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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

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.

We formalised our investment principles in an ethical Charter and several other documents. In its ethical Charter, Capital Export stated its committment to progress both for itself and its portfolio companies in four main areas: 

1/ Promoting equity, transparency, respect for others, and honesty
2/ Ensuring respect for all human beings, defense of fundamental human rights and the common good, solidarity, and attention to the most vulnerable
3/ Encouraging long-term economic development that creates jobs and sustainable economic resources while respecting all the company's stakeholders (clients, suppliers, investors, and employees)
4/ Ensuring environmental protection

We also listed behaviours that we consider unethical and therefore disqualifying for any investment. 

We are particularly committed to promoting our ethical principles and objectives, both internally and through our investments, and to strictly apply disqualifying factors to our investment activities.

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].


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.

Potential conflicts of interests (related to relations between the management company / Portfolio company / LPs) are ruled by different documents:

  • Funds' By-Laws
  • Procedures (in particular the procedure for the prevention and management of conflicts of interest) written and updated in collaboration with our Compliance Officer
  • Capital Export's Code of ethics

All employees sign this Code, that sets out the rules of good conduct and the fundamental ethical principles. Regarding preventing conflicts of interest, this Code deals, in particular, with relations with companies in which the fund holds directly or indirectly a stake. Everyone agrees to respect the rules regarding: use of outside services, confidentiality, co-investment rules, complementary investment rules, exit conditions and transfer between portfolios.

Capital Export's Compliance Officer reviews the potential conflicts of interest on a regular basis and takes relevant actions.

03.3. Additional information. [Optional]

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