SRI AFG-FIR / EUROSIF TRANSPARENCY CODE EDMOND DE ...

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EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 47, rue du Faubourg Saint-Honoré 75401 Paris Cedex 08 France T. +33 1 40 17 25 25 F. +33 1 40 17 24 42 www.edram.fr S.A. à Directoire et Conseil de Surveillance au capital de 11.033.769 euros Numéro d’agrément AMF GP 04000015 – 332 652 536 R.C.S. Paris SRI AFG-FIR / EUROSIF TRANSPARENCY CODE EDMOND DE ROTHSCHILD EURO SUSTAINABLE GROWTH 1 Updated on September 25 th 2015 1- The fund’s name was Edmond de Rothschild Euro SRI until September 1st 2015

Transcript of SRI AFG-FIR / EUROSIF TRANSPARENCY CODE EDMOND DE ...

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 47, rue du Faubourg Saint-Honoré 75401 Paris Cedex 08 − France T. +33 1 40 17 25 25 − F. +33 1 40 17 24 42

www.edram.fr

S.A. à Directoire et Conseil de Surveillance au capital de 11.033.769 euros Numéro d’agrément AMF GP 04000015 – 332 652 536 R.C.S. Paris

SRI AFG-FIR / EUROSIF

TRANSPARENCY CODE

EDMOND DE ROTHSCHILD EURO SUSTAINABLE

GROWTH1 Updated on September 25th 2015

1- The fund’s name was Edmond de Rothschild Euro SRI until September 1st 2015

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 2/20

CONTENTS

1. General information .................................................................................................................................................................................. 4 2. ESGS analysis: methodology used to assess issuers ............................................................................................................................ 10 3. Investment process ................................................................................................................................................................................. 13 4. Controls and ESG reporting .................................................................................................................................................................... 16 GLOSSARY ................................................................................................................................................................................................ 18

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 3/20

Declaration of commitment

Socially Responsible Investing is a fundamental feature of the Edmond de Rothschild Euro

Sustainable Growth fund’s strategic positioning and investment strategy. We have been active in

the field of SRI since 2009 and are proud to implement the Transparency Code. This 5th year of

adherence to the Code covers the period from September 1st 2015 to July 30th 2016. Our full

answers to the SRI Transparency Code are disclosed below and will be available in the upcoming

annual reports produced for each of our open-ended SRI funds, as well as on our website.

Compliance with Transparency Code

The investment firm, Edmond de Rothschild Asset Management (France), commits to providing

transparent communication. We consider that we are as transparent as possible in light of the

regulatory and competitive landscape of the country in which we operate.

September 1st 2015

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 4/20

1. GENERAL INFORMATION

Edmond de Rothschild Asset Management (France)

1a) Name of the investment firm managing the fund concerned with this Code

This present code applies to the FCP Edmond de Rothschild Euro Sustainable Growth (formerly

known as Edmond de Rothschild Euro SRI) managed by Edmond de Rothschild Asset Management

(France).

With close to €22.5 billion in assets under management as of 31/12/2014, Edmond de Rothschild Asset

Management (France) is the asset management subsidiary of the Edmond de Rothschild Group in France.

With global AUM close to 49 billion euros, the Edmond de Rothschild Group is a key partner for institutional

investors, banks, insurance companies and fund distribution platforms. The group’s product and service offer

covers a wide range of investment strategies designed to create strong added value: equity, corporate debt,

asset allocation and sovereign debt, alternative funds, multi-management, Socially Responsible Investment

(SRI), and overlay.

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (France)

47, rue du Faubourg Saint-Honoré

75401 Paris Cedex 08

Public limited company with Executive and Supervisory Boards and a capital of €11,033,769 euros

Authorised by the AMF under reference GP 04000015

332.652.536 R.C.S. Paris

Website: http://www.edram.fr

1b) Please describe Edmond de Rothschild Asset Management (France)’s broad approach to integrating environmental, social and governance criteria (ESG).

EDMOND DE ROTHSCHILD ASSET MANAGEMENT’S APPROCH BUILDS ON THE EXISTING

SUSTAINABLE DEVELOPMENT STRATEGY OF THE EDMOND DE ROTHSCHILD GROUP

Edmond de Rothschild Asset Management (France)’s SRI approach feeds into the Edmond de Rothschild

Group’s sustainable development approach with the view to offering clients exhaustive and dedicated

solutions able to combine their values with their performance objectives, whether financial or extra-financial.

