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Sustainability-related disclosures (published as per 1 January 2023)

Anthos Fund II RAIF-SICAV – Impact Investing Fund

The EU Sustainable Finance Disclosure Regulation (SFDR) is a set of EU rules which aim to increase transparency on how financial market participants integrate sustainability in their investment decisions and recommendations. It also aims to make the sustainability profile of financial products more comparable and better understood by investors because of the increased reporting expectations. A part of its assessment is based on pre-defined ESG metrics and includes rules that must identify any harmful impact made by investee companies. Below, Anthos Fund & Asset Management (LEI: 724500604XSTP9D0NU75) has stated how it complies with the requirements of SFDR for its financial product Anthos Fund II RAIF-SICAV – Impact Investing Fund (Investment fund managed by Anthos Fund & Asset Management B.V.; “Anthos”) (LEI: 549300Y4PZKYVOCS0104).

Summary

The sustainable investment objectives of this financial product are:

  1. to invest in external investment funds that have an impact objective
  2. the impact objectives of the external investment funds that this financial product invests in should contribute to Anthos’ values: Sustainability, Human Dignity and Good corporate citizenship.

These values translate into the following three impact themes: 

  • Protecting the environment (environmental)
  • Elevating people and communities (social)
  • Rethinking the economy (combination of ESG) 

As a fund of funds, this financial product invests in investment that are managed by other investment managers. Anthos therefore requires that the investment managers of these external investment funds demonstrate to Anthos that the underlying investments do not significantly harm the sustainable investment objectives of the respective external investment funds. Anthos also identifies and monitors the potential adverse impacts of the investment funds this financial product invests in by assessing the ESG investment practices implemented by the external investment managers of these investment funds, and more specifically obtaining information from them on the potential adverse impacts they make through their investment fund’s underlying investments.

The investment objective of this financial product is to invest capital in impact investing strategies across a wide range of investment styles and deliver Eurozone Core CPI Inflation + 3%. This financial product will invest indirectly in impact investing, by participating in investment funds.
External investment funds eligible for consideration for this financial product should be assessed as a "Professional" or "Leader" in Anthos' ESG score.
External investment funds eligible for consideration for this financial product should obtain an impact score of 7 and above and an IMP label of "B" or "C".

This financial product does not invest directly in investee companies, but indirectly, through its direct investments in investment funds. Anthos expects the investment managers of these investment funds to assess good governance practices of their investee companies. Furthermore, this financial product is screened on a periodic basis (mostly yearly) to determine whether an investee company is violating or at risk of violating, one or more of the UN Global Compact Principles and related international norms and standards.

This financial product seeks to invest 100% of its assets in external investment funds that qualify as sustainable investmentss with environmental or social objectives. This may not always be reachable as this financial product may hold from time to time cash and money market instruments for liquidity management purposes and derivatives for hedging and efficient portfolio management purposes.

Anthos developed an impact assessment tool – Anthos’ Impact Scorecard – based on the Impact Management Project norms to assess and select external investment funds for this financial product. This financial products selects external investment funds (‘impact funds') that have a clear impact intention, allocation and impact measurement and management and professional or leading practices in integrating environmental, social and governance issues and stewardship. This assures Anthos that the underlying investee companies do not cause significant harm and have good governance practices. Impact potential is scored by looking at the intention, the allocation of capital and the measurement capabilities of the external investment fund and the investment manager Anthos wants to invest in. The ESG and IMP composition of this financial product is monitored and reported to investors on a quarterly basis.

This financial product selects external investment funds (‘impact funds') that have an impact objective which aligns with the three impact themes stated above. To do so, per external investment fund one or more sustainability indicators are chosen and monitored to ensure alignment between the three impact themes and the impact objectives of the external investments funds.

This financial product qualifies the external investment funds included in this product with an ESG rating, an IMP label and an IMP score using Anthos proprietary tools. The ESG rating, IMP label and IMP score are the result of an internal assessment performed by the Anthos portfolio managers and their analysts, based on the relevant information shared by the external investment managers themselves during the RFP phase or during engagement conversations that take place at least on a yearly basis.  

Assessing the information shared by the external investment managers may be influenced by the amount of knowledge of the Anthos staff performing the assessment on ESG practices, ESG topics, market standards, etcetera.

The Anthos portfolio managers have to provide a write up on an investment fund's responsible investment practices prior to making the decision to have this financial product invest in such investment fund.

As a fund of fund manager, Anthos invests in segregated mandates and investment funds managed by external investment managers, and it relies on these external investment managers for engagement and voting in connection to the investee companies. However, Anthos believes it also needs to address active ownership through additional engagement activities, either via a service provider or, where possible, directly. This enhances investor stewardship and the pursuit of responsible investment.

