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Carnegie Fonder AB

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.

Carnegie Fonder is an independent fund management company founded in 1988. All our funds are actively managed with the purpose to create financial security for children, pension savers, foundations and institutions. We achieve this through our philosophy of focused value investing.

  • Focused means that the funds are concentrated to a limited number of securities. We do not invest in a company simply because it is included in an index.
  • Value investing means that we invest in well-managed companies that are undervalued. There are lots of good companies, but not all of them are good value. Behind each investment, we conduct a thorough analysis of the business model, finances, sustainability issues and management.

The world is rapidly changing, with megatrends like migration, climate change, scarce resources, shifts in technology and new regulations. By working with sustainability in a structured way, we can identify the companies that are well equipped for the challenges of the future. To that end we have developed a framework for responsible investments consisting of six key resources:

1. Commitments and collaborations

2. Responsible Investment Board

3. Training and incentives

4. Screening and sector exclusion

5. Internal analysis – CF THOR

6. Shareholder engagement

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]

By working with sustainability in a structured way, we can identify the companies that are well equipped for the challenges of the future. To that end we have developed a framework for responsible investments consisting of six key resources:

1. Commitments and collaborations - for instance membership in PRI, UN Global Compact and Swesif and informal collaborations with other investors.

2. Responsible Investment Board - Sets the broad framework and ensures proper implementation of ESG-factors in the management of the funds and serves as a governing body for company engagements.

3. Training and incentives - All portfolio managers, analyst and sales staff are educated on ESG-related issues. The responsibility to incorporate ESG-factors is clearly articulated in all portfolio managers job descriptions and instructions. Furthermore, all portfolio managers have annual goals related to ESG that are linked to variable salary.

4. Screening and sector exclusions - We require all holdings to comply with international norms, such as the UN Global Compact and our funds also exclude certain sectors such as weapons and tobacco production. Holdings are screened prior to investment with ongoing monitoring and bi-annual screenings from an external provider.

5. Internal analysis, CF THOR - Fundamental ESG-analysis incorporating both qualitative and quantitative measures using our proprietary tool, CF THOR. This analysis is performed on all holdings, both bonds and equities and its outputs are integrated in the financial analysis, for instance influencing views on future revenues and costs for investee companies.

6. Shareholder engagement - We are responsible owners which include voting on annual general meetings, serving on board nomination committees and engaging with the investee companies. We distinguish between reactive dialogues which typically happen after we are notified of potential non-compliance with international norms and proactive dialogues to express our opinions and expectations on specific ESG issues, or encourage our holdings to be more structured in their sustanaiblity work and integrate sustainability into all aspects of their business.

01.6. Additional information [Optional].


SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

Our internal ESG-analysis tool, CF THOR, has a section which assesses company-level transition and physical risks and opportunities related to climate, for instance based on sector-specific challenges as well as the company's CDP responses. Certain sectors where, among other risks, the transition risks and the harm to society caused by these sectors has led some of our funds to exclude these sectors from investment. For example fossil fuel producers are excluded in most of our fund range.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe the associated timescales linked to these risks and opportunities.

We attempt to incorporate this risk assessment in the company analysis, the focus is on the long-term, +10y. We have yet to assign a quantitative impact on these risks.

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

Explain the rationale

We welcome the work and recommendations of the TCFD as it guides companies as to how to produce relevant climate change related reporting in a manner that enables the investment community to understand and assess a company's main climate-related risks and opportunities but also facilitates comparison between companies. We actively consider company-specific risks and opportunities associated with climate change (both physical and transitional) in our ESG analysis as part of CF THOR, our own proprietary ESG analysis gramework.

We also encourage our portfolio companies to report according to TCFD recommendations. 

We have not yet taken a decision to publicly express our support for the initiative.

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.


Our ESG analysis tool, CF THOR, which shall be applied to all holdings, includes a section with specific indicators for climate-related risks and opportunities. 

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.

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 full policy is available in Swedish only, but can be made available in English upon request.

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.

Carnegie Fonder has adopted policies and procedures designed to identify and manage conflicts of interest. Both Carnegie Fonder and its employees shall act in the best interest of its customers.

Employees should be attentive to potential conflicts of interest and any conflicts of interest that may arise are handled in accordance with the company’s internal rules for managing conflicts of interest. This means, among other things, that the interests of unitholders come first. In matters where there are conflicting interests between unitholders in funds managed by Carnegie Fonder, interests other than the best interests of the unitholders in each fund must not be taken into account and no specific customer should be favoured at the expense of another.

Areas where conflicts of interest do or may exist are reviewed regularly. Carnegie Fonder has a number of procedures for managing conflicts of interest which are monitored by a second line of defense. As an example, the grandfather principle is applied to internal procedures.

Furthermore, information is limited to employees who need it to perform their work. Personal account dealing is closely monitored in accordance with regulatory requirements.

The board and management are informed about significant conflicts of interest. 

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

All portfolio managers and analysts closely monitor financial and other reporting on portfolio companies, including media. All portfolios are screened twice per year by our service provider Sustainalytics, detailing any allegations of companies breaching intrernationally agreed and genereally accepted conventions and norms such as UN Global Compact. Furthermore, Sustainalytics also distribute bi-weekly alerts reporting any incidents emerging in between the scheduled screenings. Incidents are managed in accordance with the shareholder engagement methods detailed in our Principles for Shareholder Engagement