EUROSIF SRI Transparency Code
2015
EXPERTISE IN SUSTAINABLE EUROPEAN EQUITIES – AUGUST
ESG-SRI Investment Strategy
of Petercam Institutional Asset Management
Individuals, organisations, companies and countries face a growing number of long-term
challenges. Economic growth cannot be sustainable if it is achieved at the expense of the
environment or social cohesion. Many global challenges relate to Environmental, Social and
Governance (ESG) themes such as global warming, ageing societies, demand for transparent
management… In addition, long-term profitability of companies can only be achieved by taking
into account the interest of various actors such as employees, clients, shareholders, service
providers, as well as broader society.
Petercam believes that integrating extra-financial data about how companies or countries
react to these challenges will add value to the investment process and will thus benefit the end
investor and society as a whole. Petercam is also convinced that incorporating sustainable
issues in its analysis improves the risk-reward relationship of its investments.
Petercam offers specialised ESG-SRI funds that select the companies or countries which optimally address global
ESG-SRI challenges.
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Petercam’s European equity investment process is built on a long experience in Sustainable & Responsible
Investment. The objective is to select the best performers with respect to ESG issues in the European equities
universe. This investment process is applied in the Petercam Equities Europe Sustainable fund.
The Sustainable Fixed Income investment process is the starting point for Petercam L Bonds Government
Sustainable and Petercam L Bonds Emerging Markets Sustainable. The former selects the OECD countries
which are the best positioned in terms of global ESG-SRI challenges. The latter ranks the emerging markets in
terms of global ESG-SRI challenges and invests depending on the ranking.
Both investment processes adopt a multi-dimensional, quantitative and objective best-in class approach.
Petercam adds value to the ESG-SRI investment and selection process by implementing a proprietary ESG-SRI filter,
based on the selection of the relevant indicators and the weights attributed to them.
With its ESG-SRI Fixed Income and Equities expertise Petercam targets a double alpha: alpha coming from the
construction of the sustainable eligible universe in addition to alpha generated by the investment process. Petercam
maximises expected return of a portfolio constructed within the sustainable investment universe.
In addition to offering dedicated ESG-SRI funds, Petercam aims to raise awareness of ESG-SRI challenges throughout
the whole company by excluding producers of anti-personnel mines and cluster ammunition in all its funds,
organising info-sessions on specific ESG-SRI topics, incorporating various relevant ESG issues in its corporate policy,
making buy-side analysts and fund managers aware of ESG-risks and including these aspects in the financial analysis
(equity and fixed income) framework.
Petercam signed the UN PRI (Principles for Responsible Investment) in September 2011 and is dedicated to
implementing the six principles. Petercam is also an active member of several national SIF that enable the financial
community and NGOs to share ideas and promote sustainable investment Furthermore, Petercam also has a formal
responsible voting policy for the investment funds managed within Petercam.
Petercam and its staff participate in various charity events. Petercam encourages the use of public transport for its
employees. Specialists of Petercam are often consulted by the media, even on subjects which are not directly linked
to its business. Petercam sees it as a service to the broad public to share its knowledge on specific topics. Finally, it
can be worthwhile to mention that Petercam also has developed Philanthropy services.
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The Petercam Responsible Investment Committee coordinates and initiates all these activities and processes. The
committee is a matrix organisation gathering ESG-SRI conscious and committed professionals from different
business lines within Petercam such as fund management, private banking, institutional sales, legal department,…
The committee is headed by the Head of Institutional Asset Management.
Section 1. Basic Details
1a. Provide the name of the fund management company managing the fund(s) to which this code
Apply
Petercam Institutional Asset Management SA/NV
1b. Describe the general approach of the fund management company with regards to how it takes environmental,
social and governance (ESG) criteria into consideration.
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Petercam launched its first sustainable strategy in European equities end 2002 on request from an
institutional investor. At that time Petercam decided to rely on the independent extra financial research
from Ethibel. In 2007 Petercam received the same request for a portfolio invested in euro sovereign bonds.
Given the lack of extra financial information regarding States, Petercam set up an Advisory Board to
develop an in-house ESG screening for the OECD Member States. This has led the company to consider ESG
in more general view. The ESG criteria are therefore used to inspire the corporate social responsibility
policy of the company, which is currently under construction.
