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Sound Shore Management, Inc.

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.

Sound Shore’s experience has been that high standards of corporate responsibility including good business practices, transparency and accountability, reflect good business sense and are directly related to long term investment outperformance. Our fundamental company research includes active engagement with management.  Before owning a stock, we generally meet with management directly.  Additionally, we conduct cross-checks with suppliers, competitors, clients, and other relevant primary sources.  We have approximately 600 management meetings annually.

Criteria we evaluate to assess risk include:

  • Operating performance
  • Rigor in capital expenditure budgeting and allocation
  • Compensation practices
  • Director accountability
  • Climate and environmental risks and changes
  • Social factors and changes
  • Focus on total shareholder return versus appropriate market benchmarks
  • Free cash flow per share and shareholder yield (dividends plus share repurchase)
  • Time allocated to non-core activities
  • Other company specific responsible investing factors

As long-term investors of our clients’ capital, we view active ownership as our fiduciary responsibility.  Our company-specific due diligence process includes financial statement analysis, focusing on risks and liabilities, including ESG considerations.  Sound Shore discusses material items with management, providing remediation input.  Our target valuations for stocks will include estimate for these factors if relevant. We also utilize external sources such as Bloomberg ESG data.

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.

As set forth in Sound Shore’s Code of Ethics, employees are required to put client interests ahead of personal interests and avoid any actual or potential conflicts of interest.  Any potential conflict must be discussed with the Sound Shore’s Chief Compliance Officer who is responsible for ensuring that there are no conflict of interest issues and that the activity is deemed to be beneficial to or at least not detrimental to Sound Shore’s clients.  Employees sign annual certifications that they have no undisclosed conflicts of interest.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)