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Stichting Pensioenfonds UWV

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.

The fund has nine general investment principles . One of these principles is dedicated to ESG.

The pension fund invests in order to meet future pension payment liabilities. The investment portfolio is invested in a diversified way to mitigate risk and maximise returns. It is believed that ESG does not reduce investment returns and may reduce financial risks resulting from physical damage of transtioning to a fossil-free world.

The ESG policy of the fund has been extensively discussed with stakeholders before deciding on the final set-up of the policy; the policy has a 3 year term in which ambitions should be realized.

ESG considerations are integrally taken into account in the investment policy, both in determining the asset mix and on an individual level. ESG is implemented through a combination of exclusions (100% coverage), best-in-class (equities, credits and emerging market debt), voting (equities) and engagement activities (equities). Active (impact-like) strategies are considered in the private markets portfolio (most notably infrastructure).

The implementation of the ESG policy and its results are disclosed in the annual ESG report of the fund. A dedicated ESG report is also required from our property advisor and manager of private market investments.

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]

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.

In its annual carbon footprint report an assessment is made of physical and transitional risks within the investment portfolio. Currently, a discussion is ongoing to act on the insights of these reports by i.e. excluding certain sectors and/or regions from investing in. The first example has already been the exclusion of coal mines, due to the expected negative transitional impact. The fund is comtemplating an assessment of its real estate portfolio and infrastructure portfolio in order to gauge potential physical risks.

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

Describe why your organisation has not yet assessed the likelihood and impact of climate risks

Quantification of climate risks has not yet been conducted, but is planned to be undertaken in the course of 2020 as part of its Own Risk Assesments as prescribed by the IORPII directive

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

Explain the rationale

The fund does not publicly endorse TCFD. However, in the fund's ESG policy a reference is made to TCFD guidelines as a tool to enhance access to climate risk related data.. Indirectly, the fund uses TFCD guidelines when applying ESG scores (in case of the Environmental score).

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


By means of a carbon reduction target the fund attempts to mitigate this risk. Furthermore, by means of a best-in-class approach the fund wishes to exclude the 50% worst performing companies from the investment portfolio. To this end ESG ratings are applied to companies. This will mitigate potential financial risks to climate change.

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


          In its annual ESG report the fund discloses its carbon footprint, based on an underlying report which uses TFCD recommendations

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.

All managers should have a conflicts of interest policy. Especially in case of private markets investments this is heavily scrutinized, also in the legal documentation between the pension fund and the private markets manager. In case of mortgage pooled funds, the pension fund explicity requires a vertical slice to be retained by the manager ('skin in the game').

Furthermore, the pension fund has the policy that it will not purchase any investment products (i.e funds an/or mandates) of its fiduciary manager.


03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)