Petercam signed the UNPRI in September 2011. In August 2012, Petercam appointed a fully dedicated SRI
Coordinator whose one of three main tasks is the implementation of the six principles of the UNPRI. The
answers to the PRI questionnaire are available for the reporting year 2013. By being part of collaborative
and dynamic global networks, Petercam gains access to a better understanding and knowledge of risks and
opportunities related to responsible investments.
o Petercam is member of several national SIF i.e. Belsif in Belgium, FIR in France, FNG for the German
speaking countries, Finanza sostenibile in Italy and Spainsif in Spain. Petercam’s commitment goes
further than its domestic market and as a token of its commitment to longer-term oriented and
sustainable finances, it is important to be engaged in different organisations, which share the
common objective towards a responsible finance for the future.
In keeping with Petercam’s approach to responsible investment, ESG integration is the result of a
collaborative discussion based on open and critically-minded permanent dialogue. The criteria used are
selected in close co-operation between financial and ESG analysts to ensure the best materiality. Selected
issues are discussed openly and compared against the analyst’s experience of the sector. This confrontation
aims to raise awareness among financial analysts of ESG risks and opportunities and explain the sector
challenges from both sides, i.e. financially and extra-financially and list questions and remarks for the
attention of the third-party provider sector analysts so as to ensure the optimal adequacy of the challenges
raised and the assigned material indicator.
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
Materiality of ESG criteria
Petercam focuses on criteria that could affect the core drivers and most important financial metrics of the
company.
In a first step, we identify
strategic
challenges
regarding ESG issues.
In a second step, the
approach is focused on
the materiality of ESG
issues i.e. identifying
medium-term risks and
opportunities and how the
companies or countries
are preparing to tackle the
challenges. We do not try
to identify all ESG criteria,
only those which may
have a material impact on
the sustainability of a
company’s activity and therefore its profitability and creation of shareholder value.

Holistic and transversal approach
The objective is to integrate ESG factors in the investment process, from research to final decision-making,
by integrating key factors in all asset classes.
The holistic approach also covers the integration of sectors which are inherently unsustainable and
considered as ESG-unfriendly, such as metals and mining or gas and oil.
Up to now, oil, gas and mining were necessary to economic development. Rather than adopting a negative
approach via exclusion - which could lead to distortions regarding sectorial underweighting and
overweighting - we prefer to apply a positive approach by looking for the leaders versus the laggards and
identifying organisations promoting best practices in their economic and social activity.

Sector specificities
ESG covers a wide range of issues. To be efficient and avoid a dilution of the signals ESG could give,
Petercam has defined key ESG issues that pertain to their particular industry. Within each sector and subsector, a number of specific sectorial criteria have been retained to reflect sector-specific drivers and
accurately identify the companies which are in a better position to face the challenges identified.
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EXPERTISE IN SUSTAINABLE EUROPEAN EQUITIES – AUGUST
Engaged Dialogue and promotion of Best Practices
Parallel to the UNPRI philosophy, the aim is to promote best practices in all sectors by privileging their
promotion and identifying leaders and laggards in the ESG field.
Company meetings are an opportunity to foster communication and are a way to assess the ESG
involvement of companies in which Petercam is investing or may invest.
During company meetings, the analyst and/or the portfolio manager raise pre-defined questions related to
ESG so as to identify material issues and engage with the company to encourage change.

Long-term approach and learning process
Integrating ESG factors in mainstream investment funds and research is a long-term and permanent
learning process. Petercam is adopting a dynamic and pro-active approach to improve its knowledge,
research process and methodology through discussion, debate and interconnectivity with external experts,
sector analysts, macro analysts and all involved parties.
The definition of key ESG factors per industry is reviewed regularly since they can evolve within the industry
and gain or lose importance in terms of their potential impact.
ESG criteria are an integral part of the voting policy of the group. This relies on four main principles among
which the third is related to ESG namely “Petercam adheres to the recommendations of the OECD in terms
of social and environmental responsibility of companies. Social, environmental and economic objectives
must be at the heart of the company’s targets and respecting them is the primary mission of the board of
directors of these companies. The board must be capable of assessing and understanding not only the
commercial and reputational impact of a company’s activities, but also their environmental and social
impact. In order to do so, the managers need to make sure that the procedures and required controls are
put in place to manage this impact. Petercam considers a company to be run in a responsible and
sustainable way when it is managed with respect of the applicable corporate governance rules, when the
interests of its human capital are central and not only considered as a cost center, and when it respects the
environment in which it operates globally.”
