This report shows public data only. Is this your organisation? If so, login here to view your full report.

Prometeia Advisor Sim

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.

Prometeia Advisor Sim is an independent financial consulting firm whose core business is advising institutional clients in managing their assets. 

Prometeia is a fully owned subsidiary of the Prometeia Group, with 800 employees and offices in Italy and abroad (Instanbul, Moscow, London and Cairo).

Prometeia Advisor Sim embraces the UN Principles for Responsible Investment (UNPRI) since May 2015.

Prometeia Group adheres to the Forum per la Finanza Sostenibile (Sustainable Finance Forum) since February 2016.

Prometeia Advisor Sim takes part on Italian Observatory for Sustainable Finance (OIFS) since November 2017.

Prometeia Group has joined the UN Global Compact in October 2018.

In 2018 the Group asked EcoVadis to evaluate his corporate social responsability. EcoVadis is one of the most important international companies in corporate sustainability ratings and monitors twenty-one criteria grouped into four macro-themes: environment, fair labor & human rights, ethics, and sustainable procurement. Among the consulting companies, Prometeia is ranked in the 30% top performers. 

As the leading investment consultant firm in Italy, in Prometeia Advisor Sim (Prometeia) we recognize the strategic relevance of our position in pursuing long-term value creation for our clients and the moral obligation of advicing the adoption and implementation of sustainable investment among institutional investors.

Prometeia's mission is to guide institutional clients to long-term value creation, not only by avoiding market risks but also by identifying investment opportunities in line with clients goals and mission. In accordance with its mission, Prometeia is committed to advising on SRI themes and offering integrated sustainable solutions to fulfill clients necessity. 

Prometeia provides solutions to the challenges of sustainable development, we embedded sustainability in our operations and promote it throughout our services. However, it must be considered that the final choice is always up to the client. 

At Prometeia, sustainability has a double application: it can be seen as corporate sustainability and as investment advisory sustainability. Prometeia promotes since a long time sustainable development in all its operations and activities. It is from our corporate vision that we establish investment objectives, set goals and action plans that will also have an influence on sustainable advisory. Here some direct sustainable achievements: reducing CO2 emissions, reducing paper use, reducing waste, reducing energy consumption, employees wellbeing, corporate welfare, diversity inclusion. We have a long-standing commitment to incorporating sustainable factors into the investment process. This commitment is outlined in our sustainable policy and is guided by international sustainability principles and best practices. Our first selection of sustainable mandate was in June 2008.

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

01.3. Indicate the components/types of your internal policy and provide the URL and/or an attachment of the document/s if they are publicly available.

Policy components/types

Public availability

Public availability

01.4. Indicate how these are put into practice internally across the organisation.

01.5. Additional information [OPTIONAL]

Policy and integrated sustainable methodology framework on specific services are not publicly available in order to protect Prometeia's competitives advantages. 


SG 02. Norms used to develop policies

02.1. Indicate what frameworks and guidelines you have used to develop your organisation’s policies. Tick all that apply.

02.2. Additional information. [OPTIONAL]

All Prometeia policy and guidelines are inspired by international best practices and are in compliance with European Regulations. 



 


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
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

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

Prometeia has set sustainable investment standards in accordance with different strategies as identified by the UNPRI: Negative/exclusionary, Norms-based, Positive/best in class, Sustainability themed investing, Integration of ESG issues, Active ownership and engagement. 

The application of the strategies slightly differs in relation to asset class and sectors. As well, all strategies are not standing alone ideas but can be combined in a more comprehensive and complex approach.  

In assisting clients toward the adoption of sustainable portfolios, Prometeia also offers support for policy and guidelines construction. Typically this service requires a high level of interaction with the clients to better identify the scope of the policy and its compliance with regulatory requirements. 

In addition to off the shelf standards previously mentioned, Prometeia offers tailored versions of sustainability strategic allocation and other services to better accomplish client's investment objectives. One client's asset allocation, for example, will never be alike to another one in terms of sustainable themes, asset class and risk exposure. 

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

Investment Consultancy

How you include ESG/RI factors

Prometeia's commitment to sustainability goes beyond offering sustainable advisory solutions as it is an embedded responsability that we pursue in all our activities and services. 

Prometeia believes that sustainable investment is a powerful keystone to achieving sustainable development.

Sustainability is embedded into the investment decision process at all its stages: macro consideration, market analysis, corporate analysis, screening of the investment universe, portfolio management selection, asset allocation and risk control. 

The world is facing new challenges like climate change, wealth inequalities, data security, resource scarcity that can powerfully influence performance over time. We believe it is our fiduciary duty to map all risks and opportunities associated with an investment. We want to deeply understand the interconnection between factors and how this may affect investment performance. 