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 5/20

This commitment is driven at the highest level by the Group and builds on the Sustainable Development

Strategy whose “5 pillars for action” include sustainable and responsible investment. The Edmond de

Rothschild Group’s sustainable development strategy is described in the Sustainable Development Report

and can be accessed using the following link:

http://www.edmond-de-rothschild.com/SiteCollectionDocuments/group/sustainable-

development/Edmond-de-Rothschild_short-sustainable-development-report-2014.pdf

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) DEMONSTRATES A LONG-TERM

COMMITMENT TO SUSTAINABLE DEVELOPMENT WITH THE SIGNATURE OF THE UN-PRI AND

THE LAUNCH OF A 2013-2016 RESPONSIBLE INVESTMENT STRATEGY

As a signatory of the UN-PRI (United Nations Principles for Responsible Investment) since 2010, Edmond

de Rothschild Asset Management (France) is firmly committed to deploying resources and harnessing our

teams’ efforts to embed ESGS1 factors across the full spectrum of the firm’s investment strategies. As UN-PRI

signatories, we are committed to disclosing progress reports and improving our practices through the

completion of annual reports 2 (since 2011).

To achieve this, Edmond de Rothschild Asset Management (France) has launched a new phase in the

deployment of its SRI efforts by drawing up the firm’s 2013-2016 Responsible Investment Strategy and, by

publishing a Responsible Investing Policy on its website early 2014.

In light of the firm’s continuous improvement programme, Edmond de Rothschild Asset Management

(France) plays an active role in various ESG industry think tanks and contributes to promoting and fostering

SRI via its commitment and involvement within working groups, notably: the AFG’s SRI Commission, the

Forum pour l’Investissement Responsable – FIR and the Eurosif- European Sustainable Investment Forum.

Furthermore, Edmond de Rothschild Asset Management (France) supports the academic research on SRI led

by the AFG’s Chair for Sustainable Finance and Responsible Investing (FDIR-

http://www.enseignement.polytechnique.fr/economie/chairefdir/mission.php).

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE)’S VOTING POLICY

A new voting policy was drawn up at the end of 2009 that can be applied in France and globally, for all funds

managed by Edmond de Rothschild Asset Management (France). This voting policy – effective from the 2010

Shareholder Meetings season – is applied in consistent manner to all stocks held in portfolios managed by

1 Environment-Social-Governance

2 The full answers provided by Edmond de Rothschild Asset Management (France) in the most recent edition of the UN-PRI questionnaire are available by

cliecking on the following link: http://www.edmond-de-rothschild.com/SiteCollectionDocuments/asset-management/isr/EDRAM-EN-Public-Transparency-Report.pdf.

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Edmond de Rothschild Asset Management (France), as long as the information provided by the issuer is

sufficient and that the custodian banks are able to register the vote. Every year, we may review or amend our

voting policy as we come across specific cases or situations that were not covered.

Furthermore, the principles of this voting policy are in keeping with the SRI approach deployed by Edmond

de Rothschild Asset Management (France): they set forth Edmond de Rothschild Asset Management

(France)’s position on Environmental or Social resolutions submitted at shareholder meetings, in addition to

fundamental governance issues.

For more details on our policy, please refer to the Voting Policy document available on our website:

http://www.edmond-de-rothschild.fr/SiteCollectionDocuments/edram/pdf/finance-responsable-et-

isr/EDRAM-voting-policy.pdf

The 2014 Annual Report on Voting Rights is available on our website in the section dedicated to our SRI

Expertise: http://www.edmond-de-rothschild.fr/SiteCollectionDocuments/edram/pdf/finance-responsable-

et-isr/EDRAM-EN-annual-report-on-exercising-voting-rights.pdf

1c) Please provide a list of your SRI funds and describe the resources that are specific to

SRI strategies.