In line with its voting policy, Petercam has set up an engagement program, which is fully transparent. According
to this, it has defined specific cases it will engage with the company. The Voting Policy Committee has
committed to engage systematically with the companies in the following cases:
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In case of technical issues regarding appointment or re-election of a member of the Board, Petercam
however votes favourably but the company management is encouraged for greater information and
transparency in conformity with our main objectives
In case of Board independency issue, Petercam IAM abstains the first year as the theoretical equitable
allocation can be disputable in practice but the company management is encouraged to improve the
independency of its various boards and relevant committees
In case of poison pills, the given voting instruction is opposed to any proposal which may reduce
minority shareholders’ rights. In the same philosophy, Petercam IAM considers that multiple voting
share classes are not in the best interest of shareholders and is a defender of “one share, one vote, one
dividend” principle. The company management is informed of our decision and is encouraged to avoid
such situation and to take corrective measures.
As a shareholder and economic actor, Petercam bears a social responsibility. By means of its voting policy, it
influences the companies it invests in to ensure they are managed according to best practices in terms of
responsible investment. Petercam makes sure the rights of shareholder are respected, but also those of
other stakeholders. The voting policy fully discloses Petercam’s vision on corporate governance within listed
companies, its expectations as well as its approach as a responsible investor. The four principles governing
our voting policy are the following:
1. protection of shareholders;
2. sound corporate governance;
3. transparency and integrity of information and;
4. social and environmental responsibility.
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1c. Describe/list your SRI products and the specific resources allocated to your SRI activities.
 Petercam is currently managing four specifically SRI strategies: Petercam Equities Europe Sustainable and
Petercam Equities World Sustainable on the equity side and Petercam L Bonds Government Sustainable
and Petercam L Bonds Emerging Markets Sustainable on the fixed income side.
o The objective is to promote those strategies and to enlarge the offer to fixed income global equity
and to corporate bond strategies.
1. Petercam Equities Europe Sustainable
o The sub fund invests in shares of European companies that meet certain ethical, economic, social
and ecological criteria. The extra-financial information is provided by an independent extra
financial information agency. The RI Committee, independently of the asset management team,
determines the SRI and ESG criteria and their respective weighting to which the European and
equivalent companies have to comply to enter the investment universe. The criteria and weighting
are reviewed on a yearly basis. The eligible universe is reviewed on a monthly basis.
2. Petercam L Bonds Government Sustainable
o The sub-fund invests in euro-denominated government bonds issued by OECD Member States,
selected as the most sustainable countries. The eligible universe is based on SRI criteria regarding
transparency & democracy, environment, education, health care & wealth distribution and
economy. The sustainability screening is in-house developed based on 55 criteria. The criteria and
the weighting are decided upon by the Fixed Income SRI Advisory Board (FISAB). The FISAB gathers
three external specialists and three internal members and meets twice a year to review the model
and to approve the eligible universe.
3.Petercam L Bonds Emerging Markets Sustainable
o The sub-fund invests in sovereign debt instruments issued by emerging countries, mainly in local
currency debt, but investment in hard currency emerging bonds is allowed up to one third of the
portfolio. The investment universe is defined through a unique proprietary quantitative screening
model to assess the sustainability of emerging countries validated by an advisory board with
external experts. The SRI screening combined with the expertise of Petercam to invest in emerging
market bonds result in a highly diversified portfolio with an atypical country and currency
allocation. The objective is therefore double: to benefit from the evolution of local currency
emerging debt markets, taking into account the eligible universe as defined by the sustainability
screening model and to aim at generating "double alpha" i.e. combining positive contribution from
the sustainable process with outperformance from the financial management within the eligible
universe.
4.Petercam Equities World Sustainable
o

The strategy invests in worldwide equities, without any geographical restrictions, of companies
with a track record of 10 consecutive years of positive earnings and dividends. Selected on the
basis of economic and financial analysis as well as social, environmental and sustainable
development considerations, companies show a strong link to four key future trends:
infrastructure, demographics, energy and Agriculture (IDEA). The criteria which the companies
must satisfy to be included in the investment universe are determined through independent
external research and relate to compliance with the principles of the United Nations Global
Compact (human rights, labour, environment, anti-corruption). This selection, which is established
by an independent consultancy, excludes companies (i) which do not comply with the Global
Compact and (ii) which may be facing "major" allegations on various subjects such as business
ethics, client incidents, management of the subcontracting chain and corporate governance.
The resources allocated to our SRI activities are at mainly three levels
o In terms of responsible investment, Petercam has set up a Responsible Investment Committee,
whose mission is to reflect upon sustainability initiatives taken within our asset management
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business unit, and to raise awareness among our employees. Furthermore, Petercam has
nominated a full time Responsible Investment Coordinator.
