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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.

In the investment process, the analysis consider the social, environmental, economic and, above all, corporate governance dimensions. In addition, it is also considered the risks associated with credibility and reputation. The ESG incorporation aproach is done both preventively and through monitoring. For this, we use an internal rating that is described in one of our risk policy which is attached to Infraprev's investment policy.

Also, we believe that transparency and values ​​associated with the best practices of corporate governance are fundamental concepts for the responsible management of investments and the fiduciary duty with Infraprev's beneficiaries.

The investment estrategy is built on the basis of the Asset Liability Management (ALM) model which considers the portfolio to be optimal against future commitments regarding the benefits of the participants.

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 investment policy and the ESG risk policy are approved by the Deliberative Council. The ESG guidelines / ranking are defined by the risk area, apart from the investment area.

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 why your organisation has not yet gone through a process to identify transition and physical climate-related risks and opportunities.

In recent years, Infraprev has been dedicated to improving processes specifically with a focus on governance improvements and mapping potential conflicts of interest. 

Regarding the risks and opportunities related to climate change, our organization, despite not having made a specific process on this issue, maps these practices through its external managers. During the selection process, when considering the ESG practices adopted by them, the way in which they assess climate risks and possible opportunities is observed.

In private equity funds, that include energy and forest assets, climate risks are mapped and monitored monthly and reported in a specific report.

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

Explain the rationale

As explained above, due to the fact that the focus of Infraprev in recent years has been primarily directed towards specific issues, there has not yet been an in-depth study on the recommendations of the TCFD.

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

Describe how and over what time frame the organisation will implement an organisation-wide strategy that manages climate-related risks and opportunities.

There is no predicted deadline for this to occur. The first step is to have an internal study to see what would be the most appropriate way to implement this organization-wide strategy that manages climate-related risks and opportunities, considering the internal structure (size and tools to be used) of teams in Infraprev.

For now, in private equity funds, that invest in energy and forestry assets for example, climate risks are mapped and monitored monthly and reported in a specific report..


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

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].

In addition, Infraprev has an ESG Risk criteria that supports the Investment Policy. They support the analysis and the monitoring process.

Infraprev's investment policy is only publicly available for participants.

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.

The Infraprev has two formal committees to advise (Risk Management Committee) and deliberate (Investment Management Committee) on the allocation of financial resources and the risks involved in this operation.Infraprev has a Statute and Code of Ethics that establish the roles and limits of competencies of board and staff.

Potencial conflicts of interest eventually can be submitted to this governance structures.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

In the monitoring process when a event is identified, the Risk Management Committee points out risks involving the event, and the Investment Management Committee deliberates the next steps.