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Eurobank Asset Management M.F.M.C.,

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.

Eurobank Asset Management MFMC aims to have an impact through its investments without excluding sectors and investments.  Our belief is that the practice of exclusions and negative screenings does not contribute to the improvement of corporate practices and the evolution of activities that condone to a fight against climate change, a more equal society and a better corporate world.  Thus, Eurobank Asset Management MFMC actively seeks sectors and investments with positive impact on ESG issues.  Overall, Eurobank Asset Management MFMC acknowledges the importance of responsibility, sustainability and ESG-related risks and opportunities due to the responsibility and sustainability strategy of the Group in which it belongs, its active participation in renowned ESG organizations, the evolution and stable growth of the ESG investment market, the turn of the investment industry towards new ESG investment products to meet the increasing demand primarily from institutional investors and progressively from retail investors, the new EU regulation on the whole spectrum of sustainability (Sustainable Finance Action Plan, Green Bond Standards, EU Taxonomy, Sustainable Investments Disclosure Rules, ESG benchmarks) and the competitive performance of ESG incorporating strategies on the medium to long term versus traditional approaches to investment which focus only on profit maximisation.

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]

At Eurobank Asset Management MFMC we started gradually incorporating ESG factors in our investment strategy since the fall of 2018 with the aim to (i) align with the widespread sustainability and ESG investment market treds, meet regulatory requirements of the European Insurance and Occupational Pensions Authority, create and maximize shared value, develop expertise in exhibiting outstading performance with new ESG strategies, promote responsibility and accountability in our industry, apply transparent policies of asset management, promote sound corporate governmance and socially responsible corporate culture, establish processes on environment, natural resources, human rights and social engagement, apply the new EU Regulation on Sustainable Investment Disclosure Rules and be one of the pioneers in the industry in Greece and in the wider region of Southeastern Europe where the Eurobank Group maintains presence.

Regarding the incorporation of ESG factors in our investment decision making process and as we can only be proactive through security selection in our own country and in the countries of the wider region of Southeastern Europe that most of the companies we invest in have a presence, we tend to opt for factors that are most relevant for the region.  In this respect, in the Environmental section, we do focus on energy efficiency and renewable sources of energy that are very crucial in our country that has been heavily and persistently relying on fossil fuels, in water scarcity and efficient use of water due to the inefficiencies related to obsolete water infrastucture, in waste management and waste disposal that has not been seriousy addressed up to recent days, in recycling that has not been addressed rendering our economy a non-cyclical economy and in the protection of biodiversity.  In the Society section, we do focus on the equality issues in the use of human capital, in the importance of education and skill development and in the provision of occupational/company retirement schemes to complement the staggering first pillar of pensions.  In the Governance section we are particularly sensitive based on our belief that efficient corporate governance is the cornerstone and prerequisite of financial performance.  In this context, we do recognize the active role that we could play in the area of mid-cap companies of our wider region that traditionall lack sound corporate governance indicating high risks in business continuity and integrity.

Our true belief both as a corporation and as an investment manager relies on the 17th SDG "Partnership for Goals" which encapsulates the philosophy that also permeates our investment policy and the investment strategy that we apply avoiding negative screening and exclusions and opting for positive screening, norms based screening and reliance on scoring data offered by specialist houses for our global holdings whilst also engaging in constructive engagement and interaction with the management of companies of our region in which we select to invest. 


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 below is an indicative, but non-comprehensive list of circumstances in which conflict of interests may arise during the provision of investment services, as identified by Eurobank Asset Management MFMC:

The company may not inform its clients of potential risks related to an investment or to the transaction costs of such investment, giving priority to the company's interests rather than to those of its clients.

The company, during the provision of advisory or discretionary investment services, may give priority to the selection of investment products of its own issuance or investment products for which it has own interest, in order to maximize or sustain existing profit.The company may also choose to manage specific types of portfolios in order to receive higher management fees and/or commissions related to the performance of such portfolios, whereas priority should be attributed to the investment needs of its clients and to the efficient management of their funds, taking into account the investment risks the clients can tolerate.

The company may be a buyer/seller for its own account and at the same time it may also be a buyer/seller for the account of its clients, thus executing different or contrary transactions. 

Continued below.

03.3. Additional information. [Optional]

The company may act as representative for more than one clients simultaneously and execute transactions in financial instruments for different clients, whereby it maynot charge the same fees or commissions or any other financial benefits to all clients.

The company or the Group may provide lead manager and public offering services to the issuer of a financial instrument and at the same time the company or the Group may proceed with the extension of loans to the issuer of such financial instrument or participate in such issuer's share capital

The company or the Group may provide lead manager services or advisory services for the public offering or the placement of financial instruments with or without guarantees and at the same time also provide portfolio management services to the issuing companies-clients, or participate in the pre-marketing of such initial public offering, or publish analysis for the offered for listing financial instruments or provide research for the issuing company.

During the provision of discretionary portfolio management services, the decisions related to the management of the portfolio of a specific client may adversely affect another client or it may give priority to the execution of transactions for some of its clients adversely affecting other clients

The company or the Group may offer lead manager or advisory for listing services simultaneously to two companies-clients, which may be operating in the same sector but may be competitors (this applies to cases of companies' mergers or acquisitions).

The Directors of the company or the Group (shareholders with stakes of over 5%, members of the Board of Directors, employees, co-operating entities or individuals, et. al.) may be accepting gifts of considerable value or fees or commissions other than the pre-defined and pre-agreed remuneration packages for their services, and which could be considered as means of special treatment of one client adversely affecting other clients.

The Directors of the company or the Group may acquire stakes or be involved in business activities or maintain personal relationships with a client that could potentially adversely affect other clients or they may act as representatives of clients for their investment accounts in order to execute brokerage transactions in order to ensure higher profits for some clients versus other clients.

The Directors of the company or the Group may participate simultaneously or sequentially in the provision of investment or investment-related services and in general in investment activities that may prove contrary to conflict of interests' management.

The Directors of the company or the Group that hold privileged information regarding financial instruments may engage in transactions in such instruments for their own benefit taking advantage of the information they have access to due to their professional activities or may use such privileged information for the benefit of one client adversely affecting other clients.

A financial analyst of the company or the Group may produce analysis- whether for external or internal use only - on the financial instruments issued by a specific company in which the financial analyst or an affiliated with him person may hold a stake equal to or more than 5% of the share capital of the issuing company.

The Directors of the company or the Group that are involved in Sales and Distribution, may receive further remuneration or may be offered special commissions for the promotion of specific investment services or the promotion of specific investment products.

The company or the Group may be receiving retrocessions for the sale of instruments (indicatively, sales commissions by issuers of financial instruments or sales commissions by co-operating mutual fund management companies or by co-operating stock brokerage companies).

The company or the Group may be promoting the distribution of financial instruments of a specific issuer whereas at the same time the company or the Group may be holding information (not publicly available) regarding the issuer due to the extension of loan facilities or to the provision of advisory services by another company of the Group to the specific issuer.

The company or the Group may be paying commissions or retainer fees to third parties for their inducement or intermediation for transactions in financial instruments without specifying the specific transaction.

SG 04. Identifying incidents occurring within portfolios (Private)