Although a benchmark is used for comparing its financial performance, this financial product does not use a specific benchmark to determine whether it is aligned with its sustainable investment objectives. This financial product attains its sustainable investment objectives through its investment guidelines, which are based on its investment strategy.

 

1. No significant harm to the sustainable investment objective

As a fund of funds, this financial product invests in investments that are managed by other investment managers. Anthos therefore requires that the investment managers of these external investment funds demonstrate to Anthos that the underlying investments do not significantly harm the sustainable investment objectives of the respective external investment funds.

Anthos also identifies and monitors the potential adverse impacts of the investment funds this financial product invests in by assessing the ESG investment practices implemented by the external investment managers of these investment funds, and more specifically obtaining information from them on the potential adverse impacts they make through their investment fund’s underlying investments. Pre-investment, Anthos assesses these external investment managers on a wide scope of criteria (Negative impacts of the portfolio to the world, exclusions applied to the investment funds, Diversity, Equity & Inclusion, climate change) using Anthos ESG Scorecard. This financial product only invests in investment funds that score high on the Anthos ESG scorecard.

This financial product implements Anthos' exclusion list by communicating the exclusions criteria to its external managers during the pre-investment phase. This exclusion list is included in the side letter upon investment. Businesses that should be eliminated include tobacco, gambling, controversial and conventional weapons, adult content when they are responsible for more than 5% of revenues for that particular tenant and criminal enterprises. The external investment funds usually already have an exclusion list aligned with Anthos’ exclusion list or aligned with the IFC exclusion list.

It is noted that the external investment funds of this financial product invest primarily in private markets outside of the European Union. For this reason, only limited PAI indicator data is currently available for the underlying investments of the external investment funds. To resolve this data gap, Anthos is updating its data collection process to obtain more data that relate to the PAI indicator metrics.

This financial product aligns with the OECD guidelines and the UN Guiding principles by selecting external investment managers that have an exclusion list aligned with Anthos’ exclusion list. This financial product recognizes three main groups of exclusions (based on the reasons for exclusion):

Legal expectations and international norms: Living up to the legal expectations where there is a ban on investing in controversial weapons and aligning with minimum standards of business practice based on international norms, such as the OECD guidelines, the UN Human Rights Declaration and the Security Council sanctions of the UN Global Compact:

  • Controversial weapons as defined by Sustainalytics;
  • Conventional weapons: small arms and military contracting;
  • Global Standards (UNGC, OECD) violators after failed engagement;
  • Sovereign bonds with EU/UN sanctions directed at central governments and including an arms embargo.

Values and beliefs: As a responsible investor, Anthos does not finance products that are not in line with Anthos’ and Anthos’ clients’ values and beliefs. Therefore, this financial product excludes companies that do not align with these values and beliefs, based on their involvement in:

  • Tobacco,
  • Adult entertainment,
  • Gambling.

Climate Net Zero 2040 ambition: Based on minimising both Anthos’ financial risk and adverse impact, this financial product excludes companies involved in Coal, oil sands and Arctic drilling.

 

2. Sustainable investment objective of the financial product

Anthos believes in the steering power of capital and has the ambition to contribute to impact through systems change and on the ground.

The sustainable investment objectives of this financial product are:

  1. to invest in external investment funds that have an impact objective
  2. the impact objectives of the external investment funds that this financial product invests in should contribute to Anthos’ values: Sustainability, Human Dignity and Good corporate citizenship.

These values translate into the following three impact themes: 

  • Protecting the environment (environmental)
  • Elevating people and communities (social)
  • Rethinking the economy (combination of ESG) 

 

3. Investment strategy

The investment objective of this financial product is to invest capital in impact investing strategies across a wide range of investment styles and deliver Eurozone Core CPI Inflation + 3%.  This financial product will invest indirectly in impact investing, by participating in investment funds. This financial product may also invest in ETFs.

The following binding elements apply to attain this financial product’s sustainable investment objective:

  • External investment funds eligible for consideration for this financial product should obtain an IMP score of 7 and higher.
  • External investment funds eligible for consideration for this financial product should have an IMP label of “B” or “C”.
  • External investment funds eligible for consideration for this financial product should have investment manager that are assessed as a "Professional" or "Leader" in Anthos' ESG score.