In response to evidence that environmental and social issues have become a major challenge for the years to

come, and in light of existing commitments and initiatives conducted by the Edmond de Rothschild Group,

Edmond de Rothschild Asset Management (France) launched its SRI fund offer:

With the launch on 26th June 2009 of Edmond de Rothschild Euro SRI, which became

Edmond de Rothschild Euro Sustainable Growth on September 1st 2015, the Edmond de

Rothschild Group’s first ESG-S selection SRI fund. Edmond de Rothschild Euro Sustainable

Growth is a Eurozone equity fund focusing on stocks offering a positive sustainable development

policy and attractive growth prospects. Since 2009, the fund has been granted the SRI Label from

Novethic3, which recognizes Socially Responsible Investment (SRI) funds that demonstrate a

systematic integration of Environment, Social and Governance (ESG) considerations in fund

management. The Label certifies the importance of ESG analysis on the portfolio structure.

In 2009, with changes made to one of the group’s flagship funds, Edmond de Rothschild

Tricolore Rendement. These changes involved upgrading the fund’s investment process

to include a SRI Dialogue/Engagement process on ESG-S issues. In September 2011 and

3 To find out more on Novethic’s SRI Label (http://www.novethic.fr/isr-et-rse/le-label-isr.html )

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20124, Novethic awarded the SRI Label to Edmond de Rothschild Tricolore Rendement, with a special

mention for Engagement, thereby shining light on a pertinent form of SRI which remains relatively

underdeveloped on the French market.

Edmond de Rothschild Asset Management (France) also manages SRI mandates on behalf of institutional

clients who are pioneering the integration of ESG factors across their investments.

Edmond de Rothschild

Asset Management

(France)’s SRI funds

SRI Strategy AUM in million euros (€m)

as of 30/06/2015

Edmond de Rothschild

Tricolore Rendement

Engagement

on ESG issues

€1,574 m

Edmond de Rothschild

Euro Sustainable Growth

ESGS-based positive selection

(Best in universe)

€38 m

SRI mandates

ESGS-based Selection

(Best-in-class)

€1,700 m

Edmond de Rothschild Asset Management (France) is recognised as key player in the field of European

Responsible Finance, with a total €3.3 billion under management as of June 30th 2015.

TEAM OF FUND MANAGERS AND ANALYSTS RESPONSIBLE FOR EDMOND DE ROTHSCHILD EURO

SRI

Edmond de Rothschild Asset Management (France) deliberately chose to include specific SRI expertise

within the investment teams in order to promote a collaborative approach and facilitate the integration of

extra-financial issues throughout financial analysis.

In order to support the deployment of Edmond de Rothschild Asset Management (France)’s 2013-2016

Responsible Investing Strategy, the company has entered a new stage in its development with the re-

organisation of the SRI investment and analysis team, whose members have been partly redistributed within

the different investment units. The rationale behind this new organisation is to promote the acculturation of

extra-financial issues through experienced ESG correspondents – the ultimate aim being to gradually embed

extra-financial risk considerations across Edmond de Rothschild Asset Management (France)’s portfolios.

4 2012 was the final year for the Engagement Label

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As of June 30th 2015, the SRI analysis and investment team includes 2 people, plus 5 SRI correspondents

deployed across the European Equity, Global Equity, Corporate Debt, Asset Allocation and Sovereign Debt

teams.

1d) Describe the contents, frequency and media used by Edmond de Rothschild Asset

Management (France) to inform investors on the incorporation of ESG factors.

Information pertaining to the Edmond de Rothschild Euro Sustainable Growth fund (monthly financial and

extra-financial reporting, fund presentation material, semi-annual inventory of stocks held in the portfolio

the Key Investor Information Document and the Prospectus) is available on Edmond de Rothschild Asset

Management (France)’s website in the SRI expertise section: “Our range of SRI funds”.

Edmond de Rothschild Asset Management (France) organises regular roundtable conferences with investors

in order to promote our SRI investment and analysis capabilities and to provide interactive and personal

answers to any questions clients may have. The investment team responsible for Edmond de Rothschild Euro

Sustainable Growth also carries out in situ client meetings.

For any additional information, investors are welcome to contact the SRI investment / analysis team by

email, or to set up an appointment using the Contacts page on Edmond de Rothschild Asset Management

(France)’s website.

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 9/20

THE SRI FUND “EDMOND DE ROTHSCHILD EURO SUSTAINABLE GROWTH”

1e) Please name the fund(s) concerned by this Code and provide an overview of their characteristics.