 The Responsible Investment Committee gathers members from diversified business lines
of the company who share the same willingness and pro-activity to enhance SRI and ESG
issues within Petercam. The Committee comprises representatives from the Private
Banking, from the third party selection team, from the legal department, from the sales &
marketing teams and from the investment management teams. It meets on a monthly
basis. The discussed topics are various, from the organisation of the RI Corner to the
practical implementation of the UN PRI principles and consequences for Petercam. The
Committee formulates recommendations to the Board of Directors of Petercam and to
the Board of Directors of the sicav promoted by Petercam.
 Next to the Committee, Petercam has appointed a Responsible Investment Coordinator
whose main objectives are:
 to steer all initiatives, projects and methodologies related to the RI aspect of
Petercam’s investment processes
 to be responsible for streamlining initiatives regarding ESG challenges
(Environmental, Social, Governance) on the Petercam group level.
 to be the privileged contact person for the UN PRI, which Petercam became a
signatory of in September 2011 and for other stakeholders (Beama, Eurosif,…).
In terms of investment, Petercam has a team of 8 Buy-side analysts, 5 credit analysts, 2 macro researchers, 6
portfolio managers of global balanced portfolios, 9 fixed income portfolio managers and 16 equity managers.
Another feature of the Responsible Investment approach is the proximity to equity and fixed income management
teams. As we all share the same office space it’s easy to speak about ESG topics with portfolio managers and to
interact. This enhances the investment process and creates sustainable added value in the long run.
o
o
o
In terms of extra financial information regarding the European companies, Petercam relies on the
research from an independent third-party, which offers the coverage of the holdings of the DJ
Stoxx 600. Furthermore, the quantitative information provided by Sustainalytics is complemented
by qualitative information from specialized brokers.
Information on the Petercam investment funds is available on www.petercam.com.
The research and investment processes are described in the investment policy of each sicav
available on request for institutional investors only.
1d. Describe the content, frequency and resources allocated/used by the fund management company to inform
investors about the ESG criteria taken into account



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The Petercam SRI universe is published on the website on a quarterly basis.
Monthly and quarterly factsheets with fund performance, portfolio composition and comments from the fund
manager including main changes in portfolio are available for all investors.
An extra-financial report is published every quarter with comments regarding the evolution of the SRI universe
and the impact on the portfolio.
Prospectus and (semi-)annual reports are also available on funds.petercam.com.
1e. Provide the name of the fund(s) to which this code applies, and its (their) main characteristics.


Petercam’s sustainable European equity investment process defines the framework resulting in investments in
European large cap companies which are among the best performers on certain extra-financial ESG-SRI criteria.
The integration of quantitative extra-financial ESG-SRI information should create added value in the investment
process. The sustainable universe is made up of the 40% best performers in each sector. Additionnaly, the
companies, which are not the leaders in ESG themes, but score satisfactory (between the best 40 and 60% in
their peer activity) are included in the eligible universe provided they show strong evidence of their
commitment to improvement (best effort over the last 3 years). The screening is done through Petercam’s ESGSRI model which is applied to the broad Stoxx 600 index universe.
The investment process is the basis for Petercam Equities Europe Sustainable stock selection process.
1f. What is (are) this (these) fund(s) trying to achieve through taking into account ESG criteria?
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With its ESG-SRI Fixed Income and Equities expertise Petercam targets a double alpha: alpha coming from the
construction of the sustainable eligible universe in addition to alpha generated by the investment process.
Petercam maximises the expected return of a portfolio constructed within the sustainable investment universe.
The objective is therefore offering best-in-class ESG-SRI funds with the purpose of having a similar long-term
performance as a classic fund. Petercam uses an objective multi-dimensional quantitative approach in its ESGSRI selection.
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Section 2. ESG Investment Criteria in SRI fund
2a. What fundamental principles underlie the ESG research methodology?
The criteria matrix relies on three main pillars:
1. Corporate governance
2. Global Compact
3. ESG Key Performance Indicators by sector
The Principles of the UN Global Compact assume companies are inherent to constant change, and encourage them
to advocate, take initiatives and play a leading role.
The SRI filter that is applied to Petercam Equities Europe Sustainable originates from independent and specialized
extra-financial analysis criteria which are supplied by an external provider.
The full range of criteria of the database encompasses the issues put forward by the Ten Principles of the UN Global
Compact.
