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Gresham House plc

PRI reporting framework 2020

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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.

Gresham House recognises that the integration of ESG/Sustainable Investing considerations into its business processes can have a positive impact on financial performance and consistency of returns.

Our business mission is to deliver strong, consistent financial performance in alternative investments and align ourselves to our clients and shareholders’ long-term objectives. To this end, we have developed an overarching Sustainable Investment Policy which outlines our definition of sustainable investing and commitments to ESG practices and integration across our entire investment portfolio.

Our definition of Sustainable Investment is as follows;

“Investment that proactively manages a full range of risks and seeks to make a positive social, economic or environmental impact whilst delivering strong financial returns.”

We believe our commitment to integrating sustainable investment practices across our strategies has a clear fit with making an active contribution to the sustainability agenda at a global, local and asset level over the long term. Please see the full list of Gresham's investment principles to sustainable investing in our response to SG 01.5, along with the actions taken this year to develop our Sustainable Investing proposition. 

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]

We recognise that sustainable investment drivers differ across asset classes and in response we have worked with an external ESG consultant to develop asset class specific policies and frameworks across all our investment divisions. Alongside these policies we have developed ESG management tools and associated KPIs that will help our investment teams identify potential  sustainability risks and opportunities in a consistent manner. These tools and associated KPIs will provide important monitoring of the sustainability performance of underlying investments enabling us to provide transparent and measurable reporting to our clients from 2020 and beyond. All sustainability related information is made available internally, so employees can further their understanding and meet internal performance appraisal objectives.

 Gresham’s commitments to sustainable investing are outlined below:

  1. Take steps to consult and understand the views, concerns and ambitions of our stakeholders in seeking sustainable outcomes from the investments we are involved in.
  2. Integrate Environmental, Governance, Social and Economic benefit considerations into our selection, evaluation, governance and engagement processes across the lifecycle of each investment. We drive rigour and consistency in this by applying our sustainable investment framework and system, including clearly defined processes and expert tools and methods.
  3. Ensure our team understands the imperative for effective ESG management and is empowered and equipped to carry this out through management support and training.
  4. Conduct regular monitoring of ESG risks, opportunities and performance in our investments and over time, reporting to our investors.
  5. Conduct our business activities in line with the UN-supported Principles for Responsible Investment, including an annual report of our progress towards implementation.

01.6. Additional information [Optional].

          Our Sustainable Investment commitments within our policy are:
1. We take steps to consult and understand the views, concerns and ambitions of our stakeholders in seeking sustainable outcomes from the investments we are involved in;
2. We integrate Environmental, Governance, Social and Economic benefit considerations into our selection, evaluation, governance and engagement processes across the life cycle of each investment; 
3. We drive rigour and consistency in this by applying our sustainable investment framework and system, including clearly defined processes and expert tools and methods;
4. We ensure our team understands the imperative for effective ESG management and is empowered and equipped to carry this out through management support and training; 
5. We conduct regular monitoring of ESG risks, opportunities and performance in our investments and over time will , reporting to our investors; 
6. We. conduct our business activities in line with the UN-supported Principles for Responsible Investment, including an annual report of our progress towards implementation.
        

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].

The elements highlighted are all addressed in our overarching Gresham House Sustainable Investing Policy document. 


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.

Gresham House has a Conflicts of Interest Policy which must be followed by all members of staff. As part of the policy, the firm has set up a Conflicts Committee to review any potential conflicts and controls that may be required to mitigate a potential conflict. Gresham House is committed to identifying, monitoring and managing all actual and potential Conflicts of Interest that can arise, between the firm and our clients, or between clients of different areas of the Group.

To manage Conflicts of Interest, we maintain a Conflicts Register that is reviewed by the Gresham House Asset Management Board. The purpose of the register is to record and maintain a list of all actual and potential types of conflicts which may cause or create a perceived risk of damage to the interests of a client. The register also sets out measures Gresham House has taken to manage such actual or potential conflicts. The operational basis of Gresham House's arrangements for reviewing and monitoring its conflicts management processes is subject to regular ongoing review by Senior Management.

Continued under SG 03.3 "Additional Information"

03.3. Additional information. [Optional]

Uses of our Conflicts Register:

The register includes identified conflicts, specifies the procedures to be followed and measures to be adopted with a view to preventing the conflict of interest from constituting or giving rise to a material risk of damage to the interests of Gresham House's clients. Where the arrangements and measures implemented are not sufficient to mitigate the risk of disadvantage to existing or potential clients, the nature of the Conflict is disclosed to them prior to undertaking business. Note that, an over-reliance on disclosure without adequate consideration as to how conflicts may appropriately be managed is not permitted.

At a product level, we have arrangements in place, either though a relevant advisory committee, investment committee or board through which any conflicts will also be noted and / or discussed along with the action plan proposed.

Conflicts Assessment:

As and when new areas of potential Conflicts of Interest are identified, they will be assessed by the Compliance Officer in conjunction with relevant investment or operations members of staff. In each case, a judgement will be made as to:

  • ​Whether existing control mechanisms are sufficient to mitigate the conflict identified;
  • Whether new/additional controls specific to the identified conflict are required; or
  • Whether the conflict should be disclosed to relevant clients so that they are able to take an informed decision with regards to the service in which the conflict arises​.

SG 04. Identifying incidents occurring within portfolios (Private)


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