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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.

Our legal foundation stipulates that ethical and environmental aspects must be considered when making our investment decisions - both in regards to investments in funds and in start-up companies and in regards to loans. Our investment policies and strategies reflect this. As part of our due diligence processes, we require to identify possible ESG issues and we instruct potential investee funds/companies to give us their own account of their ESG profile both with regard to negatives and positives.

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]

In Vaekstfonden we have a responsibility both as a company and as an investor. Our approach is based on internationally agreed principles for sustainable development. Besides PRI, we recognize and follow UN Guiding Principles, OECD Guidelines for Multinational Enterprises and are a participant in the UN Global Compact.

As a responsible investor and loan provider, our approach to overall ESG-factors is focused on dialogue, information, and cooperation.

Prior to the decision on providing co-finance, we include questions in our due diligence processes related to human rights, labor, environment, and anti-corruption. We require that the funds and companies we co-finance commit to handling CSR based on UN Guiding Principles and UN Global Compact. In companies where we are active owners, we require that CSR is discussed annually at senior management level and that issues with a negative impact are discussed immediately if they occur. If a negative impact issue occurs, we will investigate the circumstances thoroughly and use our experience and influence to remediate the situation. Our approach is based on constructive dialogue and on sharing our knowledge and experience about handling ESG-issues.


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 why your organisation has not yet gone through a process to identify transition and physical climate-related risks and opportunities.

We haven’t gone through a process identifying transition and physical climate-related risks and opportunities yet. Right now we are looking into how to identify and factor climate-related risks and how to finance funds and companies, who are working with solutions to mitigate climate-related issues. During 2020 we will launch new mandates with finance to companies working with green and sustainable solutions.

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

Explain the rationale

We are looking at how to support the TCFD, but we haven't made any public statements about it because we at the moment are investigating how to address the TCFD correctly.

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

Describe how and over what time frame the organisation will implement an organisation-wide strategy that manages climate-related risks and opportunities.

At the moment we are in progress with a wider strategy on how to manage risks and opportunities related to climate.

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].

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.

Decisions involving a potential conflict of interest will as the first step be handled in constructive dialogue with the relevant fund or company.
If there is no progress in mitigating the negative impact, the concrete case will be discussed in one of our relevant business committees; Investment committee (for internally managed PE), Fund Committee (for externally managed PE) or Credit committee (for loans). In case of severe conflicts, the case will be brought to a decision in our Executive Management Group. If relevant our board of directors will be informed and asked to make the final decision. 

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

In regards to the UN Guiding Principles, we ask our portfolio funds and companies to have processes in place handling negative impact 
We encourage the funds and companies to contact us if any incidents occur and to tell us how they will handle the conflict.

We always engage in dialogue with the involved fund or company and ask them to mitigate their negative impact. We always encourage to go into dialogue with the affected stakeholders. 

In Vaekstfonden we have a whistleblower-arrangement for both internal and external complaints: