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PRI reporting framework 2020

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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。

          Green, social & sustainability bonds policy

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。

It is the mission of ACTIAM to offer relevant investment solutions where we maximize financial, social and environmental returns. We see it as our duty to play a leading role in the transition necessary to achieve a sustainable society. The starting point of our investments is ethical: we do not want to invest in companies that violate our Fundamental Investment Principles. These principles are based on international treaties and best practices. Companies in violation exhibit unacceptable behaviour and are excluded from investment​. In addition to these ethical principles, ACTIAM aims to stimulate companies to operate within the planet’s 'safe and just operating space’, where companies operate within the planetary boundaries and respect the social foundations. For this, ACTIAM assesses to what extent companies have the capacity to prepare for the ongoing transitions and whether a lack of adaptiveness creates risks for our portfolios. Targets have been set for the themes climate, water and land and it is assessed to what extent companies follow the necessary, ‘science-based’ pathways to move towards ‘safe and just operating space’. With these objectives ACTIAM wants to invest within the planetary boundaries and in line with the SDGs. For more information, please see next item SG01.5

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]

The starting point of investing at ACTIAM is ethical and written down in our Fundamental Investment Principles (FIP). We do not want to invest - from an ethical perspective - in companies that violate our FIP. The principles are based on international treaties and best practices and cover the following subjects: Human rights, Labour rights, Corruption and fraud, Environment, Weapons, Customer and Product integrity, and Animal welfare.
In addition, ACTIAM’s investment policy stimulates companies to operate within the ‘planet’s safe and just operating space for humanity’, which means operating within the planetary boundaries and respectful of the social foundations. As our Fundamental Material Drivers policy describes in-depth, ACTIAM assesses to what extent companies have the capacity to prepare for the ongoing transitions in society and how a lack of adaptive capacity creates risks for our portfolio. We analyze if and how companies follow the necessary, ‘science-based’ pathways to move towards the ‘safe and just operating space’.

ACTIAM assesses companies through the lens of seven material business drivers: fossil fuel use, water use, land use, chemicals use, social capital management, human capital management and organisational behaviour. Based on this assessment, companies are categorised according to their capacity for behaviour change, indicating they are deemed non-adaptive, at-risk or moving towards sustainable behaviour. Their categorisation determines in which types of funds companies fit.

In addition, for climate, water and land, long-term and 'science-based' targets have been formulated. These are: 1. Climate: 30% less CO2 emissions in 2030 (compared to 2010), in line with the climate agreement of Paris; 2. Water: water-neutral investment portfolios in 2030 3. Land: no deforestation and no loss of biodiversity in 2030. With these objectives, ACTIAM aims to ultimately invest within the planetary boundaries and in line with the Sustainable Developments Goals (SDGs).

To achieve these objectives, we use different instruments. The first is exclusion from our investment universe. We are aware that excluding a company has no impact on the real world and the real economy. Investing only in the companies that do good ultimately does not lead to a sustainable society, and as described in our vision: a transition is needed. The majority of companies will also have to be encouraged to change their behaviour towards the best practices. We do this via engagements, entering into a dialogue with companies and aiming for concrete objectives that entail a change in behaviour. We make a distinction between responsive and proactive engagement. The first aims to respond to (potential) controversies or violations of our Fundamental Investment Principles. When responsive engagements are not successful within a reasonable timeframe, the next step is to exclude the company. For some of our strategies, responsively engaged companies are not investable.

The third option is to vote at shareholders' meetings. In addition to casting our vote, we also actively file for items on the agenda. The fourth option is to invest extra in companies that operate sustainably or in companies with a positive impact. For example, ACTIAM has a range of sustainable products including only the companies that already operate sustainably and are preparing, for example, for the low-carbon transition. ACTIAM also has a global equity impact fund that only invests in companies that demonstrably contribute to the SDGs. Additionally, in our Credits fund (corporate bonds), we strive to invest as much as possible in Green Bonds.