Fund name

Edmond de Rothschild Euro Sustainable Growth

(A share class)

Inception

Fund launched on: 05/07/1984. Fund investment strategy launched

on 26/06/2009 (Edmond de Rothschild Euro SRI)

Investment strategy changed on 01/09/2015 (Edmond de

Rothschild Euro Sustainable Growth)

Net assets €38 m (30.06.2015)

Curreny Euro

SRI Strategy FCP SRI with ESP-S selection and

Best-in-univers bias

Fund category Eurozone Equities

All Caps

Fund of funds No

Benchmark MSCI EMU, only for indicative

purposes

Label

Novethic SRI Label

2009, 2010, 2011, 2012, 2013, 2014 and 2015

Management Fees 2% Max (VAT incl.)

1f) Objectives behind ESG factor integration in the management of Edmond de Rothschild Euro Sustainable Growth.

Edmond de Rothschild Asset Management (France) strives to optimise its SRI capabilities on a permanent

basis in order to offer clients new analytical and investment tools that will enhance the resources already

developed by the investment firm. Our objective is to provide an efficient investment solution that

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 10/20

leverages on the economic growth of companies committed to addressing sustainable

development challenges.

2. ESGS ANALYSIS: METHODOLOGY USED TO ASSESS ISSUERS

2a) Fundamental principles on which the ESG methodology relies

Edmond de Rothschild Asset Management (France) considers that the ideal responsible and sustainable company is one that:

- Strives to create long-term value;

- Is aware that to achieve this goal, it has to address economic and financial challenges but also ensure:

o Quality governance, o A healthy and stimulating work environment, o The ability to control and reduce its environmental impact, o Positive relations with its stakeholders (clients, suppliers, civil society…).

- Is proactive in managing risks and seizing opportunities for sustainable development.

REFERENCES AND STANDARDS UPON WHICH OUR ESG ANALYSIS IS FOUNDED

The rating methodology and extra-financial analysis matrix were defined by our SRI investment /analysis

team and based on existing standards and references (e.g. United Nations Global Compact, OECD and WTO

conventions and official publications…).

2b) Internal and external resources for conducting this analysis

Company ratings are calculated in-house as Edmond de Rothschild Asset Management (France) firmly

believes that this process is complementary to financial analysis and offers important insights on whether the

company’s strategy is sustainable (or not).

Drawing upon the information obtained from corporate publications, extra-financial rating agencies and

various external sources, the SRI fund manager-analysts assess the European stocks held in the

portfolio from an Environment, Social, Governance and Stakeholders point of view (ESG-S).

Each of these four pillars includes a set of extra-financial criteria. The team uses this information to rate the

company. Fund managers can confirm their opinion on a given company by meeting the management; they

can also push the analysis further by addressing issues that may not have been mentioned or that require

challenging. It is also during these meetings that the SRI team engages a constructive dialogue with the

companies, especially small and midcaps, to raise awareness on any ESG-P issues specific to their sector of

activity.

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2c) Key ESG analysis criteria

EXTRA-FINANCIAL CRITERIA USED FOR Edmond de Rothschild Euro Sustainable Growth

The key criteria used to assess the four E, S, G and S (Environment, Social, Governance, Stakeholder

relations) pillars are the following:

Environment (E) Social (S) Governance (G) Stakeholders (S)

Environmental risk management

Environmental programmes

∙ Eco-designed products ∙ Compliance with current

and future regulation ∙ Efforts in areas of

transportation and building management…

Human Resource Management

∙ Employee loyalty ∙ Career management

and training

Corporate governance

∙ Independent Board and Committees (audit, compensation…)

∙ Respect of minority shareholder (no anti-takeover measures)

Relations with civil society

∙ Corporate engagement in initiatives such as the Global Compact

∙ Commitment to observe: Human rights Workers’ rights Sound business

practices

Environmental footprint

∙ Greenhouse gas emissions ∙ Energy consumption ∙ Water consumption ∙ Waste treatment ∙ Pollution (heavy metals…)

Social dialogue

∙ Worker representation

∙ Management support with corporate restructuring

Transparency

∙ Disclosure of extra-financial quantitative data

∙ Audited data ∙ Easy access to

information

Client /supplier relations

∙ Responsible buying policy

∙ Tests and quantified data on client satisfaction as a basis for improvement

Impact of product or service

∙ Green innovation ∙ Lifecycle analysis

Working environment

∙ Health and safety ∙ Diversity

management

Contribution to economic and social development

∙ Dynamics in vicinity of company sites

∙ Patronage/sponsorship

Analysis is systematically documented through stock monitoring factsheets and SRI rating matrices

based on the 4 ESG-S pillars.

