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Santander Pensiones, Entidad Gestora de Fondos de Pensiones, S.A. (Delisted)

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.

In 2019 we have developed a Global SRI Policy applicable to all Santander Asset Management’s AuM, which include asset managed by Santander Pensiones. This policy is the general framework defining SAM’s SRI approach and criteria considered for integrating ESG variables in the investment process.  This policy is currently following the internal approval processes and will be publicly available in 2020.

This policy recognizes SAM has the fiduciary duty to always act in the long-term interest of its clients. In order to fulfil this duty, it is necessary to consider the financial aspects together with the extra-financial ones in order to have a more complete vision of the assets under management, which often results in better-informed investment decisions.

The policy defines SAM’s ESG assessment, which takes into account different components:

  • A valuation analysis (details in next comment box SG 01.5)
  • Exclusions (details in next comment box SG 01.5)

The policy also includes a reference to SAM’s governance related to SRI. The governance mechanism is mainly composed of different bodies, such as the SRI governance committee, the Investment and Sustainability Committees and the SRI team, among others.

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]


The SRI policy defines SAM’s ESG assessment, which takes into account different components:

  • A valuation analysis where the behaviour of issuers is assessed in relation to different environmental, social and governance factors. For this assessment, SAM uses the information provided by external data providers, incorporating it into its own valuation methodology. This methodology is designed by the SAM SRI team and based on market references and the main international frameworks and standards resulting in an ESG rating of each issuer.
  • Exclusions based on the nature of the activities carried out by the issuers or on the identification of risks through the monitoring of possible controversial news. The exclusions are based on the policies of Santander Group, which apply to different sensitive sectors. In addition, other exclusions are applied for non-compliance with regulations or are related to specific SRI products conditions.

The ESG assessment of companies is composed of general analysis criteria - common to all sectors - and specific criteria - depending on the sector and activity - covering all relevant ESG aspects related to the essential thematic areas for an environmental, social and good governance analysis (e.g. Climate change, Natural resources, Human Capital, Labour Rights, Corporate Governance, Business Ethics, etc.)

In addition, for the analysis of governments, SAM uses ESG criteria adapted to the characteristics of each country (e.g. Climate change, Natural capital, Education, Health & Nutrition, Civil Rights, etc.)

In the case of third-party funds, and when possible due to information availability, SAM conducts an ESG analysis in order to assess their alignment with SAM’s SRI approach.

01.6. Additional information [Optional].

          In addition, we have also developed an engagement policy which set the principles followed by SAM in relation to engagement activities with investees or companies where SAM has an interest, both on an individual basis or through collective engagement initiatives. This policy has been developed in 2019, and, even though it would be formally approved in 2020, engagement activities has already been started, following the approach set in the policy.
Our policies also includes a reference to transparency and reporting. SAM strictly monitors and complies with reporting requirements legally required in each jurisdiction and with the requirements derived from adhering to voluntary initiatives or standards.

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].

Our policies are not already publicly available but we will disclose these documents in 2020.

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.

All of the activities under the Santander Group (that includes Santander Asset Management and therefore Santander Pensiones) are held liable under the Group´s Policy on Conflict of Interests. This policy covers:

Subjective Scope
Objective Scope
General Responsibilities of Compliance Management
Specific Actions
Disclosure of Conflict of Interests to Clients
Register of Conflict of Interests

This policy is available here:

In addition, Conflict of Interest is also included in Santander Group Code of Conduct which is public here:

Santander Asset Management, which include asset managed by Santander Pensiones, has its own conflict of interest policy and procedures in place to manage potential conflicts in a way that protects the interests of its clients. When potential conflicts are identified, SAM commits to manage them in a fair and effective manner to prevent these from harming the interests of our clients.

This policy is available here:

Conflict of interest is a topic that has been also included in the engagement policy develop in 2019 and that will be publicly available in 2020.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)