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ClearlySo (Delisted)

Service Providers Framework 2020

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.

ClearlySo's vision is a world where the financial system is a powerful force for good and the impacts of businesses are considered in all investment decisions.

It is our mission to bring impact as the third dimension into investing.

We want all investors to consider the impact of their investment decisions. This will create an environment for entrepreneurs and businesses that make a difference to thrive.

Our values are embodied by our people and in the way we work. We seek to be a different type of organisation that constantly challenges the status quo, finding new and different ways to innovate and grow the market.

ClearlySo offers services both entrepreneurs and investors. Below are the links to our business offerings:

  • Raising capital for entrepreneurs and impact investment funds: https://www.clearlyso.com/raise-capital/ 
  • Investing capital: https://www.clearlyso.com/investors/
  • Assessing impact: https://www.clearlyso.com/atlas/ 

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.

          ClearlySo is a certified B Corp, meaning it goes through a rigorous assessment on social and environmental performance
        

01.5. Additional information [OPTIONAL]


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.

          B Lab: B Impact Ratings
        

02.2. Additional information. [OPTIONAL]


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

03.3. 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

ClearlySo only works with organisations that create a positive social and/or environmental impact. When working with organisations on an advisory/consultancy basis it will actively incorporate ESG/RI factors in the documentation produced and also in how opportunities are communicated.

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

Please specify

          CMO
Head of Enterprises
        
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.

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

04.6. Describe how you ensure that your employees incorporate ESG/RI into services through other mechanisms than ESG/RI linked incentives.

ClearlySo only works with organisations that create a positive social and/or environmental impact. 

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.

06.4. 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.

Through it's capital raising and impact assessment services ClearlySo actively encourages entrepreneurs and investors to consider impact in how they operate and in their investment decision making. In doing this, the business will refer to the PRI Principles.

The business also refers to it's UN PRI signatory status in marketing materials and website.

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

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

08.2. 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.

Some of ClearlySo's clients are focused on addressing issues arising from changing demographics (e.g. innovation in elderly care).

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

Some of ClearlySo's clients are focused on issues arising from climate change (e.g. renewable energy, reduced energy consumption)

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

Some of ClearlySo's clients have developed innovative business models using the circular economy at its core.

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

Some of ClearlySo's clients are actively developing new technologies to address the key social and environmental issues faced by society.


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

          Meetings with investment management teams
        

Frequency

          When there are live projects to work on with the asset owner
        
          Meetings with ESG/RI teams
        

Frequency

          When there are live projects to work on with the asset owner
        

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.

ClearlySo's core belief is that impact is the third dimenion in investment decisions (in addition to risk and return). The firm advocates that all investment decisions should be made considering impact.

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

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

We are always looking to improve and use the feedback from clients to enhance our services and product offerings. 


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.

Potential conflicts of interest are flagged to the firm's compliance officer, the CEO and relevant managers. Together, they determine whether there is a conflict and take any actions required to manage the conflict.

The firm has a set of policies and procedures put in place and we anticipate that we will identify most potential conflicts before they arise and deal with them in the following ways.

  • We have a conflicts committee, that meets regularly to discuss new and existing business and to try and identify potential conflicts of interest before they become an issue.
  • We maintain a conflicts register that logs all conflicts identified and details the action taken by the firm to resolve the conflict
  • If the conflict relates to a member of staff or their connected person and the client we can exclude the member of staff from dealing with that client.
  • If the conflict is between one of our clients and another we may decide that we cannot act for one of the clients or indeed both if the situation warranted it.. We would of course disclose this to them.
  • If the conflict arises between the firm and a client we will ensure the client has preferential treatment.
  • In most case we would hope to identify conflicts of interest before they become a conflict, however should we become aware of a conflict of interest after it has become a conflict we would of course disclose this to our client /s and ensure that they were not disadvantaged because of it.
  • Where we have identified a conflict of interest and cannot find a way to resolve it using the methods described above, as a last resort we would, disclose it to the client prior to undertaking investment business for them or, if we do not believe that disclosure is appropriate to manage the conflict, we may opt not to proceed with the transaction or matter giving rise to the conflict.

 

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.

ClearlySo has a detailed "Personal Account Dealing" policy that sets out restrictions which apply to dealing in financial instruments and other transactions entered into by officers and employees and consultants of the Company. This policy seeks to ensure that company employees do not derive any personal gain from the use of information collected during our work process.

Application of policy:

  • This policy applies to any dealing in financial instruments of the Company’s or its group company’s current, former and potential clients by or on behalf of the Company’s employees, relatives, officers and  consultants (where such consultants are engaged in relation to client matters or have access to confidential client information) to whom the Company’s compliance procedures apply. “Potential clients” in the preceding sentence includes only persons who the Company’s employee, officer or consultant is aware have a reasonable prospect of becoming a client of the Company or group companies of the Company (but if not so aware, the employee, consultant or officer might still be subject to this policy under 1.b below).
  • This policy also applies to other transactions entered by or on behalf of such persons where such transactions relate to matters on which such persons have non-public, confidential information obtained by virtue of their position with the Company which materially influences their decision to enter into, terminate, vary or execute an arrangement (or to refrain from doing any of the same).
  • Such restrictions also apply to connected persons of such persons, being: husbands, wives, civil partners, co-habitees, parents or step parents, children or  step children, partners or others with whom the person is in business with.

Prior to entering into any relevant transaction, a company employee shall notify the company's Compliance Officer as soon as practicable and shall - wherever practicable - meet with the Compliance Officer in person or by telephone to discuss the matter. The company employee shall refrain from entering into the relevant transaction until the Compliance Officer has approved such relevant transaction.

14.4. Additional information. [OPTIONAL]


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