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
Board
Directors
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Chief Operating Officer (COO), Chief Information Officer (CIO)
Other chief-level staff
Other heads of department

Please specify

          Heads of Consulting, Head of fund selection, Head of risk management
        
Dedicated ESG/RI staff
Other role, specify (1)

Please specify

          Analysts
        
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.

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

04.5. Describe the ESG/RI linked incentives.

The CEO oversees the SRI team that is managed by an SRI specialist who is in charge of coordinating all the team members.

All team members work in different departments reinforcing the idea that sustainability is not a stand-alone practice.

The team’s aim is to work across functions while implementing Prometeia sustainable commitments through a structured managing process. 

Part of the team members annual performance and remuneration rewards are evaluated on the matter of Sustainability achievements. In addition, the participation of managers and directors to external conferences, working groups and category association meetings is highly encouraged as a valid approach to training and as a way of sharing our experience and contributing on the making of fast-evolving best practices. 

We encourage everyone to take part in the success of the Sustainable Development Goals of the United Nations. Beside distributing the lazy guide to SDGs, we hope to build our own guide based on how everyday corporate endeavors of our employees can become part of the change. All employees will report on specific sustainable performance indicators and we will reward those who have actively participated in the challenge and remarkably improved their performance over time. 

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.

Internal training on Sustainability takes place for the team members and targeted groups of employees on specific occurrences. In 2017 external resources had been reached for training employees on sustainable investment strategies and operational sustainability. In 2018 all employees took an online ESG course, which has been accredited to the highest educational standard. At the end of the training, the employees have received a certificate they can store within their curriculum vitae.

We have internally published and shares numerous studies on the issue, building awareness among our teams and clients.

In addition, the partecipation of team members, managers and directors to external conferences, working groups and category association meetings is highly encouraged as a valid approach to training and as a way of sharing our experience and contributing to the making of quickly evolving practices. 
We right and publish our experience and new ideas on responsible investment in our newsletter Anteo and whenever we are called to contribute to external articles. 

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

          Yes, some of the conferences also include commercial elements, even this aspect is fundamental to our activities: we need to be always up to date on products and strategies of asset managers and other financial institutions.
        

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.

PRINCIPLE 1 - WE WILL INCORPORATE ESG ISSUES INTO INVESTMENT ANALYSIS AND DECISION-MAKING PROCESSES.

Sustainability is embedded into the investment decision process at all its stages: macro consideration, market analysis, corporate analysis, screening of the investment universe, portfolio management selection, asset allocation and risk control. 

PRINCIPLE 2 - WE WILL BE ACTIVE OWNERS AND INCORPORATE ESG ISSUES INTO OUR OWNERSHIP POLICIES AND PRACTICES.

All our policy and guidelines are inspired by international best practices and are in compliance with European Regulations. Following the UN Global Compact 10 Principles, Prometeia corporate sustainability relies on: the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, and the United Nations Convention Against Corruption. Prometeia will set objectives and goals every year to reduce its footprint and improve its positive impact. 

PRINCIPLE 3 - WE WILL SEEK APPROPRIATE DISCLOSURE ON ESG ISSUES BY THE ENTITIES IN WHICH WE INVEST.

Prometeia has developed a proprietary framework to analyze the sustainability of asset managers, investment funds and issuers. In addition, the firm constantly engages with all financial institutions to implement transparency within the industry. 

PRINCIPLE 4 - WE WILL PROMOTE ACCEPTANCE AND IMPLEMENTATION OF THE PRINCIPLES WITHIN THE INVESTMENT INDUSTRY.

Prometeia systematically promotes the inclusion of the UNPRI's considerations into investment decision making to clients. We have internally published and shared numerous studies on sustainable investment, building awareness among clients. We sponsor events and conference on the issue and we train our employees. We organize SRI focus on our training InFormazione we conduct every year with all our clients.

PRINCIPLE 5 - WE WILL WORK TOGETHER TO ENHANCE OUR EFFECTIVENESS IN IMPLEMENTING THE PRINCIPLES.

The participation of employees, manager and directors to external conferences, working groups and category association meetings is highly encouraged as a valid approach to training while actively contributing with our own experience on the making of fast-evolving best practices. 

PRINCIPLE 6 - WE WILL EACH REPORT ON OUR ACTIVITIES AND PROGRESS TOWARDS IMPLEMENTING THE PRINCIPLES.

Prometeia reports its responsible investment achievement and development yearly on its sustainability report. In addition, as part of Prometeia Group, it publishes a sustainability report aligned with GRI framework.

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]


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.