Finally, we look at financially material sustainability issues per company and per sector. Here, we look at ethical components, top-down policy based on climate, water and land and bottom up or company-specific relevant sustainability topics. This research is reflected in the ACTIAM ESG score. This score looks at the company specifically, the climate, water and land focus themes and the positive contribution to the SDGs. On the basis of these three steps, a score is given per company between 0 and 100. The higher the score, the more sustainable (also from a financially-material perspective) the company. For some of our strategies, we have a minimum ESG score. For all investments, the average ESG score should be at least as high as the relevant benchmark.

The responsible investment policy is drafted by the in-house ESG team (9 FTE and 2 interns on average). All policies and exclusion decisions need to pass by the ACTIAM ESG Committee, which consists of the CEO (performing the role of Chair), CIO, Head of Fund Management and Head of ESG Research and an external expert who is also a Professor of Ethics. This committee meets at least once every quarter. The policies are reviewed and updated on a regular basis.

Several instruments used in our investment universe, such as Green Bonds and the ACTIAM ESG Score, are developed and applied in collaboration between Portfolio Management and the ESG team. Therefore, we meet on a regular basis and continuously discuss content and developments.

01.6. 補足情報 [任意]

          For more information, see

SG 01 CC. Climate risk

01.6 CC. 投資期間において特定され、組織の投資戦略・商品に組み込まれている気候関連のリスクおよび機会について記述してください。

特定された気候関連の移行リスク・物理的リスクおよび機会、ならびに投資戦略・商品にそれらがどのように組み込まれているかを説明してください。(500 語以内で自由に記載)

ACTIAM has taken several important steps to reduce climate-related risks over the past years. Both transition risks and physical risks are addressed:

·       Transition risks: ACTIAM developed an energy transition policy in 2014 that addressed carbon intensive sources of energy. This was recently upgraded with the latest policy update in 2019. Currently, companies with expansion plans for coal-fired power plants  above a certain threshold are excluded, as well as those earning a substantial part of their revenues from thermal coal related activities. In addition, companies with a insufficient 'low-carbon-transition score', lacking the management capacities to make the transition, are either classified as non-adaptive and therefore excluded from investment, or classified as at-risk and therefore not part of our sustainable and impact product ranges. This implies that energy intensive companies that are not in the process of decreasing this intensity or moving towards renewable energy sources are not part of our investable universe or are engaged. The same applies for companies with substantial revenues from unconventional oil & gas activities (shale oil & gas, tar sands, arctic drilling, deep water drilling) that do not demonstrate to have the capacities and plans to move to more renewable energy sources. Responsive engagement can lead to exclusion if there is insufficient progress. The decision to exclude companies based on this policy has been made multiple times during the last years. At the same time, extensive (proactive) engagement is conducted with companies that face transition risks. ACTIAM has also set a goal of reducing the carbon footprint of its investments by 30% in 2030 -compared to 2010- in order to minimize climate-related risks.

·       Physical risks: many companies face both transition and physical risks. Companies flagged for extreme physical risks may be excluded from our sustainable index ranges as they create unacceptable risks to our portfolios.  Physical risks are part of our dialogue with companies. It is also an important element of ACTIAM's focus on water. ACTIAM has a "water neutral portfolio" target for 2030. In order to achieve this, companies need to demonstrate long-term planning and scenario analyses.

Both transition and physical risks are also addressed through the integration of ESG scores in the investment process.

Investment in companies with climate-related opportunities and green bonds is stimulated by an increase in their ESG score. The majority of these are opportunities relating to resource efficiency, energy sources, and products and services.

