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Artemis Investment Management

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.

Our investment teams use a number of different investment philosophies and processes that are specific to each strategy. The majority of our strategies are managed in teams of two or three managers who are wholly responsible and accountable for the assets they manage, whilst benefiting from the shared specialist knowledge of their investment colleagues. Fund managers have a high degree of discretion and are free to pursue different investment philosophies and processes within a robust risk control framework. Each investment strategy will include an assessment of the material risks and opportunities and their financial impact on the performance of investments. The specific method of incorporating these risks and opportunities including those related to ESG drivers - and at what stage of the investment process - will depend on the approach and timeframe of the fund manager.

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]

Our quantitative strategies use our in-house quantitative model which analyses many factors, both company-specific and macroeconomic, to construct a portfolio of stocks. Meeting managements does not form part of this process. However, our quantitative strategies do vote at company 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.

We have a firm-wide policy which sets out how we will deal with actual or potential conflicts of interest. Our approach is always to act in the best interest of our clients. Artemis is a privately owned, independent partnership and fund management is all we do. So we don’t encounter some of the conflicts of interest faced by larger investment or financial services companies. But it does happen, even in less complex businesses – and we recognise that. For example, the pension scheme of a company in which we are investing might be a client of Artemis; or we may have investments in one of our main distributors, or in Affiliated Managers Group Inc (AMG) which owns a stake in our business; or one of our partners, non-executive directors or employees may be a director of one of our holdings. How we vote may benefit, or be perceived to benefit, Artemis or a particular investor.Where there is a possibility of a conflict of interest any decision to vote against the voting policy is discussed with Artemis’ CIO, and the final decision with explanation is recorded.

03.3. Additional information. [Optional]

We record and cross-reference all potential conflicts in a matrix. This allows us to monitor and prevent any disadvantage to our clients. Both the policy on conflicts of interest and the accompanying matrix are reviewed and approved every year by our management committee.

SG 04. Identifying incidents occurring within portfolios (Private)