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EFA Group

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy


SG 01. RI policy and coverage


01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類と対象範囲を示してください。


01.3. 投資ポリシーが以下のどの項目をカバーしているか明示して下さい:

01.4. 組織の投資原則および全体の投資戦略、受託者義務(または同等のもの)の解釈、ならびに、ESGファクターおよび実体経済の影響をどのように考慮に入れているかについて説明してください。

EFA has adopted a negative screening strategy to incorporate ESG standards into our investment process and decision making process.This is done through the ESG evaluation questionnaire. The implementation of ESG factors into our portfolio construction and investment strategy helps us to measure the sustainability and ethical impact of our borrowers.

Our approach is to highlight and raise awareness of ESG issues to our portfolio companies. We believe by implementing such a screening and assessment process, we can trickle down the importance of managing ESG concerns and having the right policies and procedures in place to mitigate these risks. Ultimately, we hope that this ripple effect can lead to the development of a more sustainable global financial system. In implementing these factors, EFA Group contributes to the development of a more sustainable global financial system and raise the awareness of ESG standards as a borrowing criteria among SMEs.

EFA’s private debt strategy contributes to a positive social impact, through financing of its borrowers. By funding these SMEs, known as the engines of economic growth, we are supporting jobs creation, increase of productivity, and improvement of living standards. Our strategy impacts real lives of families.

01.5. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。[任意]

We assign an ESG evaluation questionnaire to each borrower during the due diligence process or facility renewal to ensure that they meet our ESG scoring.

10 key criteria have been selected for the environment, social and governance categories based on the industry sustainability impacts. Here are the ESG considerations reviewed during our investment process:


Pollution (contamination of land, water and air)
Climate change mitigation


Working Conditions & Social Protection
Occupational Health & Safety
Employment and Employment Relationships
Economic Impact
Child Labor


Ethics and Integrity
Board of Directors Structure and Remuneration
ESG Issues Consideration

We also abide by the International Finance Corporation’s (IFC) Project Exclusion List for the list of projects that we do not finance. Full list can be found here:

The assessment ensures that the companies in our portfolio abide by the ESG standard that we have in place.

01.6. 補足情報 [任意]


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。



02.2. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。


02.3. 補足情報 [任意]

Our investment strategy and ESG policy are not available on our website or publicly but is provided to prospective investors and investors upon request. 

SG 03. Conflicts of interest

03.1. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

Please refer to the below for our conflict of interest policy.



03.3. 補足情報 [任意]

Article I: Purpose

This conflict of interest policy is designed to foster confidence in the integrity of Eurofin Investments Pte Ltd (the “Company”) and to protect the interest of its clients and key stakeholders against potential conflicts of interest from a director, corporate officer or any key employee (defined below).

Article II: Definitions

Article III: Personal Dealing

1. Reporting and Approval

All employees must seek the approval of the Compliance team at the latest within 1

business day after transacting in any security for personal account or connected party account using the

personal account transaction approval form as indicated in the Compliance Manual. A transaction will not

be approved if its part of the negative list maintained by the Compliance Team. If the transaction is not

approved, the employee will be required to perform reversal on the position.

Employees must submit a copy of the contract note / statement of accounts / email

confirmation or other relevant supporting documents for personal trades to the Compliance team as soon

as the documents have been received.

Article IV: Procedures

1. Duty to Disclose Business Interests Upon Joining the Company

Each insider, upon joining the Company shall disclose to the Board of Directors all

material information regarding his or her business interests, directorship and shareholding in any

corporation, sole proprietorship, partnership or business interest in Singapore or elsewhere.

Material information required includes the name of the corporation, sole proprietorship,

partnership or business interest, place of incorporation/ establishment, nature of the business, extent of

his or her business interest and the date of acquisition of such.

2. Prior Approval on Subsequent Business Interests

All insiders cannot obtain subsequent business interests without the prior written

approval of the Board of Directors who will then evaluate the request based on the procedures set

forth in Article V.

3. Duty to Disclose Upon Cessation

All insiders with business interests shall within 5 business days notify the Board of

Directors of the cessation of any previously declared or approved business interest.

4. Determining Whether a Conflict of Interest Exists

With regard to an insider, the Board shall determine if a conflict of interest exists. The

insider(s) and any other interested person(s) involved with the transaction shall not be present during

the Board’s discussion or determination of whether a conflict of interest exists, except as provided in

Article V below.

5. Procedures for Addressing a Conflict of Interest

The Board shall follow the procedures set forth in Article V in order to decide what

measures are needed to protect the Company’s interests in light of the nature and seriousness of the

conflict, to decide whether to enter into the transaction and, if so, to ensure that the terms of the

transaction are appropriate.

Article V: Review by the Board

The Board may ask questions of and receive presentation(s) from the insider(s) and

any other interested person(s), but shall deliberate and vote on the transaction in their absence. The

Board shall ascertain that all material facts regarding the transaction and the insider’s conflict of interest

have been disclosed to the Board and shall compile appropriate data, such as comparability studies, to

determine fair market value for the transaction.

After exercising due diligence, which may include investigating alternatives that present

no conflict, the Board shall determine whether the transaction is in the Company’s best interest, for its

own benefit, and whether it is fair and reasonable to the Company; the majority of disinterested members

of the Board then in office may approve the transaction.

Article VI: Records of Proceedings

The minutes of any meeting of the Board pursuant to this policy shall contain the name

of each insider who disclosed or was otherwise determined to have an interest in a transaction; the

nature of the interest and whether it was determined to constitute a conflict of interest; any alternative

transactions considered; the members of the Board who were present during the deliberations on the

transaction, those who voted on it, and to what extent interested persons were excluded from the

deliberations; any comparability data or other information obtained and relied upon by the Board and

how the information was obtained; and the result of the vote, including, if applicable, the terms of the

transaction that was approved and the date it was approved.

Article VII: Annual Disclosure and Compliance Statements

attached, that:

Each employee of the Company, shall annually sign a statement on the form

• affirms that the person has received a copy of this conflict of interest policy, has read

and understood the policy, and has agreed to comply with the policy; and

• discloses the person’s business interests and family relationships that could give

rise to conflicts of interest.

Article VIII: Violations

If the Board has reasonable cause to believe that an insider of the Company has

failed to disclose actual or possible conflicts of interest, including those arising from a transaction with

a related interested person, it shall inform such insider of the basis for this belief and afford the insider

an opportunity to explain the alleged failure to disclose. If, after hearing the insider’s response and

making further investigation as warranted by the circumstances, the Board determines that the insider

has failed to disclose an actual or possible conflict of interest, the Board shall take appropriate disciplinary

and corrective action.

Article IX: Annual Reviews

To ensure that the Company operates in a manner consistent with its status under the

relevant regulatory bodies including the Monetary Authority of Singapore, the Board shall authorize and

oversee an annual review of the administration of this conflict of interest policy. The review may be

written or oral. The review shall consider the level of compliance with the policy, the continuing suitability

of the policy, and whether the policy should be modified and improved.

SG 04. Identifying incidents occurring within portfolios (Private)