This financial product does not invest directly in investee companies, but indirectly, through its direct investments in investment funds. Anthos expects the investment managers of these investment funds to assess good governance practices of their investee companies. Before investing in a new investment fund for this financial product, Anthos performs an assessment on the policies of the investment manager of that investment fund, including whether material ESG factors – such as good corporate governance practices at investee companies – are considered in the investment process. Such assessment of the investment manager is repeated by Anthos on a periodic basis (mostly yearly). Furthermore, this financial product is screened on a periodic basis (mostly yearly) to determine whether an investee company is violating or at risk of violating, one or more of the UN Global Compact Principles and related international norms and standards.

 

4. Proportion of investments

This financial product seeks to invest 100% of its assets in external investment funds that qualify as sustainable investments with environmental or social objectives. This may not always be reachable as this financial product may hold from time to time cash and money market instruments for liquidity management purposes and derivatives for hedging and efficient portfolio management purposes. Anthos does not currently assess those investments against any environmental or social safeguards and considers E/S characteristics are not applicable for those investments.

The external investment funds are considered as sustainable investments when the following criteria are met:
1. SFDR classification: the external investment fund is classified as an article 9 SFDR financial product; or/and
2.a. Objective: the external investment fund has a sustainable objective;
2.b. ESG rating: the investment manager of the external investment fund is rated either as a "Professional" or a "Leader";
2.c.i. IMP label: the external investment fund has an IMP label of "B" or "C";
2.c.ii IMP score: the external investment fund has an IMP score of 7 or above
2.d. DNSH: the underlying investments of the external investment fund do not significantly harm (DNSH) its sustainable investment objectives. The investment manager of the external investment fund must demonstrate to Anthos, by using one or more of the PAI indicators stated in Annex I of the SFDR regulatory technical standards, that the underlying investments do not significantly harm the sustainable investment objective. DNSH is also implicitly included in the ESG scorecard assessment, under Exclusions and Negative impact questions, as well as the IMP scorecard assessment, under B and C score guide;
2.e. Investee companies follow good corporate governance practices: the investment manager of the external investment fund must have a policy or procedure to assess and demonstrate that the investee companies follow good corporate governance practices.

This financial product seeks to invest 0% of its assets in direct investments that do not qualify as sustainable investments. However, this financial product may from time to time hold cash and money market instruments for liquidity management purposes and derivatives for hedging and efficient portfolio management purposes.

 

5. Monitoring of the sustainable investment objective

Anthos assesses all investment funds that are considered for this financial product on responsible investment practices and key ESG characteristics prior to investing, using its proprietary tools (ESG and IMP scorecard). This financial product only invests in investment funds with investment managers that have an ESG rating as "Professional" or "Leader", with an IMP score of 7 and above and an IMP label of "B" or "C". The ESG and IMP composition of this financial product is monitored and reported to investors on a quarterly basis.

In addition to this, Anthos engages on a regular basis with the external investment managers on the components of the ESG scorecard to:
a) ensure the ESG rating correctly reflects the responsible investments practices of the investment manager; and
b) signal the importance of responsible investing, highlight Anthos' expectations about key ESG characteristics (for example, Climate Change, DEI and Human rights) and monitor the progress made against Anthos' expectations.

The ESG+IMP scorecard is updated at least once a year to reflect the outcome of the engagement conversations between Anthos and the external investment managers.

 

6. Methodologies

Objective 1: To invest in external investment funds that have an impact objective

Anthos developed an impact assessment tool – Anthos’ Impact Scorecard – based on the Impact Management Project norms to assess and select external investment funds for this financial product.

This financial products selects external investment funds (‘impact funds') that have a clear impact intention, allocation and impact measurement and management and professional or leading practices in integrating environmental, social and governance issues and stewardship. This assures Anthos that the underlying investee companies do not cause significant harm and have good governance practices.

Impact potential is scored by looking at the intention, the allocation of capital and the measurement capabilities of the external investment fund and the investment manager Anthos wants to invest in. Each potential external investment fund is assessed against the impact criteria shown in figure 1 below and given a score between 0 and 9 points. A potential external investment fund needs a score of at least 7 in order to be selected for this financial product. On a quarterly basis, the average portfolio impact score is monitored for this financial product.

An investment fund can have one of the following IMP labels:

  • Avoid Harm (IMP label A): the investment fund seeks to improve its impact and avoid the potential negative impact it may cause or have caused.
  • Benefit stakeholders (IMP label B): the investment fund seeks to maintain the well-being of one or more group of people and/or the condition of the natural environment within the sustainable range.
  • Contribute to solutions (IMP label C): the investment fund seeks to address a social or environmental challenge not caused by the organization by improving the well-being of one or more group people and/or the condition of the natural environment so that it is within the sustainable range. 
  • May/Does cause harm (IMP label M/D): If the investment fund does not have an impact intention, it is classified as ‘May/Does cause harm'.