The world is facing new challenges like climate change, wealth inequalities, data security, resource scarcity that can powerfully influence performance over time. We believe it is our duty to map all risks and opportunities associated with an investment. We want to deeply understand the interconnection between factors and how this may affect investment performance. That is why we integrate sustainable themes in our research and analysis.

At the same time we want to align the mission of our clients to their investment goals, therefore we provide tailor-made investment advisory solution satisfying their needs.

Our asset allocation committee defines investments views every month, which will be applied to each investment advisory with a tailored approach. One client advisory will never be alike to another client advisory in term of asset allocation, asset class, risk and sustainable theme exposure. 

We offer clients macro and financial views for short and long term scenario, we study sustainable trends and analyze how those trends relates to the client's portfolios. But it is up to clients to choose what matters the most to them. 

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

Please see 9.1

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

Please see 9.1

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

Please see 9.1

          please see below
        

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

Our sustainable themes:

  1. access to services: healthcare, education, finance
  2. food and agriculture
  3. buildings and infrastructure
  4. wealth inequalities
  5. data security and technology
  6. demographic changes
  7. climate change
  8. resources' scarcity

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

Frequency

          normally monthly, but often ad-hoc basis
        

Frequency

Frequency

Frequency

Frequency

10.3. Additional information. [OPTIONAL]

We strongly believe in building a trustworthy relationship with clients. 

Thanks to highly skilled professionals with deep knowledge of the reference market, our teams usually build a relationship that lasts for many years.

By constantly talking to clients, we optimize our contribution to assuring the greatest achievement. Always being updated on clients activities allow us to have a broad vision on the investment advisory and clients investment development. 


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.

In accordance with its mission, Prometeia is committed to advising on responsible investment, offering integrated sustainable solutions to fulfill clients necessity. We want to align the mission of our clients to their investment goals, therefore we provide tailor-made investment advisory solution satisfying their needs. 

Through a careful dialogue, we define together with the client the objectives of sustainability, risk, and return of the portfolio. Once established them, it is possible for us to combine the client’s specific needs and sustainable vision with the current and coming portfolio’s asset allocation.

11.2. Additional information. [OPTIONAL]

For example, more and more often institutional investors are willing to know green bonds and invest. 

We provide evidence that investing in a green bond is just like investing in a 'normal' bond from a financial perspective but in addition, it generates also a positive impact on the environment. Some clients are fascinated by these new instruments and want to know all the details about their investment. Green bonds allow great transparency and thanks to the green bond report we are able to provide supportive evidence of the environmental impact generated through the investment. Not all green bonds are the same in terms of the investment objectives, and we try to align the use of proceeds that best fits with the client's mission. 


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.

The interest of asset owners in integrating responsible and sustainable considerations into their portfolios is fastly growing. We rarely encounter rejection, perhaps more often perplexity that sustainable finance can be consistent with client financial objectives and responsible values. We believe this is due to the fact that only recently sustainable investment products have been developed in all asset classes with a positive integration of market opportunity approach rather than an ethical exclusion. This change in the portfolio manager mindset is not yet fully being perceived by asset owners. Therefore asset owners still think of sustainability as an ethical exclusion with a lower financial return. When we encounter this situation, we provide further information and educational insights on sustainable investment to our clients.

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

13.2. Describe how you use this feedback in your RI/ESG services and product offerings.

We value client satisfaction as the cornerstone of our success.

Annually we ask clients to complete a questionnaire of advisory satisfaction on:

  1. service quality
  2. respect of deadline 
  3. team availability and professional capabilities
  4. the effectiveness of operational support

We want to know how our clients evaluate our performance and what we can improve on. Our aim is to keep improving by implementing clients' feedback and adjusting our approach to clients' demand.


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.

In our conflict of interests policy, we identify those conflicts of interest that could arise with clients or among clients. In the policy, we refer to both the process of identifying possible conflicts and to the adequacy of the measures adopted to prevent them. In fact, we have developed a management policy system to better prevent and handle conflicts. If a conflict occurs and the adopted measures are not sufficient to ensure, with reasonable certainty, that the risk of damaging the client's interests is avoided, we promptly provide detailed disclosure to the client. 
Policy revision is carried out annually. Any policy change is promptly notified to all our employees and 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 have set up organizational procedures and operational safeguards aimed at preventing and handling the occurrence of conflicts of interest. 
All employees in charge of providing services to clients have the obligation to promptly communicate any situation that may generate, even potentially, in a new conflict of interest to their direct manager and to the compliance department. 
Since a long time all employees are required to act honoring the Code of Ethics, the Code of Conduct and the Model of Organization, Management and Control aligned with Legislative Decree no. 231/2001. 

 

14.4. Additional information. [OPTIONAL]


Top