ESG

• Article 29

• No consideration of the main negative impacts

• Archinvest Exclusion policy

• Sustainability risk policy

• Voting policy and shareholder engagement policy

• Compensation policy

• Archinvest Provision

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DETAILS :

Article 29

[Excerpt] Summary presentation of the entity's general approach to taking into account environmental, social and quality criteria of SG governance, and in particular in the investment policy and strategy: 

Archinvest is a portfolio management company approved by the AMF (GP-202221) in September 2022. 

Archinvest bases its investment strategy on the creation of funds of funds. Archinvest has developed a strong belief in the benefits of responsible investments. The management company believes that integrating environmental, social, and governance criteria is important for sustainable management. This is why Archinvest now includes an analysis of the underlying fund's management company as well as a review of the underlying funds' ESG policies and procedures. Archinvest selects funds that have made ESG a central focus of development. 

The management company has made it possible to monitor the progress of the results of the ESG indicators included in the funds, where applicable. 

No consideration of the main negative impacts

Article 4(1)(b) of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector ('SFDR') requires fund managers to publish a statement on the consideration of principal adverse impacts of investment decisions on sustainability factors as of 30 June. 

Archinvest has implemented processes and measures from 2022 to assess and monitor ESG issues and sustainability risks (i.e. environmental, social and governance factors) in the investment cycle.  

At this stage Archinvest does not consider the main adverse impacts prescribed in the EU SFDR Regulation, as the Company recognizes the current limitations of the data available to fully comply with the reporting requirements. 

The Company's position is subject to continuous review and close monitoring as market developments evolve. In this sense, Archinvest reassesses the situation and makes the necessary changes in a timely manner, with a view to addressing the main negative impacts in the manner envisaged in Article 4(1)(a) of SFDR. 

Archinvest Exclusion policy

[Excerpt] The exclusion policy applies primarily to Article 8 and 9 funds within the meaning of SFDR and may in certain cases apply to Article 6 funds. 

This exclusion policy is part of Archinvest's sustainable investment policy, consistent with Archinvest's corporate social responsibility approach. As part of its corporate social responsibility, and as an asset manager, Archinvest has decided to formalize its commitments to the general interest by excluding from its investment scope several sectors of activity with significant negative impacts on the environment and societal aspects. The exclusions are applied to all Archinvest management strategies for Article 8 and 9 funds within the meaning of SFDR.  

The purpose of this policy is to establish the general framework for excluding companies carrying out controversial activities with reference to a regulatory framework which includes:  

• The Ottawa and Oslo Conventions and their transpositions into French law; 

• The list of high-risk or “non-cooperative” jurisdictions established by the FATF; 

• The UN Global Compact. 

This normative exclusion policy consists of excluding investment funds that do not comply with our ESG policy, nor with international conventions and internationally recognized frameworks, nor with national regulatory frameworks.  

Archinvest has added sectoral exclusions to its normative exclusions, so as to avoid investing in activities whose ESG impacts are highly criticized. 

Sustainability risk policy

In accordance with Article 3 of Regulation (EU) 2019/2088 (“Disclosures” or “SFDR”) and Article L. 533-22-1 of the CMF (derived from Article 29 of the Energy-Climate Law), financial market players publish on their website information concerning their policies relating to the integration of sustainability risks into their investment decision-making process, including for French players, risks associated with climate change as well as risks linked to biodiversity. 

The objective of this policy is to enhance transparency on how financial market participants integrate relevant sustainability risks, whether material or likely to be material, into their investment decision-making processes. 

The policy is based on the principle of double materiality: 

• Sustainability risk: Impact of external events on the product's performance (How is the impact that external events could have on the performance of the financial product integrated into the risk management policy?), 

• Adverse sustainability impacts: Impact of investments made on external sustainability factors (How does the entity ensure that investments made do not cause significant harm to environmental and social objectives?). 

Voting policy and shareholder engagement policy

1. Voting policy 

Archinvest markets feeders (a single underlying Private Equity fund) and multi-funds (several underlying Private Equity funds). These underlying funds are managed by third-party Management Companies. In accordance with their regulations, these underlying funds make the decisions to invest or not in identified companies. Archinvest does not exercise decision-making powers regarding the decision to invest or not in a company in the portfolio of an underlying fund. Archinvest does not have voting rights and cannot make direct commitments through voting rights. 

However, when assessing the underlying funds and the Management Company managing the underlying funds, Archinvest will verify that the Management Company's voting policy is consistent with its commitments. 

2. Shareholder engagement policy 

The shareholder engagement policy will be activated in two ways, namely through:  

• The consistency of the Policy and the conclusions of the Annual Report of the voting rights of the Management Company of the underlying fund in which Archinvest invests; 

• Interviews during due diligence and the study of the Annual Shareholder Engagement Report of third-party Management Companies.

Compensation policy

Sustainability criteria are integrated into the annual evaluation of team members. They are taken into account in the assessment of the annual bonus. 

Provision

Pre-contractual documents, Article 10 and periodic reports concerning the funds are available upon request from Archinvest.