The internally developed model of the SRI filter contains a limited number of SRI criteria, criteria with regard to
corporate governance and finally key performance indicators (KPIs) per sector
The Ten Principles of the Global Compact are taken into consideration by the combination of criteria selected by
Petercam for the sectors of the European equity universe, notably through SRI criteria and key performance
indicators per sector.
For example, the Principle 10: Businesses should work against corruption in all its forms Preventing corruption is a
selected SRI criterion for all corporate sectors.
As the SRI filter only keeps the 40% best performing companies per sector within the eligible investment universe,
the Petercam Equities Europe Sustainable fund only invests in those companies which strictly adhere to these
Principles.
2b. What internal and external resources are used to carry out this research?
The SRI filter prior to the company research is based on extra-financial research provided by an independent
company. The remuneration of extra-financial information agencies substantially differs from that of financial rating
agencies, avoiding any conflict of interest. The independence and objectivity of the provided information is therefore
guaranteed.
Nonetheless, the corporate governance of an extra-financial information company is also part of its selection
process. Other elements taken into account are the relevance of the information, the coverage, and the reactivity
towards controversies and market events, for instance how long it takes to cover a security that enters the universe.
Petercam relies both on in-house expertise and on expertise of an independent service provider. This independent
screening agency delivers detailed ESG-SRI analysis at company level. Petercam itself has developed a proprietary
selection and weight model based upon indicators and scores.
2c. Which ESG analysis criteria are used?
Petercam selects and weights the indicators based on the ESG-SRI vision of Petercam for each sector reflecting its
long term view. Petercam sees five major trends and challenges to which companies will need to respond/
 Global warming and climate policy: CO2 rights, new technology,…
 Environmental awareness: pollution prevention, health claims,…
 Demographic challenges: ageing, multi-ethnic societies, war for talent,…
 Reputation risk: sensitivity of consumers to the reputation of a company,.
 Rising importance of Corporate Governance
Based on these long term trends and in-depth sector knowledge, Petercam defines ESG KPI’s (Key Performance
Indicators).
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The KPI’s vary from sector to sector in order to be able to highlight and differentiate issues on a sector specific base.
For instance, in sectors that are more directly related to consumer services (such as the financial sector or
telecommunications) relevant ESG KPI’s are to be found in indicators which track the relationship with clients like
communication or responsible contractual agreement. For sectors that are more directly exposed to environmental
issues, pollution prevention, minimising greenhouse gases, improvement of safety conditions for workforce are seen
as key relevant indicators.
In addition, indicators track corporate governance issues and have a weighting in the overall score.
Petercam integrates elements which comply with the 10 Principles of Global Compact (see above).
2d. What is your ESG analysis and evaluation methodology (how the investment universe is built, rating system,
etc.)?
The scoring is applied to the companies belonging to the Stoxx 600 index. The eligible universe results from the
application of a priori exclusion criteria in combination with a scoring by sector.
 Producers of anti-personnel mines and cluster ammunition as well as tobacco manufacturers are a priori
excluded from the sustainable investment universe. Companies in the exclusion list of the Norwegian Ministry of
Finance are excluded from the Universe as well.
 Excluded as well are companies non-compliant with the Global Compact (quarterly independent assessment)
and those facing most severe allegations (bi-weekly independent assessment).
 The 40% best performing companies in each sector in the ESG-SRI scoring model of Petercam are eligible for
investment in the sustainable equity portfolios.
 In addition, the companies, which are among the 40 and 60% best performing companies are also eligible for
investment provided that they rank in the first quartile in terms of 3-year improvement.
2e. How frequently is the ESG evaluation reviewed?
Data are updated on a monthly basis. The Petercam RI Committee holds an annual meeting during which the
investment process is monitored and continuously improved.
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Section 3. Fund Management Process
3a. How do you take into account ESG criteria when defining the universe of eligible investments?
The investment team of the investment fund Petercam Equities Europe Sustainable can only invest in the top 40%
companies in their respective sectors (level 4 of the MSCI GICS classification). The ESG scoring is based on in-house
developed matrix. 25% of the scoring is based on corporate governance, 12% on Global Compact Principles and the
remaining 63% is based on sector specific KPI’s.
The companies which are among the best 40 and 60%, are also eligible provided they rank in the top quartile in
terms of ESG scoring improvement over the last 3 years.
The investable universe is updated each month and sent automatically to the investment team as well as to the fund
administration, so as to ensure compliance of the investments with the universe.
3b. How do you take ESG criteria into account into the portfolio construction?
The management teams have the leeway to select securities within the investable universe, based on macroeconomic convictions, themes and relative and fundamental analysis of investable securities.
