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NEI Investments

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

Other description (1) Public policy approach. Public policy includes engaging with regulators, governments as well as standards setters.

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.

Our ESG Investing Program is based on the thesis that companies integrating best environmental, social and governance (ESG) practices into their strategies and operations will build long-term sustainable value for all stakeholders and provide higher risk-adjusted returns to shareholders. The program incorporates the following elements:

• Evaluation of sectors and companies for material ESG risks.

• Corporate engagement on ESG issues with companies in our funds.

• Proxy voting based on ESG guidelines.

• Public policy and standards work to mitigate systemic ESG risks.

• Research on emerging ESG issues.

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]

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.

Other description (1) Public policy approach. Public policy includes engaging with regulators, governments as well as standards setters.

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.

Our conflicts of interest policy describes situations in which a conflict of interest may exist and sets out procedures and requirements related to, among other things, disclosure, prohibited activities, resolution of conflicts of interest and consequences of unresolved conflicts. As well, members of the asset management team that are considered "access persons" (which includes all of the ESG team) must register their personal investments in individual equities with the compliance team and must run all new purchases through compliance before making them.

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

NEI has a comprehensive process for monitoring portfolio companies. All portfolio companies are monitored for Headline Risk through news and ESG controversies services. As part of this process, the NEI ESG Services Team identifies, evaluates and monitors stories that are published in credible media sources and portray a company in a negative manner. Observed Headline Risks are categorized for type and severity, and required actions are determined.

In cases where an incident identified falls outside the range of issues normally captured by a company evaluation and is not being addressed by our Corporate Engagement Program, a Management Breach Investigation may be conducted. We define a Management Breach as a significant transgression of management ethics or a situation indicating a corporate culture that is inconsistent with our responsible investment thesis. While a Headline Risk report records and assesses controversial or negative media coverage about a company, the Management Breach process examines the fundamentals of an incident to determine if a company has violated our Baseline Expectations. A Management Breach determination results in one of three potential outcomes: enhanced monitoring, engagement or divestment.

In addition, we have developed and implemented an internal due diligence process to ensure that our investment processes comply with the OECD's guidance on Responsible Business Conduct for Institutional Investors, which outlines the expectations for investors in regard to undertaking proper due diligence related to the OECD Guidelines for Multinational Enterprises. This process applies to all screened and non-screened portfolios. A particular concern for us is to ensure that none of our portfolio companies are engaging in any activities that cause or contribute to negative human rights impacts.