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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.

Coeli’s investment philosophy is to generate positive return for our customers using a long-term perspective. Our fund managers use a high conviction approach, hence we only invest in what we truly believe in. This way, we aim to exceed market index and create value in our customers’ investment portfolios.

Responsible investments play an important role in the investment process and we encourage companies to be a signatory of UN Global Compact and follow OECD's guidelines for multinational companies.

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]

Our ambition is to invest in companies that are proactive in the environmental, social and governance issues. This means that we do not invest in companies that are violating the international norms and where a dialogue has not lead to the desired result. Coeli does under no circumstances invest in companies that are involved in production or sales of illegal weapons, such as cluster munitions and anti-personal mines, or nuclear weapons. We expect that the companies we invest in apply to international norms and conventions. If a company violates these norms and conventions Coeli initiates a dialogue with the concerned company to achieve changes in management and behaviour. If a dialogue does not lead to desired impact Coeli will sell its holding in the company.

01.6. Additional information [Optional].


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].

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.

Coeli's management team must work actively to continuously identify, monitor and manage any conflicts of interest that may arise in the business.

Employees shall immediately inform their immediate superior or the Compliance function of situations where any conflicts of interest have been identified or may arise.

Identified existing and potential conflicts of interest should be documented in a special log that is administered by the Compliance function. The documentation must contain information on how the conflict of interest is handled.

In particular, Coeli shall assess the existence of any conflicts of interest associated with the following situations:
▪ When developing new or substantially changing products and services
▪ When entering into new contract agreements
▪ When entering into agreements with new counterparties for portfolio transactions in the funds
▪ In case of other material changes to the business, such as acquisitions or mergers of companies, recruitment of board members, etc.

The above situations should always be considered in connection with the annual audit of the guidelines.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)