A country’s or company’s positioning in the ranking influences the management team in choosing between two
securities from a financial point of view. Preference will thus be given to the state or the company with the best
score.
In the case of Petercam Equities Europe Sustainable, the filter is updated each month. The manager has three
months to sell positions in a security that is no longer in the investable universe.
The management teams take part in various SRI meetings (RI Corners and the RI Committee for equities) so they gain
awareness to SRI topics.
The portfolio is monitored on a permanent basis and checked in its entirety monthly. This ensures that existing
holdings match with the target SRI universe. The risk management of Petercam Institutional Asset Management
plays an active role in this process.
The sustainability ranking is updated on a monthly basis. Changes in the eligible universe are communicated to the
portfolio managers and the risk management of Petercam Institutional Asset Management. If a company is not in
the eligible universe anymore, the position cannot be increased anymore. If the exit is confirmed twice, the fund
manager sells the position taking into account market conditions.
3c. Does the fund have a specific ESG engagement policy?
Petercam adopted an engagement program in the second half of 2014.
The reasons to engage are the following:
 To defend our corporate governance principles in line with our voting policy
 To add real value to the investment process as companies with strong ESG performance tend to
outperform. Therefore important that key ESG issues are addressed
 To identify and mitigate risks with corporate management and therefore to optimise the risk/return profile
of our portfolios
 To better understand the companies to make long-term investment decisions
 To demonstrate the long-term commitment opposed to the trend of short-termism of the markets
 To recommend corrective measures/best practices.
We engage in the framework of our voting policy, of our global sustainable strategy and through the platform
Clearing House on topics which are of upmost importance.
In addition, the meeting with the management is key in the research process at Petercam.
Petercam engages in an active dialogue with companies, NGOs, as well as with the academic world and government
institutions. The RI committee invites specialists from outside the financial world to discuss ESG/SRI topics.
Committee members participate in presentations/ round tables of NGOs etc.
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Through the Clearing House opportunity from the PRI, Petercam is participating in collaborative engagement
initiatives, such as on the prevention of corruption or on the full transparency of clinical trials.
3d. Does the fund have a specific voting policy integrating ESG criteria?
Each sicav is an independent entity which has its own voting policy. Although the group voting policy is distinctive
from the voting policies of the individual independent entities, these are in line and the inclusion of ESG criteria is
making part of the underlying principles of the Voting Policy. Please see above for additional information.
3e. Does the fund engage in securities lending activities?
Yes, the fund can engage in securities lending activities.
Petercam funds limit securities lending in such a manner that voting instructions can be applied to at least
part of the securities in the portfolio. The Committee can decide not to recall securities when it deems this
inopportune or when exercising the attached rights will not sufficiently offset the costs incurred by repatriating the
securities.
When a vote is of particular strategic importance for the funds and when it pertains to securities that have been lent
out, these securities can, insofar as possible, be repatriated such that the Committee is able to fully exercise the
associated voting rights.
We lend max 80% of our position in one security so as to ensure that at least 20% is always available to participate to
the general assembly. Moreover, there is a limit in terms of the securities lent out in the same sicav (not the issuer)
in order to ensure this limit in reality is below 80%.
3f. Does the fund use derivative instruments?
N.a.
3g. Is a share of the fund invested in unlisted entities pursuing strong social goals?
N.a. the fund invests exclusively in listed instruments.
Section 4. Controls and ESG Reporting
4a. What internal/external control procedures are in place to ensure the compliance of the portfolio with the ESG
rules defined in section 3 of this code?
Petercam uses the input from an independent SRI research institution in its ESG-SRI screening process. The model
ranking European companies is established by the RI Committee, which is primarily composed of investment
professionals not involved in the day-to-day management of the portfolios.
The investable universe is updated each month and sent automatically to the investment team as well as to the fund
administration, so as to ensure compliance of the investments with the universe.
The compliance of the investments with the company ranking is audited internally and externally. An external audit
report is available in the annual report of the investment fund.
4b. Please list all public media and documents used to inform investors about the SRI approach to the fund and
include URL’s. this should include a link to the detailed, no more than 6 months old, list of holdings of the funds.
 Prospectus, annual reports, fund factsheet, KIID: : on funds.petercam.com
 Dedicated SRI webpages: https://www.petercam.com/be-en/institutional/responsible-investment
 Voting policy: https://www.petercam.com/be-en/institutional/responsible-investment/our-shareholderresponsibility
 Detailed fund holdings and other documents available to investors: funds.petercam.com
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