2d) Methodology used for ESG-based analysis and assessment (construction, assessment scale,…)

Our SRI rating model is constructed in order to allocate different weightings to criteria in order to take the

specificities of each sector or industry in account.

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In practical terms, this means that different extra-financial criteria are given varying degrees of importance

depending on the company’s sector or industry; each of the four pillars is therefore allocated a different

weighting. For instance, a chemicals company will be more concerned by environmental issues, while a

services company will be allocated a higher weighting for social factors.

EXCLUSION OF COMPANIES INVOLVED IN CLUSTER BOMBS OR ANTI-PERSONNEL MINES

Beyond the exclusion of companies whose business is any way related to cluster bombs and anti-personnel

mines - in compliance with an internal policy applicable to all Edmond de Rothschild Asset Management

(France)’s funds (managed in house or sub-advised) - there is no sector, geographic, market cap or thematic-

driven exclusion/inclusion bias within Edmond de Rothschild Euro Sustainable Growth.

A “BEST IN UNIVERSE” INVESTMENT PROCESS

In order to determine whether the companies held in the portfolio meet the criteria of a “responsible and

sustainable company” as per Edmond de Rothschild Asset Management (France)’s SRI standards, the

investment team responsible for Edmond de Rothschild Euro Sustainable Growth grant the stocks an

internal SRI rating. These ratings are based on a seven-point scale ranging from CCC5 to AAA and are

determined by aggregating the company’s global results on different ESG-S criteria, as per the

rating matrix designed by the SRI specialist team. Extra-financial criteria are allocated different weightings

according the company’s sector or industry; however, the overall rating is determined on an absolute basis

and is not relative to the sector performance. To enter the portfolio, a stock must have a minimum

rating of A.

The “Best in universe” approach favours companies with the strongest ESGS ratings – i.e. those with

ratings that are as close as possible to AAA regardless of their sector or industry. As some sectors may not

include highly rated AAA, AA or A companies, they may not feature in the portfolio of Edmond de Rothschild

Euro Sustainable Growth.

5 AAA = ESGS rating above 15/20, AA = rating between 13 and 15, A = rating between 11 and 13, BBB = rating between 9 and 11, BB = rating between 7 and 9, B = rating between 5

eand7, CCC = rating under 5.

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2e) ESG assessment revision frequency

The ESGS ratings of companies covered by our in-house extra financial analysis are updated every 18 to 24

months.

As far as the ESGS methodology is concerned, our 4 main research pillars (Environment, Social, Governance

and Stakeholders – ESGS) are not set to change. However, within these pillars, the extra-financial criteria or

weightings can be modified or enhanced if and when we identify new sustainable development issues.

3. INVESTMENT PROCESS

3a) How are ESG criteria taken into account when defining the universe of eligible stocks for the portfolio?

The universe of eligible stocks for Edmond de Rothschild Euro Sustainable Growth only includes stocks

with extra-financial ratings of A or above.

SELECTION RATIO

From the investment universe (universe of rated stocks) to a universe of SRI eligible

stocks (i.e. ESGS ratings of A and above)

+/- 40 %

3b) How are ESG criteria taken into account at the portfolio construction stage?

The investable universe is defined through the selection of stocks with minimum ratings of A, combined with a selection of growth stocks that operate principally on market segments that are typically exposed to sustainability issues: energy transition, healthcare and population, digitalisation, education & research…

From this investable universe, we conduct financial and stock market analysis and construct a portfolio of around 50 positions.

The structure of the investment process is summarised below:

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The investment process shown above describes the different internal investment constraints that have been

set by fund managers. This is the process as it stands today and it may change over time.

The analysts/fund managers also monitor impact indicators on a regular basis. These indicators help the

team to develop a better understanding on the extra-financial impact of the portfolio. The fund currently

focuses on 4 indicators: CO2 gas emissions (in t/million sales), changes in the accident rate, the number of

women on the executive committee, the signature of the United Nations Global Compact. These indicators

enable the fund managers to keep a close watch on the fund’s extra-financial performance relative to its

benchmark but do not constitute investment criteria.