01.7 CC. 組織はそれら気候リスクの可能性および影響を評価しましたか?


ACTIAM is currently working on a scenario analysis for climate related transition and physical risks. For  a number of climate scenarios, the likelihood and impacts of climate risks on our portfolios are being evaluated. ACTIAM does already integrate transition and physical risks on the company level (of ours investees) (see SG 01.6CC). As a result, a large part of the climate risk is already addresed in our portfolios. With the scenario analysis, we are pursuing more detailed insights into the direct and indirect effects of climate change on the different sectors and how impacts on vulnerable sectors may trickle down to other economic sectors. In addition, in line with requirements from the Dutch Central Bank, a stress test has been performed, analyzing the impact of shocks in vulnerable sectors on our portfolios.

01.8 CC. 組織はTCFDを公式に支持しますか?

01.9 CC. 重大な気候関連リスクおよび機会を特定・管理する組織全体の戦略がありますか?


As integral part of our sustainability policy, ACTIAM evaluates the material risks and opportunities of companies, including the material climate related risks and opportunities. For the factors that are considered material by SASB, MSCI or our proprietary evaluations, it is evaluated how exposed companies are to these risks and how well they manage these risks. For each company, it is indicated whether they sufficiently manage these risks and mitigate them. For this, we look at their policies, certifications and performance on these topics. If their management is below our thresholds, companies are considered to create risks for our portfolios and may therefore be excluded from investment or engaged to stimulate companies to improve their management, if potential for behaviour change is found. In addition, companies that provide solutions to these risks and therefore have opportunities to benefit from the changing market circumstances are positively selected.

1.10 CC. TCFD開示を発表するために組織が使用する文書/通信を示してください。

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。












          Green, social & sustainability bonds policy

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]

All companies are assessed not only according to our Fundamental Investment Principles (, but also according to their performance under the ACTIAM's Fundamental Material Drivers (

Both documents form the full ACTIAM screening, integration and exclusion criteria and procedures.

ACTIAM strives for providing more sustainable solutions, pursued by our clients, as stated in our Sustainable Investment Policy. For an example, see one of our clients' page on how ACTIAM contributes to their ESG investment goals:

More information, policies and procedures can be found on our website:

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。

There is a company wide policy on conflicts of interest. The goal of this policy is to limit the possibility of any potential conflict of interest and respond properly if a conflict of interest does occur. Compliance with the policy is monitored by the responsible management of a business unit and an independent compliance officer. Besides that an internal audit committee provides an independent assessment on the overall effectiveness of the control measures of all business units.
With respect to conflict of interests regarding exclusions, engagement or voting decisions, ACTIAM has a committee including an external expert that reviews RI policies and exclusion decisions. ACTIAM does not accept mandates of clients that want to invest in entities which are excluded based on the responsible investment policy.

03.3. 補足情報 [任意]

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、投資先企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

Our investment universe is screened at least every quarter. Please see the compliance process with the Fundamental Investment Principles, Fundamental Material Drivers and ACTIAM ESG Committee procedures in other parts of this questionnaire. If any incidents occur during any quarter, this is reflected in the screening results. Depending on the severity of the incident, a proper response will be sought. This could include engagement or exclusion. Next to the regular, quarterly ACTIAM ESG Committee meetings in which such an incident is discussed and decisions are made, we have the possibility to use the a "Fast Track". This means that the ESG department will prepare a case description and proper advice and the request for a decision towards the company in question is sent to the members ACTIAM ESG Committee. Within five working days, a response is given and a decision is made. This can include engagement or exclusion.

Next to this compliance process, we can manage incidents through our ESG scoring methodology. If an incident occurs, the ESG score of the company can be adjusted and/or downgraded. This is not mutually exclusive to the above process. A company’s ESG score can be downgraded while at the same time a responsive engagement is set up. In such cases, the company is excluded from some of our strategies. 

Within the above processes, there is a close collaboration between the ESG department and other relevant departments within ACTIAM. For example, the sector specialist from the Portfolio Management team is involved in the discussions and seeking the appropriate solution for each case. The final advise is given by the ESG department, and the ultimate decision is made by the ACTIAM ESG Committee.