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PRI reporting framework 2020

Export Public Responses

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.

 As a wealth management firm for Private clients we have clear rules of conduct where we put our clients first and avoid conflict of interest at all cost; should a conflict of interest arise we have to put our clients first and offer full transparency.

We discuss ESG/SRI investment with all our clients; we increasingly see it as our fiduciary duty so inform our clients of the option to invest their assets in a socially and environmentally responsible manner, and aim to educate them about the possibilities therefore, the historical and expected returns vs non-SRI investment, and the difference in impact on the environment and society.

It is in the end up to our clients whether they choose a portfolio that is managed with a specific ESG/SRI mandate, or a more "traditional" portfolio.

For the SRI/ESG portfolio mandates we only use external managers with strong ESG credentials and measurable impact; managers with a well defined approach, usually a combination of exclusions and "best in class".  We expect that these managers actively engage with the companies they invest in, vote their proxies, and use their engagement to encourage positive change. We also use a number of impact funds.


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]

Key elements of our SRI approach

1) endeavor to increasingly educate ourselves and our clients on SRI/ESG investing

2) endeavour to increase engagement with ALL our external asset managers on ESG/SRI issues, also the managers used in non-SRI mandates, in order to stimulate external manager increasing their ESG focus, plus our company dis-investing from non-ESG focussed managers over time.

3) Increasingly favoring external managers that have clear ESG/SRI policies in place, with a focus on active engagement with companies invested in.

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].

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.

1) We avoid conflict of interest by not accepting any form of remuneration from our custodian banks or external managers.  Our sole source of income is management fees.

2) None of our shareholders, officers or employees have management positions in publicly quoted companies, or external management firms that we use.

3) All our clients are treated equally and all "across the board" portfolio changes are executed as "bulk trades" where all buy and sell instructions are given as a "bulk" to custodian banks so all clients are trading at the same time and price.

4) All our staff attend mandatory bi-annual training sessions organised by our SRO which cover subjects such as conflicts of interest.

5) Our company does not manage any money for staff or partners or directors.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)