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Pennam Partners (Delisted)

Service Providers Framework 2018

You are in Strategy and Governance » Responsible investment policy

Responsible investment policy

SG 01. Responsible investment policy

01.1. Describe how your organisation’s philosophy incorporates environmental, social and governance factors, and the link to your business offerings.

In a nutshell, Pennam Partners provides financing-related advisory services both for local and offshore entities.  We have a predominant focus on delivering internal projects as well as servicing external clients.  As part of our offering we tend to pursue mandates that have an alignment with sustainable development goals and also putting emphasis on responsible finance. 



01.2. Indicate whether you have internal policies that formalise the incorporation of your beliefs in your business offerings.

01.5. Additional information [OPTIONAL]

SG 02. Publically available policies (Not Applicable)

SG 03. Norms used to develop policies (Not Applicable)

SG 04. Policy offerings to clients

04.1. Indicate whether you offer standard, off the shelf, policies to clients as part of your product offerings, and/or whether you create tailored versions for individual clients.

Off the shelf Tailored
Asset class-specific RI guidelines
Sector-specific RI guidelines
Screening/exclusions policy
Engagement policy
(Proxy) voting policy
RI guidelines set out within the Investment Policy Statement (IPS)
RI guidelines set out in a freestanding RI policy
Multi-year RI implementation project plan
Conflict of interest management policy
Stockbroker allocation policy
Securities lending policy
Other, please specify (1)
Other, please specify (2)
Other, please specify (3)
None of the above

04.3. Additional information. [OPTIONAL]

SG 05. ESG/RI in business offerings (Not Applicable)

SG 06. Outsourcing of services (Private)

SG 07. Providing training/education

07.1. Indicate whether you provide training/educational services on ESG/RI. Tick all that apply.

          Investment related training for underlying investee firms (sell-side) with focus on sustainable development goals.

07.2. Describe the main components of your training/educational services on ESG/RI and any variations depending on the group you provide training/education to.

No further disclosure to be made.

07.3. Describe whether these training/educational services include any commercial elements.


07.4. Additional information. [OPTIONAL]

SG 08. Applying, advancing and promoting the PRI principles

08.1. Describe how your organisation applies, advances and promotes the PRI Principles.

As previously stated, Pennam Partners operates in the financing-related advisory services and it works predominantly on its internal mandates as well as servicing external clients.  Some of our mandates contain both financial and non-financial drivers (including ESG) and are geared towards the sustainable development goals (including mandates specifically targeting investee firms that are heavily promoting and activly contributing towards ESG in their local jurisdictions) and ensuring that are appropriately meeting the buy-side impact investment thesis.

In addition, we have to ensure that these investee firms are properly measuring and accounting for their ESG contributions to ensure the buy-side parties can appropriately measure the SROI.

08.2. Highlight whether there are any ways that your organisation would like to engage further with the PRI. [OPTIONAL]

SG 09. Actions taken to promote responsible investment

9.1. Indicate which of the following actions your organisation has taken to promote responsible investments during the reporting year, independently of collaborative initiatives.

9.2. Additional information. [OPTIONAL]

SG 10. Long term trends

10.1. Indicate which of the following long-term trends are addressed in your product outputs.

10.2. Explain how this long-term trend affects your product outputs.

No further disclosure to be made.

10.4. Additional information. [OPTIONAL]

SG 11. Interaction with asset owners

11.1. Indicate whether you interact with asset owner clients.

11.3. Additional information. [OPTIONAL]

SG 12. Aligning approach with investor goals

12.1. Describe how you align your organisation’s philosophy on and approach to ESG/RI with investor goals.

Part of the investor base that we service has an impact investment mandate looking to invest in opportunities that deliver positive social and environmental impact alongside a financial return.  This allows us to be pro-active in putting our philosophy into practice by servicing buy-side parties that are ESG/RI aligned while concurrently identifying and nurturing investee firms that are (or can become) a right investment fit for the buy-side parties both from a financial and non-financial perspective giving the buy-side parties the comfort that they may be able to generate their intended SROI from the underlying investments. 

12.2. Additional information. [OPTIONAL]

SG 13. ESG recommendations not aligned with investor goals

13.1. Describe what steps you take, if any, when your ESG recommendations are not in line with investor goals.

13.2. Additional information. [OPTIONAL]

SG 14. Seeking feedback from clients

14.1. Indicate whether you seek feedback from clients on your RI/ESG services and product offerings

14.3. If not, please explain why.

No further disclosure to be made.

14.4. Additional information. [OPTIONAL]

SG 15. Managing conflicts of interest

15.1. Indicate whether your organisation has a policy for managing potential conflicts of interest.

15.2. Describe how you manage potential conflicts of interest.

1) There is a mandatory, contractual-based, internal disclosure required for any of our mandates.  Employees and contractors are required to disclose any actual, perceived or potential conflict of interest.  If there is a negative disclosure, an assessment is made whether such conflict is material in nature and whether this can be mitigated.  If it cannot be mitigated, then the servicing party is withdrawn from the assignment.

2) There is a 2-tier servicing process, which ensures that any final sign-off on an assignment is subject to a peer review by directors and approval to ensure, among other things, any undetected conflict of interest is minimised.  Sometimes, for certain assignments, third party reviewers are also called upon to maintain the integrity of the process.

15.3. Describe how you ensure that company employees do not derive any personal gain from the use of information collected during your work process.

1) Contractually, all rights (including moral rights) are vested in Pennam Partners.

2) Practically, employees and contractors have limited access to highly sensitive information and there is a disaggregation of data to ensure that employees and contractors do not have access to the full and complete information gathered/produced during an assignment.


15.4. Additional information. [OPTIONAL]