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S-Bank Plc.

PRI reporting framework 2020

Export Public Responses

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.

The basis for our investing is strategic asset allocation. Depending on the clients' investing goals and desired risk level, the allocation is applied according to each customers' needs. We emphasize active products in markets where we believe we can achieve excess return. Passive products are used in combination with active products in some markets. Active allocation and position taking in the underlying products are dynamic processes and deviations from strategic allocation and benchmark are based on different issues on different time horizons.  Issues can be related to megatrends, economic cycles, central bank policies or company specific issues that can be related to financial or sustainable issues that will later turn into financial issues etc.

We believe that automatisation, artificial intelligence, urbanisation, population ageing, transformation into low carbon society and other sustainability related issues will be crucial issues shaping the investing landscape going forward.

We believe that incorporating ESC factors in the investment decision making process alongside with financial factors will enhance portfolio performance and reduce risk in the long run. We have reached the level in sustainable investing where we don't make a distinction between 'investing' and 'sustainable investing' any longer. 

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

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

As a part of our investment process, we evaluate the climate related risks of each of the potential investments. The framework is centered around two possible climate scenarios: 1) global warming of two degrees and 2) four degrees Celsius by 2100, respectively. In assessing the two-degree-scenario we focus on identifying and, up to certain level, quantifying transition risks and opportunities, emphasis being on the risks. In assessing the four-degree-scenario, we focus on identifying and quantifying (when possible) physical risks and opportunities brought on by the changing climate, emphasis of the analysis being once again on the risks.

The analysis is based mostly on our previous knowledge of the industry, opinions presented by trusted experts, material provided by the company and discussions with company representatives.  

Special emphasis is laid on analyzing the preparedness of the company for both of our scenarios. We probe the awareness and prioritizing on the board level, quality and depth of reporting on climate risks as well as actual or planned measures for mitigating those risks.

The outcome of our analysis serve as an input for our investment decision process and helps us better contextualize the valuation of the company.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe the associated timescales linked to these risks and opportunities.

The horizon of our analysis spans 10-15 years.

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.


We have trained portfolio managers to use TCFD framework in analysing companies' climate related risks and opportunities. We have adopted an exclusion policy that covers all our internally managed assets. Coal exclusion is currently the core element in managing climate related risks at FIM. We have also planned to make exclusion criterias stricter going forward. Also, our strategy is to introduce more products that have climate risks and opportunities in the core of the investment strategy. By doing this, the proportion of climate aware AUM will increase. All this will be on the top of existing climate consideration in analysing and making investment decisions on a portfolio management level.

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.


          We provide those clients that are interested a carbon footprint for their portfolios. Also, for the public funds we disclose carbon footprints publicly.

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 two conflict of interest prevention policies on a S-Bank Group (parent entity of FIM Asset Management) level: the general policy and the complementary policy for offering investment services.

The general policy addresses the following issues:

1. Identifying and disclosing conflicts of interests
2. Managing Conflicts of interests
3. Organizational arrangements
4. Secondary external roles of management and personnel members
5. Gifts and hospitality
6. Personal trading
7. Renumeration
8. Training activities
9. Specific rules regarding offering of investment services
10. Roles and responsibilities
11. Documentation and monitoring

The complementary policy for offering investment services identifies the following specific areas of possible conflicts of interest:

1. Brokerage services
2. Discretionary asset management
3. Mutual fund management
4. Offering custody services
5. Offering advisory services

The complimentary policy specifically defines management of conflicts and segregation of duties when offering discretionary asset management, mutual investment funds and proprietary trading activities.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

We follow ESG controversies that occur in portfolio companies. We use an external service provider to highlight controversies and their severity. Our ESG / responsible investing policy describes the process and options we have in place should those incidents happen.