DISINVESTMENTS TRIGGERED BY ESGS ISSUES

The ESGS ratings for Edmond de Rothschild Euro Sustainable Growth are determined on a dynamic basis.

Controversies can cause ESGS ratings to be downgraded, depending on the severity and frequency of the

issue. In the event of a severe controversy, the company’s ESGS rating is downgraded; the fund manager-

analysts will then put the stock on watch in order to review details and assess the company’s response to

correct the situation. If a company’s rating falls below A, the stock is removed from the portfolio within 15

days.

Generally speaking, disinvestments can be driven by a change in the fund managers’ financial or extra-

financial convictions. Meeting the company’s management can alter our view of the company, cause the

up/downgrade of its ESGS rating, or even trigger an exit from the portfolio due to a low rating.

As far as information on portfolio movements is concerned, new portfolio holdings and exits are recorded in

the fund’s monthly financial and extra-financial reporting, where the fund manager may mention any ESGS-

related issues in the comment section, where relevant.

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3c) Have you developed a specific ESGS Engagement process for Edmond de Rothschild Euro Sustainable Growth?

The investment process for Edmond de Rothschild Euro Sustainable Growth does not include a formal

engagement policy. However the SRI fund manager-analysts do engage with the companies they meet in

order to assess the efforts deployed to manage extra-financial issues and the results obtained in relation to

their stated objectives. These factors are used to update the ESGS ratings. In this respect, during 2014, the

SRI investment and research team carried out 42 ESGS-focused company visits. Most of these visits are in

situ and are traceable via meeting minutes and ESGS ratings revisions, where relevant.

3d) Is there a specific Voting Policy for Edmond de Rothschild Euro Sustainable Growth?

Edmond de Rothschild Euro Sustainable Growth does not have its own Voting Policy. Edmond de Rothschild

Asset Management (France)’s voting policy applies consistently to all equity funds managed by Edmond de

Rothschild Asset Management (France) (cf. section 1b).

3e) Does the Edmond de Rothschild Euro Sustainable Growth fund lend or borrow securities?

No, the fund does not borrow or lend securities.

3f) Does the Edmond de Rothschild Euro Sustainable Growth fund use derivatives?

No, the fund does not use derivatives.

3g) Does the Edmond de Rothschild Euro Sustainable Growth fund invest in high social benefit unlisted companies?

No, the fund does not invest in high social benefit unlisted companies.

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 16/20

4. CONTROLS AND ESG REPORTING

4a) Internal and/or external controls designed to ensure portfolio compliance with ESG rules as defined in section 3 of the Code

Edmond de Rothschild Asset Management (France)’s Risk Control Group has set up specific risk controls via

Dimension, our front/middle/risk management tool, applicable to the Edmond de Rothschild Euro

Sustainable Growth fund. Every day, the Risk Control Group checks that all portfolio holdings have SRI

ratings of A or above and therefore, that any stock with an inferior rating is on the “sell” list.

Edmond de Rothschild Asset Management (France)’s Compliance and Internal Control team carries out

annual controls on the investment process and ESGS analysis methodology implemented for the fund. These

reviews involve ensuring that the each portfolio holding is documented (stock factsheets) and has received an

internal SRI rating.

Finally, the transparency and quality of our ESGS research methodology is audited by Novethic as part of the

SRI labelling process6.

4b) Media used to communicate on the SRI approach applied to Edmond de Rothschild Euro Sustainable Growth

Please click on the following links to view the entire range of documents available for the fund:

- Prospectus :

http://medianet.edmond-de-rothschild.fr/edram/pdf/Prospectus_SH%20EUROPE%20SRI_en.pdf

- KIID (Key Investor Information Document):

http://medianet.edmond-de-rothschild.fr/edram/pdf/KIID_FR0010505578_en.pdf

- Fund factsheet, Financial and extra-financial reporting:

http://medianet.edmond-de-rothschild.fr/edram/pdf/Monthly_Factsheet_FR0010505578_en.pdf

- Corporate SRI Webpage:

http://www.edmond-de-rothschild.com/site/France/en/asset-management/our-expertise/socially-responsible-

investment

- EdR Euro Sustainable Growth specific page:

http://funds.edram.com/en/edmond-de-rothschild-euro-sustainable-growth-FR0010505578

6 The Edmond de Rothschild Euro SRI fund (which then became Edmond de Rothschild Sustainable Growth) receives its first SRI label in September 2009.