External investment funds eligible for consideration for this financial product should have an IMP label of “B” or “C”.

Anthos ESG scorecard:

The Anthos ESG scorecard shows the quality of the integration of environmental, social and governance assessments in the investment process at the external investment manager. Anthos specifically looks at the following criteria:

Criteria

Explanation

Relevant Anthos Policy    

Purpose & values & Industry leadership

Anthos assesses the values and purpose of the external investment manager. Anthos also assesses the industry memberships, the public commitments and the active participation or advocacy of the external investment manager.

ESG Positions

RI Policy, resources & governances allocated to RI

Anthos assesses the external investment manager’s ESG policy, targets and commitments, methodologies, due diligence process, stewardship policy, ESG tooling, RI team, etcetera.

RI Policy

Integration of ESG in investment process

Anthos assesses the ESG integration in the investment process of the fund, and more specifically which ESG topics are considered, which data are used, how ESG topics are considered in portfolio construction. Anthos also reviews the ESG monitoring process of the fund and which decisions are made.

RI Policy

Principal Adverse Impact/ Negative impact

Anthos assesses how the external investment manager evaluates, monitors, managers or remediates the impact of its investment fund’s portfolio on the world and the tools and methodologies to perform its assessment.

RI Policy

Anthos PAI statement

Exclusions

Anthos assesses the exclusions policy applied for the external manager's fund and to which extent it aligns with Anthos’ preferred exclusions.

Exclusion Policy

Engagement

Anthos assesses whether or not the external manager engages with the companies and or countries in the fund but also the engagement methods used, the objective defined and the metrics tracked.

Engagement Policy

Voting policies

When applicable, Anthos assesses the voting policy of the external investment manager, how it is applied to the external manager's fund and to which extent it aligns with Anthos’ ESG position.

Engagement Policy

Reporting

Anthos assesses whether the external investment manager reports on ESG factors for the fund, using qualitative and/or quantitative metrics, in alignment with relevant standards.

RI policy

Manager’s approach on DEI

Anthos assesses whether the external investment manager incorporates diversity, equity and inclusions (DEI) considerations for itself as well as in its investment funds. Anthos reviews the DEI programs, targets and commitments, engagement on DEI and reporting available.

ESG positions

Manager’s approach on climate change

Anthos assesses whether the external investment manager incorporates climate change considerations for itself as well as in its investment funds. Anthos reviews the climate positions, the commitments and reduction targets, the associated strategy, the assessments of the climate risks, the engagement initiatives on climate, data transparency and the reporting available.

Climate Position Paper

Impact Intention

Anthos assesses whether the external investment manager has the intention to avoid to cause harm, or to benefits stakeholders or contribute to solutions in its investments practices.

Anthos Positive and Impact Investment

Impact Influence

Anthos assesses the strategies used by an investor as a set of tactics to support investee’s impact management and performance improvement.

Anthos Positive and Impact Investment

 

An investment manager can have one of the following ESG ratings: "Laggard", "Novice", "Professional" or "Leader". An investment fund with an investment manager that has an ESG rating of "Professional" or "Leader" will have strong governance policies and requirements, will include sustainable risk assessment as a part of the investment process and will have a developed stewardship approach.

This financial product seeks to invest primarily in investment funds with investment managers that have an ESG rating as "Professional" or "Leader".

Objective 2: The impact objectives of the external investment funds that this financial product invests in should contribute to Anthos values and the selected impact themes

This financial product selects external investment funds (‘impact funds') that have an impact objective which aligns with the three impact themes below. To do so, per external investment fund one or more of the following sustainability indicators are chosen en monitored to ensure alignment between these impact themes and the impact objectives of the external investments funds. Please note that not all sustainability indicators stated below will be used to measure the attainment of the sustainable investment objective of this financial product.

Protecting the environment (environmental)

  • Houses with clean water
  • CO2 credits issued
  • GHG emissions saved
  • People with improved energy access
  • Solar systems deployed
  • Clean energy household appliances sold
  • Clean energy generation
  • Women with improved energy access

Elevating people and communities (social)

