ESG UCITS fund specifically excluding companies with significant revenue from coal or fossil fuels

2019: retained vendor to perform emissions analysis of the flagship strategies

2020: enhancing the sustainability factors in the firm's proprietary rubric; becoming a member of the SASB Alliance

01.8 CC. 組織はTCFDを公式に支持しますか?

01.9 CC. 重大な気候関連リスクおよび機会を特定・管理する組織全体の戦略がありますか?


SKY Harbor abides by the principles of each organization to which we are a signatory.  With respect to the more climate-related coalitions, we became a signatory to UNPRI in 2015 and joined the PRI Fixed Income engagement in 2016. In 2017 the firm became a signatory to the UN Global Compact and committed to the SDGs. In 2018 we joined the PRI engagement on climate change transition for oil and gas companies, and in that same year we subscribed to the TCFD. The Investment Committee and investment strategy working groups have specific climate-related investment risk & opportunities data points that must be addressed in producing a complete issuer analysis. As part of each employee's job performance senior management expressly evaluates the extent to which employees have incorporated these standards in their performance. In addition SKY Harbor has also established a specific Sustainability Working Group that works alongside the Investment Working Groups to promote and assist in the systematic identification of material climate-related and other sustainability risks and opportunities. 

1.10 CC. TCFD開示を発表するために組織が使用する文書/通信を示してください。

SG 02. Publicly available RI policy or guidance documents


02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。





          engagement as fixed income investors



          industry participation


02.2. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。







02.3. 補足情報 [任意]

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。

SKY Harbor recognizes that potential conflicts of interest may arise in conducting the business of an investment manager and has clearly stated compliance policies and procedures designed to address potential conflict that may arise. Such policies and procedures include, but are not limited to, side-by-side management, trade allocation, brokerage practices and asset valuation and liquidity determinations. Operationally, systems and risk controls have been constructed to identify possible conflicts, which if detected, are escalated to the Chief Compliance Officer and Chief Risk Officer for appropriate mitigation. Conflicts of interest in personal trading are mitigated by the firm’s Code of Ethics, which requires employees to obtain Compliance approval for trading securities of an issuer of below-investment-grade debt. SKY Harbor’s Conflicts of Interest Policy is stated in our Compliance Manual and SKY Harbor conflicts of interest are disclosed in the Part 2A of the Firm’s Form ADV filed with the SEC.

03.3. 補足情報 [任意]

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、投資先企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

Every member of the investment team has access to real-time data feeds from a number of financial data vendors and news organizations.  The information from these sources are monitored continuously by the portfolio managers, traders, research analysts and compliance. Any developments concerning investee entities, particularly of a negative nature or involving adverse regulatory circumstances, would be immediately picked up not only by the analyst assigned to that investee entity but by the rest of the investment team as well.

Given our strong fundamental research experience, when we observe negative information, including ESG-related incidents, either directly regarding the issuer or tangentially from economic or sector sources, we will initiate an immediate review of the credit. If the investment team believes the trends or risk profile will remain negative, we will sell the position or initiate an engagement with the company, determined by severity of the incident on a case-by-case basis.