Investment process in the OPCVM pocket excluding unit-linked products (UL)
The work undertaken by the Sustainable Development Department and the Investment Direction has enabled the implementation of a responsible investor approach in the OPCVM pocket, excluding the open-ended monetary funds and non-UL funds.
I. General criteria for the eligibility of UCITS outside UL (open and dedicated funds, regardless the nature of the underlying assets)
a. Exclusions of company and countries :
Exclusion of producers of cluster munitions and antipersonnel mines (list produced by the group compliance department, provisionally delegated to the sustainable development department, see appendix)
Exclusion of speculative funds on agricultural raw materials
Exclusion of OPCVM domiciled in a sensitive country
b. ESG commitment of management companies :
The Investment Management Department checks whether the management company has joined the MICs and failing that, questions its ESG commitments
II. For non-UL dedicated corporate funds (shares and bonds) : in addition to the general rules, additional exclusions of « sensitive securities »
a. Securities listed
Securities with a very high ESG risk : non-compliance with the principles of the Global Compact
Securities with a significant share of their turnover in thermal coal
b. Application by the management company :
Exclusion of the investment universe from any relevant securities.
Sale of the relevant securities in stock at the time of the distribution of the note according to deadlines consistent with the market liquidity
III. Dedicated sovereigns funds excluding UL products : exclusion of sensitive countries
IV. Open-ended funds: ESG monitoring of asset management companies
Monitoring of open-ended funds ensures that the guiding principles of the responsible investment policy are respected :
On the stock : a survey is carried out every 2 years by the Analysis and Funds Selection service (FFGF) on the exposure of funds to producers cluster munitions and anti-personnel mines bombs and on the management of embargoes and tax havens.
In the selection: exposition in the field of cluster munitions and antipersonnel mines bombs is integrated into due diligence and, since July 2015, the management of embargoes and tax havens too.