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PRI reporting framework 2020

You are in Strategy and Governance » Investment policy


SG 01. RI policy and coverage


01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類と対象範囲を示してください。


01.3. 投資ポリシーが以下のどの項目をカバーしているか明示して下さい:

01.4. 組織の投資原則および全体の投資戦略、受託者義務(または同等のもの)の解釈、ならびに、ESGファクターおよび実体経済の影響をどのように考慮に入れているかについて説明してください。

METROPOLE Gestion has adopted a single, global and integrated process: Responsible Value Investment. We select undervalued stocks compared to their industrial value within a stock-picking framework encouraging the companies in which we invest to implement sustainable development over the long term, regardless of their business sector. Implementing a Value management style necessarily calls for particular vigilance, not only the financial risks but also governance, social, environmental  and climate change risks and opportunities. In addition to the risks companies face in these areas, we believe it is essential to encourage them to improve by a responsible and sustainable approach to growth. We therefore apply a best-in-class and best effort methodology, engage with the companies from the very outset, integrate these criterias in the exercise of our voting rights and maintain an on-going dialogue with them (direct, thematic and collective). We also produce ESG performance indicators, climate change risks scores, for measurement and transparency purposes.

Therefore and starting in 2008, we implemented a full set of tools in order to fulfill our objectives. We started by establishing a quantitative company rating methodology exploiting ESG criterias, funded a research Chair at the Clermont Auvergne University or more recently improve climate change risks measures.

01.5. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。[任意]

Since 2008, METROPOLE Gestion has  established a methodological basis independent of the major ESG rating agencies by establishing an academic collaboration with the Clermont Auvergne University in order to produce an in-house company rating system proprietary to METROPOLE Gestion.

1. The reference framework:

The frame of reference is the architecture of the rating system. It is organised into 4 orthogonal pillars:

  • Environment
  • Social
  • Governance
  • Stakeholders

2. Quantitative analysis: data metrics and aggregation:

  • We use Eikon (Thomson Reuters), one of the largest extra-financial databases (5000 companies worldwide), which provides stable data over time, combining official corporate data (annual reports, sustainable development reports) and details of any controversies sourced from press agencies.
  • Using this data, we build 150 indicators to measure each element of our standards, favoring outcomes over drivers deployed (75% - 25%).
  • Each pillar is equally weighted.
  • Best in Class rating: each company is rated in relation to its sector to obtain a Best in Class rating.
  • Best Effort rating (1 to 5 stars): this takes into account the change in extra-financial rating over the past four years, with additional weighting given to the last year.
  • Ratings are reviewed annually.

3. Qualitative analysis:

The quantitative rating is verified and completed by the qualitative analysis. It is based on the following elements:

Consideration of current controversies

All the controversies relating to stocks held in the portfolios are fed back and monitored weekly.

On new companies studied, controversies are analysed over the last three years in addition to the quantitative score.

Analysis of specific sector risks

We also pay close attention to identifying specific ESG risks. We include these risks in our analysis for all companies in the same sector.

Dialogue with the companies

The dialogue with companies is through interviews with CSR managers and company managers (at least once a year for portfolio companies), which provide the opportunity to look in greater detail at the identified risks, pinpoint unidentified risks during the rating process and understand the company’s strategy.

Climate change principles and criteria

A set of climate change indicators is integrated within our in-house model. 35 indicators out of 150 indicators that we monitor are climate change criteria and are distributed among the 4 analytical pillars. In addition to these quantitative criteria, we engage with companies during direct dialogue with them and as a signatory of the CDP, we adopted the "Non Disclosure Campaign", a collective engagement campaign targeting companies not responding to information requested by the CDP.

4. Our Responsible Value Investment policy:

METROPOLE Gestion Responsible Value Investing is a global, integrated management process.

Our initial investment universe is composed of European companies with over 100 million euros of market capitalisation, with the exception of those subject to the exclusions specified in our policy (controversial weapons, coal production or consumption, tobacco and pornography).

As such, the systematic exclusion of mining companies that generate more than 30% of their revenue through coal production and energy-producing companies with more than 30% of its production coming from coal is a strong incentive for European companies to embark on the path of the Energy and Ecological Transition. Our eligible universe therefore constitutes the starting point for portfolio construction.

Financial analysis and the selection of discounted securities comparing to their industrial value constitutes the second filter that once again narrows the universe.

