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PriorNilsson Fonder

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy


SG 01. RI policy and coverage


01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類と対象範囲を示してください。


01.3. 投資ポリシーが以下のどの項目をカバーしているか明示して下さい:

01.4. 組織の投資原則および全体の投資戦略、受託者義務(または同等のもの)の解釈、ならびに、ESGファクターおよび実体経済の影響をどのように考慮に入れているかについて説明してください。

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. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。[任意]

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. 補足情報 [任意]


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。



02.2. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。






02.3. 補足情報 [任意]

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. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

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. 補足情報 [任意]

SG 04. Identifying incidents occurring within portfolios (Private)