Public HTML RI reports - PRI reporting framework 2020

Pareto Asset Management AS

PRI reporting framework 2020

Basic information [OO 01 - 09] Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]

Strategy and Governance

Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Asset class implementation not reported in other modules [SG 16 - 17] Innovation [SG 18] Communication [SG 19]

Direct - Listed Equity Incorporation

ESG incorporation in actively managed listed equities [LEI 01 - 10] Implementation processes [LEI 01 - 10] (A) Implementation: Screening [LEI 04 - 06] (C) Implementation: Integration of ESG factors [LEI 08 - 10] Outputs and outcomes [LEI 12 - 13]

Direct - Listed Equity Active Ownership

Overview [LEA 01] Engagement [LEA 02 - 08] Outputs and outcomes [LEA 09 - 11]

Direct - Fixed Income

ESG incorporation in actively managed fixed income [FI 01 - 12] Implementation processes [FI 01 - 03] (A) Implementation: Screening [FI 04 - 06] (C) Implementation: Integration [FI 10 - 12] Fixed income - Engagement [FI 14 - 16] Outputs and outcomes [FI 17 - 18]

Confidence building measures

Confidence building measures [CM1 01 - 07]

Export Public Responses

You are in Direct - Listed Equity Active Ownership » (Proxy) voting and shareholder resolutions

(Proxy) voting and shareholder resolutions

LEA 12. Typical approach to (proxy) voting decisions

12.1. Indicate how you typically make your (proxy) voting decisions.

Approach

We use our own research or voting team and make voting decisions without the use of service providers.

Based on

Our own voting policy

Our clients` requests or policies

Other (explain)

We hire service providers who make voting recommendations and/or provide research that we use to guide our voting decisions.

We hire service providers who make voting decisions on our behalf, except in some pre-defined scenarios where we review and make voting decisions.

We hire service providers who make voting decisions on our behalf.

12.2. Provide an overview of how you ensure that your agreed-upon voting policy is adhered to, giving details of your approach when exceptions to the policy are made.

Voting requires authorisation/poa from the CIO. In the case of possibly controversial issues, voting would at least be cleared by the CIO and possibly by the CEO or the board.

12.3. Additional information.[Optional]

Voting generally follows a discussion with the CIO or the ethics committee.

LEA 13. Percentage of voting recommendations reviewed (Not Applicable)

LEA 14. Securities lending programme (Private)

LEA 15. Informing companies of the rationale of abstaining/voting against management

15.1. Indicate the proportion of votes participated in within the reporting year in which where you or the service providers acting on your behalf raised concerns with companies ahead of voting.

100%

99-75%

74-50%

49-25%

24-1%

Neither we nor our service provider(s) raise concerns with companies ahead of voting

15.2. Indicate the reasons for raising your concerns with these companies ahead of voting.

Vote(s) concerned selected markets

Vote(s) concerned selected sectors

Vote(s) concerned certain ESG issues

Vote(s) concerned companies exposed to controversy on specific ESG issues

Vote(s) concerned significant shareholdings

Client request

Other

15.3. Additional information. [Optional]

We would be doing a poor job if our vote came as a surprise. In general, we would expect it to be cast after preceding dialogue.

LEA 16. Informing companies of the rationale of abstaining/voting against management

16.1. Indicate the proportion of votes where you, and/or the service provider(s) acting on your behalf, communicated the rationale to companies for abstaining or voting against management recommendations. Indicate this as a percentage out of all eligible votes.

100%

99-75%

74-50%

49-25%

24-1%

We do not communicate the rationale to companies

Not applicable because we and/or our service providers did not abstain or vote against management recommendations

16.2. Indicate the reasons why your organisation would communicate to companies, the rationale for abstaining or voting against management recommendations.

Vote(s) concern selected markets

Vote(s) concern selected sectors

Vote(s) concern certain ESG issues

Vote(s) concern companies exposed to controversy on specific ESG issues

Vote(s) concern significant shareholdings

Client request

Other

16.3. In cases where your organisation does communicate the rationale for abstaining or voting against management recommendations, indicate whether this rationale is made public.

Yes

16.4. Additional information. [Optional]

We have no policy of formally flagging our voting intentions ahead of the vote. On the other hand, it is not precluded. Would be judged on a case-by-case basis.

LEA 17. Percentage of (proxy) votes cast

17.1. For listed equities in which you or your service provider have the mandate to issue (proxy) voting instructions, indicate the percentage of votes cast during the reporting year.

We do track or collect this information

We do not track or collect this information

17.2. Explain your reason(s) for not voting on certain holdings

Shares were blocked

Notice, ballots or materials not received on time

Missed deadline

Geographical restrictions (non-home market)

Cost

Conflicts of interest

Holdings deemed too small

Administrative impediments (e.g., power of attorney requirements, ineligibility due to participation in share placement)

Client request

Other (explain)

Issues of limited materiality, like approving ok accounts in a small holding. As for administrative impediments, it is sometimes exceedingly cumbersome to vote in foreign countries.

17.3. Additional information. [Optional]

We limit our voting to issues of some presumed importance and do not count all issues on the table.

LEA 18. Proportion of ballot items that were for/against/abstentions

18.1. Indicate whether you track the voting instructions that you or your service provider on your behalf have issued.

Yes, we track this information

18.2. Of the voting instructions that you and/or third parties on your behalf have issued, indicate the proportion of ballot items that were:

Voting instructions	Breakdown as percentage of votes cast
For (supporting) management recommendations	75 %
Against (opposing) management recommendations	25 %
Abstentions	0 %

100%

No, we do not track this information

18.3. In cases where your organisation voted against management recommendations, indicate the percentage of companies which you have engaged.

18.4. Additional information. [Optional]

Votes would never be cast without preceding discussions with the portfolio managers, so there is no need to communicate our votes to them. We don't track these votes in terms of percentages, so the above percentages are rough approximations. In cases where we vote against management recommendations, we may nevertheless cast votes in favor of, say, approving the accounts.

LEA 19. Proportion of ballot items that were for/against/abstentions

19.1. Indicate whether your organisation has a formal escalation strategy following unsuccessful voting.

Yes

19.3. Additional information. [Optional]

We are not likely to give up after a negative response, but we have no board-approved guidelines for escalation.

LEA 20. Shareholder resolutions (Private)

LEA 21. Examples of (proxy) voting activities (Private)

Previous Section Next Section