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PriorNilsson Fonder

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.

At PriorNilsson we believe in true active management. We build our asset management on pure fundamental analysis. We stick to basic factors for valuing a company and its equities. Through our active management we believe that we can create a better return than the market over time. Our portfolio managers have no secret models. Their ideas are largely based on many years of experience. If they sit opposite each other and talk about equities throughout the day a lot of investment ideas are born in the daily conversations. ESG factors are an integrated part of these conversations and the investment decision-making process.

True active management means that we can fully choose the stocks we believe in, without taking a position on an index. This also means that sometimes we may opt out a company completely from the funds no matter how heavy the weight is in index.

Our investment principles oblige us to exclude investment in certain sectors. We also screen our holdings by external service-providers to inform us on any breaches of our investment norms in our portfolio companies. This enables us to stick to our principles.

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 work with responsible investments is based on international conventions signed by the Swedish government regarding topics such as human rights, environmental issues, corruption and labor rights. PriorNilsson invests primarily in Swedish firms, but also to some extent in other markets across the globe. Our investments are aligned with the principles and policies settled by PriorNilsson’s Board of Directors.

We are investing in accordance with several principles, conventions and treaties. Thus, we are commited to refrain from investing in firms breaching these agreements. In addition, PriorNilsson is a signatory of the UN Principles for Responsible Investment (UNPRI) as well as the Sveriges Forum för Hållbara Investeringar (Swesif).

These commitments by PriorNilsson on the policy level with regards to responsible investments affect the operational management of funds directly through three primary methods: exclusion, screening & review and ESG integration.



We are restricting our funds’ investment universes (i.e. the companies and asset classes we can invest in) by excluding such companies that are operating in sectors where there is a general prohibition or in conflict with our commitments on the policy level (see ”Responsible investments” above). The general prohibition excludes companies involved in controversial weapons such as cluster mines, landmines, nuclear weapons, biological weapons, chemical weapons as well as weapons of white phosphorus or depleted uranium. Apart from this, there are no absolute prohibitions towards any specific type of investment. Instead, ESG factors are well-integrated into the fundamental analysis prior to every investment decision.

External resources such as reports and ESG research data are being used by PriorNilsson to consider exclusion. As an example, the AP7 fund communicates a ”blacklist” bi-annually that serves as a basis for exclusion from our investment universe. On top of this, our external ESG research analysis providers supply us with ad hoc recommendations on companies that could be excluded.

On a post-investment basis the news flow regarding portfolio holdings is naturally covered for news that could lead to exclusion based on our commitments.


Screening & Review

As a means to follow-up current holdings in order to (in severe cases) exclude/divest companies or (in less severe cases) discover opportunities to influence companies in a direction more in line with our overall take on responsible investments, we are conducting regular screenings and reviews. Our external partner for ESG services, Sustainalytics, is performing rigorous screenings of our portfolios twice a year to control and identify potential risks. These risks often concern companies that might deviate from PriorNilsson’s ESG commitment.

Apart from this, the Head of Responsibility as well as the portfolio managers are performing in-house screenings and reviews of ESG issues frequently.


Active Ownership

We invest in companies where we see long-term potential for risk-adjusted excess returns for our clients. Under certain circumstances, we might come to the conclusion that the best means to achieve this goal is through active engagement with our portfolio companies in order to better their performance or risk management. The ownership actions available to us under these circumstances are proxy voting, dialogues and particitating in nominations to the board of directors.


ESG integration

A responsible approach to investments constitute an integral part of the investment decision-making process at PriorNilsson. The portfolio managers are treating company, sector and country ESG data in the financial analysis in the same way as and alongside other publically available data on the firm. This ESG data is sourced from the media, external reports, annual reports, CSR reports, equity research reports or any publically accessible information source.

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].

Most of the content regarding our investment policies are provided exclusively in Swedish. Should there be requests for information in English, please contact our Head of Responsible Investments:

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.

Our policy builds on Swedish and EU jurisdiction and guides PriorNilsson to 

  • Identify conflicts of interest,
  • provide routines to deal with any conflicts of interest.

The policy specifies certain areas where conflicts of interest risk to take place and provides detailed information on how to deal with these risks proactively and reactively while protecting clients from negative effects of any such conflict. Whenever a conflict of interest occurs, the policy specifies the line of command and necessary actions for mitigating this risk as much as possible with the client's best in mind.

In order to avoid conflicts of interest there's a self-reporting system in place and the policy states that the information from these reports will be subject to review in the recurring compliance meetings.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)