  • Student enrolled
  • Live tutoring sessions provided to underserved
  • Educators who borrowed favorably
  • Digital career accelerator job placements
  • Students/ Teachers provided with digital tools
  • Adult learners
  • Average salary increase vs alternative
  • Farmers with imporved yields
  • Jobs maintained
  • Lives touched
  • Low income individuals reached
  • Low income individuals with imporved basic needs
  • People with access to finance
  • Retail customer served
  • Underserved borrowers, customers, savers
  • Individuals with improved income
  • Small business loans to New to Credit customers
  • Consumer loans to New to Credit customers
  • Vehicule loan to New to Credit customers
  • Affordable house improvements
  • People with improved healthcare
  • Number of new healthcare facilities receiving a loan/year
  • Number of patient visits
  • Vaccine financing
  • Diagnostic device financing
  • Therapeutic financing
  • Covid tests
  • Vaccine acceleration technology
  • Rabies vaccines sold
  • Contraceptive & STI prevention gels provided
  • Affordable housing loans to women

Rethinking the economy (combination of ESG)

  • Borrowers of outcomes-based financing
  • SMEs invested in
  • Woman owned SMEs invested in
  • People receiving independent news

Anthos monitors the development of these sustainability indicators and it engages with the external investment managers and collaborate with others to increase the impact of the external investment funds, as measured by these sustainability indicators. Anthos is further defining specific targets for these sustainability indicators.

Please note that, although data availability and quantity is improving, it remains challenging to obtain data for some of the sustainability and principal adverse impact indicators. However, Anthos is continously engaging with the external investment managers in order to obtain the required data.

 

7. Data sources and processing

This financial product qualifies the external investment funds included in this product with an ESG rating, an IMP label and an IMP score using Anthos proprietary tools. The ESG rating shows the quality of the integration of environmental, social and governance assessments in the investment process at the investment manager. The IMP assessment  shows the impact intention of the investment funds that this financial product invests in and the investor influence that the investment manager of that investment fund exercises. This results in an IMP label (showing the impact intention of the investment manager for the fund) and an IMP score (showing the impact potential of a fund).

The ESG rating, IMP label and IMP score are the result of an internal assessment performed by the Anthos portfolio managers and their analysts, based on the relevant information shared by the external investment managers themselves during the RFP phase or during engagement conversations that take place at least on a yearly basis.

 

8. Limitations to methodologies and data

Assessing the information shared by the external investment managers may be influenced by the amount of knowledge of the Anthos staff performing the assessment on ESG practices, ESG topics, market standards, etcetera. Anthos mitigates this limitation by providing regular training to its staff, either on processes or specific topics (for example climate training and human rights workshops). The Anthos ESG & IMP scorecards are accompanied of a scoring guide which indicates which kind of requirements lead to specific ratings/labels/scores.
The assessments are also reviewed by the Anthos Responsible Investments Team on a need basis and the tools are continuously improved to keep up with market standards.

The assessment is also much more focused on policies and processes rather than real ESG outcomes. Anthos aims to incorporate outcomes in its assessment, as external ESG and Impact data becomes more reliable and methodologies more robust.

 

9. Due diligence

The Anthos portfolio managers have to provide a write up on an investment fund's responsible investment practices prior to making the decision to have this financial product invest in such investment fund.

 

10. Engagement policies

As a fund of fund manager, Anthos invests in segregated mandates and investment funds managed by external investment managers, and it relies on these external investment managers for engagement and voting in connection to the investee companies. However, Anthos believes it also needs to address active ownership through additional engagement activities, either via a service provider or, where possible, directly. This enhances investor stewardship and the pursuit of responsible investment.

Anthos has high expectations of the external investment managers selected for this financial product and incorporates ESG considerations into the entire external investment manager due diligence and relationship lifecycle. Anthos expects the selected external investment managers to be signatories of the Principles for Responsible Investment (PRI) and to support the Principles of the European Fund and Asset Management Association (EFAMA) Stewardship Code or a similar guidance, which clearly outlines engagement and voting good practices for direct investors.

Internally, engagement is carried out by Anthos’s portfolio managers, who assess the ESG integration capacity and quality of the external investment managers of the investment funds that this financial product invests in. Anthos also engages via an external engagement service provider that engages on behalf of Anthos' clients, even when Anthos does not appear as shareholder at the investee companies in question. In this way Anthos gives its voice to the pool of like-minded investors wanting meaningful change.

In addition to Anthos’ own proprietary engagements, its external engagement provider engages with more than 300 companies on human and labour rights and on environmental and business ethics issues, both on Anthos' behalf and on behalf of other investors.

More information on Anthos' engagement process and objectives can be found in its Stewardship Policy.

 

11. Attainment of the sustainable investment objective

Although a benchmark is used for comparing its financial performance, this financial product does not use a specific benchmark to determine whether it is aligned with its sustainable investment objectives. Going forward, Anthos will keep on monitoring whether any benchmark could become relevant regarding the sustainable investment objectives of this financial product. This financial product attains its sustainable investment objectives through its investment guidelines, which are based on its investment strategy.