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Lofoten Asset Management

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.

  • Our overall investment strategy is to invest in superior quality business models with a focus on visibility, sustainable margins and high returns on invested capital. We follow a fundamental, bottom-up stock picking approach looking for companies trading at a discount to intrinsic value.
  • We integrate ESG considerations into our investment process in line with our commitments under the UNPRI. On initial review of a stock, we check the ESG risk rating provided by Sustainalytics, as well as key ESG controversies and incorporate this analysis with our traditional fundamental analysis. 
  • We run a concentrated portfolio focused on high quality names and thus we can be very selective as to how we invest. 
  • Once past the initial hurdles, we will spend more time on areas of concern, using our judgement and experience as to what is material, and may not invest if we consider the ESG risks to be too high, just as we may not invest if we believe the valuation to be an impediment or market forecasts to be too high. 
  • We also maintain an active dialogue with company management on many areas including ESG issues.  

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 (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.

The firm is committed to ensuring that it takes all reasonable steps in its arrangements for managing any conflicts of interest that may arise during the course of carrying out any regulated or ancillary activities for its clients and that these are appropriate and comprehensive, given the nature, size and complexity of the firm, and that arrangements are fully integrated into the operational and ethical framework of the firm. It is the responsibility of the firm’s employees to comply fully with the firm’s policies, procedures and guidelines and to bring to the attention of the firm’s Senior Management any concerns they may have. The firm will:

▪ manage all conflicts of interest that could have a detrimental effect on its’ clients, in particular where there is a prospect of financial gain or avoidance of financial loss 

▪ take all reasonable steps to identify conflicts of interest 

▪ maintain effective organisational and administrative arrangements with a view to taking reasonable steps designed to prevent conflicts of interest 

▪ disclose the nature and/or the specific sources of conflict with the interests

▪ maintain and implement an effective policy 

▪ keep record of the activities performed in which a conflict has/or may arise

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)