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NewAlpha Asset Management

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.

NewAlpha's historical core business is to identify talented and smaller/newer investment managers, founded and run by entrepreneurs, on behalf of institutional investors interested by their performance potential and innovative approaches. Discovering and developing relationships with these characters inherently requires an open-minded spirit and a team, which shares a passion for new ideas, innovative and disruptive ways of thinking. Since 2016, NewAlpha has applied these fundamental investment principles when developing its Private Equity activity by creating two funds dedicated to identifying innovative technologies in the FinTech, Healthcare, TMT and industrial niches sectors.

NewAlpha's commitment to supporting entrepreneurial initiatives and encouraging job creation, has attracted institutional and governmental bodies that have supported NewAlpha, such as Bpifrance (, which became an investor in NewAlpha's FinTech fund through its French Tech Acceleration Fund.

Furthermore, when writing its CSR policy, NewAlpha re-committed to its ESG initiatives:

  • Taking measures to control its environmental impact
  • Supporting non-profits initiatives
  • Putting NewAlpha's employee at the core of its governance with access to the company shares and/or a carried interest 

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]

As a responsible Investor, NewAlpha strongly believes in the inevitable convergence between Investment and Responsible Investment.

On the foreseeable future, any investment will be analysed according to financial criteria as well as ESG ones. Apart from obvious cases, such as coal fired power plant companies, where asset value has already started to halve (stranded assets), it is still difficult today to quantify precisely:

  • the negative impact of not taking ESG issues into account
  • the positive impact on investment appreciation of such criteria

However, we are convinced that financial performance will be strongly correlated to business ethics and that ESG criteria will be critical to manage any business.

As an example, diversity and inclusion, leading to broader point of views when dealing with investment analysis, have demonstrated to be efficient. On another hand, as talented people tend to request sustainability as a prerequisite to join corporations, high performing companies will be sustainable ones.

Practically, in the fund of fund or investment advisory business, we select asset managers and invest in management teams. Therefore, extended due diligence on people, mindset, corporate and business values (such as how they conduct their own business) are critical to us.

We certainly request some exclusions, progression towards parity, among other topics, but the best way to ensure we deal with responsible managers is to research the ones with value alignment, or willingness to move towards sustainable investment as an intimate conviction.

Finally, building trust and transparency with our managers will benefit to long term partnership and financial performance.

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.

Practically, in the fund of fund or investment advisory business, we select asset managers and invest in management teams. Therefore, extended due diligence on people, mindset, corporate and business values (such as how they conduct their own business) are critical to us.

NewAlpha is conscious of the climate-change related risks. However, we do not have yet the the ability to implement a specific climate-change policy within the scope and the time horizon of the mandates we managed for our clients.





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

Explain the rationale

As a small investment manager (25 professionals), our resources are limited. We will express our support soon.

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.

We envision the next step to focus on the Climate issue: investors, corporations will have to measure their portfolio temperature and how they are aligned with carbon neutrality in 2050.

Specifically, on the 2°C Paris climate target, we will set a clear roadmap to reach our target of carbon neutrality by 2050. The Paris community is in the process of:

  • Exploring methods to measure adequately the portfolio temperature and its evolution;
  • Setting guidelines for investors to follow their commitments towards portfolio alignments and more generally sustainability of portfolios across several dimensions (AMF & ACPR to set clear measurements and reporting guidelines by year end). We will have to set the standard for our portfolio managers.

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].

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.

NewAlpha identified the following risks of potential conflicts of interest : (i) allocation and redemption process applied to investment programs, (ii) investment cases involving a manager linked with an investment program embedding GP economics, (iii) link between the firm and its staff with of external managers or their service providers. Eventually, in order to meet its regulatory duties and to act permanently in the best interest of its clients, NewAlpha’s Internal Control & Compliance officer maintains a mapping of conflicts of interest related to the Firm’s business lines, which encapsulates all identified potential conflicts of interest are defined accurately and the way the management company is addressing and mitigating them. This mapping of risks of conflicts of interest is updated on a regular basis and is registered with the Autorité des Marchés Financiers, NewAlpha’s regulator. ​

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)