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Trecento

PRI reporting framework 2020

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You are in Direct - Listed Equity Incorporation » ESG incorporation in actively managed listed equities » Implementation processes » (A) Implementation: Screening

(A) Implementation: Screening

LEI 04. Types of screening applied

04.1. Indicate and describe the type of screening you apply to your internally managed active listed equities.

Type of screening

Screened by

Description

Exclusion from our SRI investment universe of listed issuers when their core activity is, according to Trecento AM, incompatible with the principles of socially responsible investment. On its website (http://www.trecento-am.com), Trecento AM releases the list of sectors and issuers included in this negative exclusion policy, as well as information and details on the choice of organisations we have deemed relevant as a source for this exclusion policy.

Screened by

Description

Exclusion from our SRI investment universe of listed issuers that do not comply with international norms, including the 10 Principles of the the United Nations Global Compact, the Universal Declaration of Human Rights, the ILO Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development and the United Nations Convention Against Corruption.

On its website (http://www.trecento-am.com), Trecento AM releases the list of sectors and issuers included in this norms-based exclusion policy, as well as information and details on the choice of organisations we have deemed relevant as a source for this exclusion policy.

04.2. Describe how you notify clients and/or beneficiaries when changes are made to your screening criteria.

Clients/beneficiaries are notified of changes made to our screening criteria through several ways:

- We update our publicly available exclusion policy and ESG incorporation policy on a regular basis and the up-to-date version of the policies is available on our website.

- If the modifications are sufficient enough to amend our investment process, then we need to update the legal documentation of the funds (prospectus) and inform all our clients / beneficiaries through a detailed letter to unit holders. We usually also send a newsletter to your clients to inform them of the modifications.


LEI 05. Processes to ensure screening is based on robust analysis

05.1. Indicate which processes your organisation uses to ensure ESG screening is based on robust analysis.

05.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your ESG screening strategy.

05.3. Indicate how frequently third party ESG ratings are updated for screening purposes.

05.4. Indicate how frequently you review internal research that builds your ESG screens.

05.5. Additional information. [Optional]

Trecento AM has set up an ESG committee that includes all its fund managers (of which the CEO and CIO) and (extra-)financial analysts. The ESG committee implements and monitors the responsible investment policies of the management company. In this role, it ensures that the ESG incorporation and analysis models are audited and controlled (by the compliance officer and its delegates), are updated and implemented according to the rules and processes described in the publicly available RI policies of the company and to the legal documentation of the investment funds.

As regard ESG screening, the ESG committee ensures that the third parties which provide information for the exclusion lists or ESG ratings/scores of the investment universes of the funds are relevant and have regularly updated their information. It then controls that the subsequent data, analysis or synthesis realised by our internal staff based on this information is accurate and robust.


LEI 06. Processes to ensure fund criteria are not breached

06.1. Indicate which processes your organisation uses to ensure fund criteria are not breached.

06.2. If breaches of fund screening criteria are identified, describe the process followed to correct those breaches.

If breaches of fund screening criteria were to be identified, by an analyst, fund manager, compliance officer, the CIO/CEO or the ESG committee, then a compliance alert would be issued to the fund manager in charge of the fund. This fund manager would have a maximum time period of one month to liquidate the controversial position. 

06.3. Additional information. [Optional]


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