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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.

Makalani has adopted the following 8 principles:

  1. Integrate ESG issues into the investment process, from investment screening and decision-making, through the monitoring of investments over the holding period.
  2. Ensure that all investment sponsors and/or investee companies are dedicated to preventive and precautionary approaches with respect to environmental and social impacts.  If any environmental or social impact is unavoidable it must be appropriately mitigated or compensated.
  3. Ensure that investment sponsors and/or investee companies comply with the legal and regulatory requirements of the jurisdictions in which they operate and, beyond that work towards relevant international ESG norms and standards.
  4. Ensure that investment sponsors and/or investee companies observe high standards of business integrity and governance. Makalani will work through appropriate governance structures (e.g. board of directors) with investee companies with respect to ESG issues, with the goal of improving performance and minimizing adverse impacts.
  5. Encourage investment sponsors and/or investee companies to establish an open dialogue with their stakeholders on the environmental and social impacts of their activities.
  6. Seek continuous improvement in the management of ESG matters.
  7. Report on Makalani’s activities and progress towards implementing ESG principles.
  8. Provide transparent and relevant information on ESG matters relating to investment activities, adhering to confidentiality. 

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 are able to incorporate client preferences to our ESG policy.  

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 organisation has a Conflict of Interest Policy that covers all individuals and the wider organisation.

This Conflict of Interest Policy forms an integral part of the Code of Conduct and addresses the conduct of investment and other personnel of the fund manager. It also deals with a number of related matters, including the requirements imposed on the regulators in South Africa (Financial Sector Conduct Authority) and Namibia (Namibia Financial Institutions Supervisory Authority).  In addition, certain rules may apply to individuals (in managing conflicts) by professional associations or by virtue of their specific role within the organisation. 

The objective of the Conflict of Interest Policy is to protect the fund manager and investors, against inadvertent breaches of these requirements and, in the event of a breach, to demonstrate that all reasonable precautions had been taken. The policy also protects all individuals by minimizing as much as possible the risk of inadvertent breaches and from the appearance of profiting from knowledge or presumed knowledge gained at the fund manager.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)