Exploiting non-financial analysis, the third filter consists of supplementing the financial analysis by favouring the discounted companies with the best ratings in their business sector and discounted companies making the best efforts in terms of transition to better ESG practices. This approach not only limits potential risk, whether financial or, more specifically, relating to ESG, but also encourages the companies to accelerate their transformation toward sustainable growth and seize the opportunities created by such transformation.

Lastly, the catalysts likely to reduce the valuation discount and ESG controversies represent the final filter applied to the selection of securities that may constitute the portfolio.

The investment universe established accordingly may evolve as time progresses in line with valuation movements in the markets and ESG transformation at company level. The fund management team adjusts the investment universe on a daily basis.

The portfolio is constructed via a collaborative decision-making process by the entire fund management team, weighting each security in accordance with its discount, the quality of the company’s balance sheet and its ESG qualities. Lastly, the fund management team applies a strict disposal policy if the valuation objectives are reached, if the quality of the company deteriorates in terms of ESG or in the event of a major controversy.

5. Impact measurement and ESG analysis

- We measure an average ESG footprint calculation (average rating calculated for each portfolio), which can be compared to their benchmark and published monthly.

- The carbon footprint of the portfolios is also published in each monthly factsheet alongside the carbon footprint of their benchmark.

The carbon footprint is calculated in equivalent tonnes of CO2 per year per million euros of revenue. The calculation covers Scope 1 and Scope 2 emissions.

- An annual impact report is published

One indicator has been selected per pillar (Environment, Social, Governance and Stakeholders):

·         CO2 emissions (equivalent tonnes of CO2 per year per million euros of revenue; i.e intensity);

·         Percentage of women managers;

·         Integration of non-financial criteria within the compensation of senior management;

·         Companies applying a policy to defend human rights.

- Finally we calculate a climate score specifically linked to the climate change risks and to the energetic and ecological transition risks.

This score includes  physical risks, transition risks, and  measures taken by the companies to limit global warming to below 2°C.

01.6. 補足情報 [任意]


SG 01 CC. Climate risk

01.6 CC. 投資期間において特定され、組織の投資戦略・商品に組み込まれている気候関連のリスクおよび機会について記述してください。

特定された気候関連の移行リスク・物理的リスクおよび機会、ならびに投資戦略・商品にそれらがどのように組み込まれているかを説明してください。(500 語以内で自由に記載)

As a stock picker asset manager, METROPOLE Gestion identifies climate related risks and opportunities for every company held in the portfolios. 35 indicators out of 150, i.e. over 20% of the indicators we monitor in our ESG framework are climate change risks and opportunities criteria and are distributed among the 4 analytical pillars.

They are broken down into the following themes:

•     Physical risks induced by climate change

•     Risks induced by transition to a low-carbon economy

•     Benefits of favouring a low-carbon economy

•     Compatibility with the 2°C pledge

•     Consequences of climate change and of extreme weather events

•     Changing availability of resources “climatically” compatible with the objectives

•     Consistency of investment expenditures with the low-carbon strategy

•     Measurement of greenhouse gas emissions

The consideration given to these issues is therefore an integral part of the company rating process and, therefore, of the selection process and the  construction of the portfolios.

The 35 indicators are also following the11 recommended disclosures by the TCFD even if some of the disclosures are not yet aligned with these recommandations. This is the reason why, in addition to incorporating criteria within the ESG ratings, METROPOLE Gestion has adopted a policy of thematic engagement covering climate change risks and opportunities. During dialogue with issuers, we question all companies held in the portfolio about their CO2 strategy and assess the extent to which they comply with the 2°C pledge established during the Paris Climate Agreement. The results of this engagement are detailed in our annual Engagement Report available on our website.

Furthermore, as a signatory of the Carbon Disclosure Project, METROPOLE Gestion has adopted the "Non-Disclosure Campaign", a collective engagement campaign targeting companies not responding to information requests from the CDP. This engagement is designed to improve the transparency of climate change risks and opportunities financial disclosures communicated by companies.

Through its proxy voting policy, METROPOLE Gestion is putting emphasis on the Governance recommendations from the TCFD by prompting companies to implement remuneration correlated with ESG targets and therefore Climate related risks and opportunities disclosures. We are planning in 2020 to collaborate with other investors to place resolutions regarding better climate related risks and opprtunities disclosures that we already sustained in 2019 and that we reported in our voting policy reporting available on our website.

Regarding metrics and targets ( 4th recommandation of the TCFD), two metrics are followed specifically among others from the past two years and are available on our impact reports on our website: CO2 emissions of the portfolios  and the inclusion of extra-financial criteria in executive pay awards.


