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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.

As a first step, the Siparex Group (hereafter SIPAREX) has commited in 1999 to taking into account ESG criteria through an ethic clause within shareholders agreement. Today Siparex’s ESG initiatives gathers: i) an RI Charter, drawn up in 2012 and available on its website, ii) commitment to UN PRI in march 2014, iii) commitment to France Invest RI charter and gender parity charter, iv) dedicated governance, team and toolbox.

The integration of ESG issues in our investment processes takes the form of: i) the ESG assessment of investment targets, which includes exclusion criteria, integration of a generic ESG assessment framework for investment targets into our Memos, and the presence of an ESG clauses in the shareholder Agreement; ii) working or encouraging our portfolio companies to work on an “ESG & Impacts” roadmap, promoting progress approach and extra-financial impacts.

Siparex also provide its portfolio companies with external experts and a web platform dedicated to annual ESG reporting (Reporting21). Then Siparex leverage on the data gathered through an annual ESG report, mapping portfolio compagnies ESG strength and weaknesses, which is delivered to LPs as to managers of portfolio companies in order to follow their ESG & Impacts roadmap.

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 investment policy refrain from taking any equity interest in companies whose primary and direct business is in the defense or tobacco sectors, or which engage in activities that are harmful to the environment. We commit to take ESG issues into consideration within our investment process. We commit to promote ESG and Impacts best practices and progress approach. We commit to define or encourage our portfolio companies to define and accomplish / execute an ESG & Impacts roadmap for our ownership life.

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 Group has been equiped with a Procedures Handbook since 2003, which has been regularly updated since then and covers as governs subjects including conflicts of interest, investment procedures and risk management.

Each fund has a Supervisory Committee specifically composed of subscribers representing over 8% of subscriptions, responsible for monitoring the operational and financial management as well as the ethical compliance of transactions.

Each fund has an Advisory Committee specifically composed of between 5 and 8 members representing major investors (over 5% of the total subscription amount) and/or strategic investors invited to participate by the Management Company. This Committee will be consulted as required, notably for any proposal the Management Company may submit to it, specifically including potential or existing conflicts of interests identified by the Management Company. The Committee’s decisions will not bind the Management Company except in the case of conflicts of interest or where expressly provided for by the Regulations. The Advisory Committee will take decisions based on a simple majority vote by its members.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)