This report shows public data only. Is this your organisation? If so, login here to view your full report.

Amethis Luxembourg S.à.r.l

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.

Africa’s population is forecasted to more than double to 2.4bn by 2050 and the continent is expected to face the fastest urbanization of any region in the world. Despite a 250$ billion middle-class market confirming the continent’s progress towards growth and development, poverty rate continues to reach highs. With a workforce projected to be larger than either China or India by 2034 whilst job creation is outpacing labor force growth, multinationals have been eyeing the continent for opportunities in consumer-linked sectors. For the first time in Africa, sectors delivering the highest returns are consumer-oriented. However macroeconomic turbulences have impacted various sectors (financial institutions vs. industry or FMCG) and categories of consumers (stronger impact for the bottom of the pyramid). Natural resources exporting countries have suffered from the dramatic decrease in commodity prices.

In this prospective context, we strive for support toward local SMEs in developing their activities to:

•           Provide local markets with qualitative goods and services for basic necessities and consumption

•           Provide decent jobs, enabling workers to earn their living while not compromising their health and safety

•           Protect the local environmental ecosystem by managing the environmental externalities and optimizing the resource consumptions

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]

The responsible investment approach of Amethis is composed by 5 key elements:

1. A reference framework:

  • National laws and regulations
  • The IFC Performance Standards and World Bank Environmental Health and Safety Guidelines

2. An exclusion list: Amethis has a strict investment exclusion list

3. A risk analysis framework: Amethis has a structured procedure to assess ESG risks related to investment projects, which 3 main stages:

  • Risk universe definition
  • Inherent risk analysis
  • Residual risk assessment

4. E&S due-diligence: Amethis always hire external specialist to conduct E&S due-diligence during the investment process
5. E&S actions plans and E&S covenants in shareholders’ agreements

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.

Potential conflict of interest are addressed by specific stipulations in each constitutive documents of each AIF, whereby the Advisory committee representing certain large Investors of the Fund is responsible to, certain governance issues that may arise in the context of the management of the Fund, and, without limitation regarding any potential or actual conflict of interest.

Moreover, to prevent any conflicts of interest having a detrimental effect on the Fund and its assets (except with the consent of the Advisory Committee), (i) the Fund shall not directly or indirectly acquire investments from, sell investments to or otherwise engage in any transaction with the General Partner, the AIFM, the Investment Advisor, the Initiator, any limited partner or any Affiliates thereof; and (ii) none of the General Partner, or Amethis, the Initiators, any limited partner or any Affiliates thereof shall engage in any transaction with the Fund.

03.3. Additional information. [Optional]

In addition to the specific rules relating to the management of conflicts of interest set out the constitutive documents of the Fund, the Fund will rely on and apply the conflict of interest policy of the AIFM in order to identify and manage conflicts of interests.

This conflict of interest contains specific rules on deals allocations and priority between the various AIF managed by the AIFM

In addition, any actual or potential conflicts of interests shall be disclosed to the Advisory Committee which shall review, assess and approve or disapprove conflicts of interest, any member of the Investment Committee will be precluded from participating in decisions, if the member has a potential or actual conflict of interest.

Where conflicts of interest cannot be avoided and there exists a risk of damage to Investors’ interests, the AIFM shall inform Investors of the general nature or causes of the conflicts of interest and develop appropriate policies and procedures in order to mitigate such conflicts while ensuring equal treatment between investors and ensuring that the Fund is treated in an equitable manner.


SG 04. Identifying incidents occurring within portfolios (Private)