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ABS Investment Management LLC

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

          Policy covering external managers
          Policy covering ABS firm behavior

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.

At ABS we recognize that as individuals and as a firm, we have a responsibility not only to our investors, but also to the larger global community.  This policy sets out to detail how we aim to address that responsibility.  As a firm, we strive to provide an inclusive, transparent, and enjoyable working environment while minimizing our environmental footprint.  As an investor, we endeavor to leverage our platform as an early investor in niche equity managers to promote the spread of ESG consciousness in the broader investment community. In doing so, we aim to not only better safeguard the interests of our clients, but also to contribute to a more sustainable asset management industry.

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]

ESG integration into the investment process refers to an investment approach that clearly acknowledges and incorporates material ESG risk factors into the investment process and security underwriting.  The goal is not to restrict specific stocks, countries, or industries, but rather to ensure that our invested managers are aware of, and consider in their investment decision making, any potential ESG risks or opportunities within their coverage universe.  ABS does have the ability the restrict specific stocks, industries, countries, etc. based on specific client preferences within our manager-of-managers product that invests exclusively via Separately Managed Accounts.

ABS encourages and works closely with all of our invested managers to develop and maintain an ESG policy that provides the ABS investment team sufficient confidence that any potential ESG-related risks and opportunities are being properly assessed. ESG analysis is a key consideration in our investment research process, with the main pillars outlined below:

ESG in the Due Diligence Process

ABS takes a three-track approach by incorporating ESG due diligence in into our qualitative research process, quantitative research process, and operational due diligence process.


The Qualitative Research Team is responsible for all new manager research and for ongoing monitoring of all invested managers.  Because ESG awareness is a core consideration in our investment underwriting, the Qualitative Research Team has primary responsibility for understanding, documenting, and monitoring the ESG policies of all the managers with which we speak.  The Qualitative Analysts track these interactions using ESG-specific features built directly into our proprietary internal research system (the ABSolute).


The Quantitative Research Team provides an additional layer of support by monitoring the underlying holdings of all SMA accounts and of all fund investments where position-level transparency is available. If securities are held that appear to be at odds with a manager’s written ESG policy, that security can be brought to the manager’s attention and used as an engagement opportunity.


The Operational Due Diligence team provides an additional layer of support to the Qualitative Team’s efforts through a series of Responsible Investment questions that are included in our mandatory annual Due Diligence Questionnaire.  The responses are compared to the Qualitative Team’s assessment and any discrepancies or nuances are discussed with the manager.



ABS’ investment philosophy emphasizes finding the most talented asset managers around the world.  Our focus on local and niche managers means that ABS is often a significant investor in the earliest stages of a manager’s track record.  As a result, we are able to use our influence to engage with all potential and invested managers to encourage them to adopt an official ESG policy in the event that no policy already exists.  Not only does ABS benefit by ensuring all of our managers are cognizant of ESG risks, but we are also able to positively influence the proliferation ESG consciousness across the broader investment management community.

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].

ESG Policy and Investment Policy documents are available upon request.

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.

ABRIDGED: As an Access Person, you have an obligation of loyalty towards the Firm. Under no circumstances are you to use your professional position directly or indirectly for personal purposes by taking unfair advantage of any confidential or inside information or by profiting in any other way from your professional position. You should be extremely careful to avoid any personal conflict of interest with the Firm or its clients. Access Persons are reminded that they must give prior notice of outside activities in which they wish to engage. This includes serving on committees or boards for any companies or
organizations (including non-profits), any outside business interests, private securities transactions, and maintenance of personal brokerage accounts. In addition, any spouses or immediate household members who are employed with publicly held companies should be disclosed to the Chief Compliance Officer. Should the Chief Compliance Officer determine that there is a risk that such person may come into contact with material non-public information due to the responsibilities
of their position, the issuer will be placed on ABS’s restricted list. Access Persons may not use their authority or position for their personal gain.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)