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Service Providers Framework 2019

You are in Strategy and Governance » Policy on ESG beliefs

Policy on ESG beliefs

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.

As a consulting firm we have implemented several actions to develop ESG factors within our organisation :

Social :

- hability to become a shareholder of the company for employee with a discount,

- equity in term of gender salary for a same level ofepsonsability

- no short term contracts, we tend to hire our employees with permanent contracts

- employees are able to benefit from the firm growth with an attractive pension plan (third pillar)



- Recycled paper only

- printing counter

- use of public transportations whenever possible



-  employees representatives elections and regular meeting organisation to exchange about the firm strategy

- separate managing director and president roles

- external accounting and auditing


The link to our business offering is to make our consultants and employees aware of the ESG philosophy and make them proactive in advising our clients on their ESG policy implementation

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

01.5. Additional information [OPTIONAL]

In process

SG 02. Norms used to develop policies (Not Applicable)

SG 03. Policy offerings to clients

03.1. 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
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

03.2. Provide a brief description of the key elements, any variations, or exceptions applying to these policies.

Our clients (institutional investors)  have their own policies regarding those themes. 

We produce a lot of teaching materials towards our clients trustees about ESG standards, issues, and regulation.

We advise some of our client regarding those processes, in defining their own tailored policies regarding their environnement (industry, regional, trustees, objectives...)but also in monitoring the impact of the policies on their portfolios.


03.3. Additional information. [OPTIONAL]

SG 04. ESG/RI in business offerings

04.1. Briefly describe how you include ESG/RI factors as part of your business offerings.

Business area


How you include ESG/RI factors

We use MSCI ESG Research as database, informations and analysis.

In terms of monitoring and reporting, we analyse our clients portfolios on the themes defined in their policies, on a security by security basis.

The output and information for our clients and our consultants, is more used to monitor the evolution of their ESG portfolios ratings than an analysis on an absolute basis. As  the majority of our clients delegate the management of their portfolios to assets managers, this information and ESG reporting is used to challenged the managers regarding the implementation of the investor policies. 

The objective of those reporting is mainly to analyse the impact of the investor  ESG and RI policies on their portfolio and the sensitivity to ESG factors.

Investment Consultancy

How you include ESG/RI factors

We help our client in defining their own policy and their own ESG strategy, within the several strategy's and action possible (exclusion, best in class, climate impact, voting ...).

We then implement their policy in their portfolio in redefining their investment management delegation mandates. 

We also use ESG criteria and factor to help client hedging specific risk.

04.2. Indicate the roles in your organisation, and indicate for each whether they have oversight and/or implementation responsibilities for ESG/RI within the organisation.

Roles present in your organisation
Oversight/accountability for ESG/RI
Implementation of ESG/RI
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Chief Operating Officer (COO), Chief Information Officer (CIO)
Other chief-level staff

Please specify

          Head of reporting
Other heads of department
Dedicated ESG/RI staff
Other role, specify (1)
Other role, specify (2)
Other role, specify (3)
None of the above

04.3. Indicate how you ensure ESG/RI expertise for the roles where there are RI oversight/accountability or implementation responsibilities.

          Access to MSCI ESG Research Database for our consultants

04.4. Indicate whether your organisation has any ESG/RI linked incentives for its employees.

04.7. Additional information [OPTIONAL]

SG 05. Outsourcing of services (Private)

SG 06. Providing training/education

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

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

ESG/RI educational services :

- Reguulation

- Market standards

- Definition of the different component

- Defining policies on those themes

- How to implement and monitor ESG RI policies

-Opportunities and threats


The training is more operational for executive training and more top down for trustess training.

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

          We are regulated by the French Governement and we are not allowed to include commercial elements.

06.4. Additional information. [OPTIONAL]

SG 07. Applying, advancing and promoting the PRI principles

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

All our marketing documents include the fact that we are signatory of the PRI Principles and we include these principles in our training for our staff and clients

Furthermore we promote to our client the importance of singing the PRI, why, what is the benefit, and how they can contribute.

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

SG 08. Actions taken to promote responsible investment

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

8.2. Additional information. [OPTIONAL]

We finance a research chair which is regularly working on ESG / RI and impact of ESG / RI policies on portfolio risk and returns.

SG 09. Long term trends

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

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

When the carbon impact of a portfolio has been analysed, we try to implement actions to decrease this carbon impact with several strategies.

- Asking the investment manager to decrease the impact with a low carbon approach

- investing on green infrastructures/bonds

- Giving objective of carbon impact in the investor policy

SG 10. Interaction with asset owners

10.1. Indicate whether you interact with asset owner clients.

10.2. Indicate the typical frequency and type of interactions with your asset owner clients.

Type of interaction






10.3. Additional information. [OPTIONAL]

SG 11. Aligning approach with investor goals

11.1. Describe how you typically align your organisation’s philosophy and approach to ESG/RI with your investor clients’ goals.

11.2. Additional information. [OPTIONAL]

SG 12. ESG recommendations not aligned with investor goals

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

12.2. Additional information. [OPTIONAL]

SG 13. Seeking feedback from clients

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

13.3. If not, please explain why.

We do not offer products as we do not directly manage assets. We advise directly our clients tin defining their financial strategy including ESG policy. 

SG 14. Managing conflicts of interest

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

14.2. Describe how you manage potential conflicts of interest.

Independance and no potential conflict of interest are in the DNA of our organisation.

We have a strict conflicts of interest policy. 

We do not have to manage conflict of interest as our organisation is totally independent and we only have contracts with our asset owners clients.

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

We work on a strategic level and our employee could not derive any personal gain from the informations. Furthermore, only our consultants in relation with the clients have access to clients data throught a very strict confidential policy.

14.4. Additional information. [OPTIONAL]