Regarding sectors, and following two UN Sustainable Development Goals, affordable and clean energy and climate action, METROPOLE gestion exclude from its investment universe, companies that produce and consume coal: mining companies that generate more than 30% of their revenues from coal production and energy producing companies when more than 30% of their production comes from coal.

01.7 CC. 組織はそれら気候リスクの可能性および影響を評価しましたか?


Risks and opportunities' timescales are systematically assessed through the dialogue with companies in order to comply with regulation in France as we are a french asset management company based in France and as a signatory of the UNPRI, the TCFD, the Montreal Carbon pledge and the CDP.

01.8 CC. 組織はTCFDを公式に支持しますか?

01.9 CC. 重大な気候関連リスクおよび機会を特定・管理する組織全体の戦略がありますか?


As a signatotory of the TCFD, METROPOLE Gestion has started to implement the 4 recommendations of the TCFD in the analysis of each company METROPOLE Gestion owns in its portfolios.

We approach this implementation in two ways depending on the current disclosures from the companies we invest in (some recommended disclosure as the "resilience of the strategy" or the "integration into overall risk management" have still a very low percentage of disclosure). In the case we get a clear and transparent disclosure, it is part of our ESG rating and of our climate scoring. In the case disclosures are not existing or are still in their infancy, we engage with companies through our proxy voting, through direct dialogue, through thematic engagement ( this year the theme has been the reduction of CO2 emissions policies and the alignment of companies towards the  Paris agreement) and finally we've been part this year of the the "Non disclosure Campaign" led by the CDP.

In 2020, we will implement a complete framework of climate scoring following the TCFD disclosures recommendations for all our investments.

1.10 CC. TCFD開示を発表するために組織が使用する文書/通信を示してください。

SG 02. Publicly available RI policy or guidance documents


02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。









02.2. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。








02.3. 補足情報 [任意]

We publish on a monthly basis reporting on each equity fund including time horizon on our investments, CO2 emissions  and ESG ratings compared to their indices.

SG 03. Conflicts of interest

03.1. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

Possible conflicts of interest directly concerning the financial management business:
This type of conflict of interest has been identified and is managed by means of the system for processing stock market orders (for investment or divestment purposes) placed with financial intermediaries, requiring:
• The systematic pre-allocation of orders in the management application/transmission of orders (sent to brokers),
• The drafting of an incident report when a trading error is recognised,
• The prohibition of transactions arbitraging positions (buy-sell) between funds and between funds and mandates, when their sole purpose is to ensure sufficient liquidity for one of the counterparties.
To this end, the company has an operational procedure for allocating and monitoring orders and a procedure for transactions between managed portfolios.
As part of its third-party asset management business, METROPOLE Gestion must always serve the best interests of its principals or of the shareholders [or unit holders] of the funds under management, ensuring that principals and shareholders are treated equally.

03.3. 補足情報 [任意]

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、投資先企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

In the event that any anomalies or incidents are detected, the following procedure is applied:

1-Information of the operational manager and prior analysis

The person who caused or detected an incident covered by the scope of the procedure immediately informs his/her operational manager. Together, they decide whether or not an incident report form should be opened for the problem.

2-Incident report form

The incident report form is created. It is identified by a number that chronologically lists incidents. The standardised report form particularly contains the identity and function of the person (the "author") who detected the incident, the date the problem was detected, the type of incident, the details thereof, the date(s) of reminder(s) and the corrective measure(s) taken. This report form is signed by the author and his/her operational manager.

3-Categorisation and retention of incident report forms

In an incident life cycle, a report form may have the following statuses:

- in progress: the incident is being investigated with a view to its resolution;

- solved: a solution has been found and normal service is restored. As soon as the incident has been solved, the author must close it by indicating the resolution date on the report form together with any further information about the corrective measures taken. Once signed, report forms are saved on the network in a dedicated directory with any relevant document (email, order ticket, etc.).

4-Communication of the incident

The author must inform Management and the permanent control team by email quoting the incident reference number as soon an incident report form is created ("in progress" status) and again once it is solved ("solved" status).


Resolution lead-times are determined based on the priority of incidents. 6-Incident follow-up If within 5 working days of opening an incident report form, the problem is still unsolved, the report form author informs his/her operational manager and the permanent control team by email. Within 10 working days of opening the incident report form, if the problem is still pending, the CCO notifies Management by drafting a memo explaining why the problem is still not solved. The CCO reads the incident report forms and reports to Management on a monthly basis on incidents that occurred during the month. Incidents are recorded in the incident database monitored by the permanent control team and are analysed to improve internal processes.