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S-Bank Plc.

PRI reporting framework 2020

Export Public Responses

You are in Strategy and Governance » Governance and human resources

Governance and human resources

SG 07. RI roles and responsibilities

07.1. Indicate the internal and/or external roles used by your organisation, and indicate for each whether they have oversight and/or implementation responsibilities for responsible investment.


Select from the below internal roles

07.2. For the roles for which you have RI oversight/accountability or implementation responsibilities, indicate how you execute these responsibilities.

The CIO has the ESG oversight role. He oversights everything that is related to investment processes and investing, including ESG. Some ESG strategies are executed by the CIO, but he mostly oversights responsible investing. Oversighting is done for example by observing daily working of the investment teams and by researching ESG reports of portfolios or mandates to verify that ESG criterias are not breached. The portfolio managers are responsible for the day-to-day implementation of the ESG processes in their respective funds. 



07.3. Indicate the number of dedicated responsible investment staff your organisation has.

1 Number

07.4. Additional information. [Optional]

At FIM ESG is truly put in place by the people who make the investment decisions, ie the fund managers. This is how it should be. Now that a distinct ESG process is in place, the system operates smoothly. Furthermore, the Head of ESG became the CIO in 2019 when the two roles were merged. This highlights the importance of ESG at FIM.

SG 07 CC. Climate-issues roles and responsibilities

07.5 CC. Indicate the roles in the organisation that have oversight, accountability and/or management responsibilities for climate-related issues.

Board members or trustees

Chief Executive Officer (CEO), Chief Investment Officer (CIO), Chief Risk Officer (CRO), Investment Committee

Portfolio managers

Dedicated responsible investment staff

External managers or service providers

07.7 CC. For management-level roles that assess and manage climate-related issues, provide further information on the structure and processes involved.

As we recently combined the CIO and Head of ESG roles, the CIO is now in charge of ESG at FIM.This was due to the importance of responsible investing for FIM. Also, we do not want to make a distinction between 'investing' and 'responsible investing' as our approach is to align these two. When it comes to climate related issues, the CIO suggests to the ESG committee what actions should be taken. The committee then makes the final decisions. Exclusion criterion will be decided upon in the management committee of FIM. For climate related product development, the CIO takes new ideas forward to the management board.

We have excluded coal companies according to certain parameters from our investment universe. Also, our updated ESG policy refers to TCFD. We familiarised portfolio managers more formally with the issue in 2019. These decisions have been taken as described earlier. Portfolio managers do have a good knowledge on climate change and its effects on sectors and companies.

07.8 CC. Indicate how your organisation engages external investment managers and/or service providers on the TCFD recommendations and their implementation.


          We regularly ask service providers to a) develop TCFD related analysis b) integrate that into their analysis and reporting.

SG 08. RI in performance management, reward and/or personal development (Private)