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 17/20

- Voting Policy:

http://www.edmond-de-rothschild.fr/SiteCollectionDocuments/edram/pdf/finance-responsable-et-isr/EDRAM-voting-

policy.pdf

- Link to provider of ESG analysis website: http://www.vigeo.com

http://www.reprisk.com

- Detailed information on portfolio stocks:

http://www.edmond-de-rothschild.com/SiteCollectionDocuments/asset-management/isr/EDRAM-inventaire-

portefeuille-EdR-Euro-Sustainable-Growth.pdf

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 18/20

GLOSSARY

SRI (Socially Responsible Investment)

Applying sustainable development principles to investing. Approach to investing which systematically and

concurrently takes into account the three dimensions that are Environment, Social and Governance (ESG) in

addition to the usual financial criteria. Implementation methods can vary from positive selection to

exclusion, or a combination of both, and include (where relevant) criteria for issuer dialogue.

Sustainable Development

“Development that meets the needs of the present without compromising the ability of future generations to

meet their own needs”. This concept includes at least the three economic, social and environmental

dimensions.

ESG criteria (Environment, Social, Governance)

Environmental Dimension: refers to the direct or indirect impact of an issuer’s activity on the

environment.

Social Dimension: relates to the direct or indirect impact of an issuer’s activity on stakeholders based on

universal values (human rights, international labour standards, anti-corruption…)

Governance Dimension: set of policies, regulation, laws and institutions that influence how a given

company is managed, administered and controlled. This dimension also includes relations between the many

stakeholders and the objectives that govern the company. These key players include the shareholders,

executive managers, and members of the board of directors.

Engagement

Investor action (pension funds, insurance companies, asset management firms…) designed to influence the

behaviour of a company over the mid to long-term through the promotion of a deeper integration of

environmental, social and governance factors. This action also comprises dialogue with companies (on an

individual or collective basis), and fund managers’ voting practices - including the submission of resolutions

at shareholder meetings.

CSR (Corporate Social Responsibility)

Applying sustainable development principles to business. Corporate initiative to assess and take

responsibility for the company's effects on the environment, impact on social welfare, and governance (ESG)

in the context of its business and stakeholder relations.

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Stakeholders

A group or individual that can affect (or be affected by) a given entity as it meets its objectives. In the case of

a company, the term refers to all people or legal entities (employees, shareholders, clients, suppliers, local

authorities, NGOs, trade unions, civil society…) with whom it has direct or indirect relations.

SRI Engagement approach/ ESGS Engagement

This approach consists in engaging a positive, constructive, and medium to long term dialogue with

companies and voting at shareholder meetings to encourage them to improve business practices and

communicate on ESGS (Environment, Social, Governance and Stakeholders) issues clearly identified by

Edmond de Rothschild Asset Management (France). The objective is for the companies to improve their

practices, transparency and awareness of ESGS challenges.

ESGS Screening

Edmond de Rothschild’s SRI investment team assesses portfolio holdings or stocks that feature on the

potential buy-list from an extra-financial point of view. The team gives each company a rating based on the

four research pillars: Environment, Social, Governance, Stakeholders, resulting in an overall SRI rating

constructed from the different weightings given to each pillar for the company concerned.

Materiality

The materiality of environmental, social and governance issues reflects the impact that an

improvement/removal of these challenges can have on a company’s stock market performance.

United Nations Global Compact

The Global Compact was launched in 1999 at the Davos Economic Forum in Switzerland by Kofi Annan,

former Secretary General of the UN. The UN Global Compact is a strategic policy initiative for businesses

that are committed to aligning their operations and strategies with ten universally accepted principles in the

areas of human rights, labour, environment and anti-corruption.

EDMOND DE ROTHSCHILD ASSET MANAGEMENT (FRANCE) 20/20

DISCLAIMERS

Key investment risks: risk of capital loss, discretionary management risk, equity risk, SRI selection risk,

rate risk, credit risk and foreign exchange risk. The synthetic risk indicator and performance ranks this

UCITS in category 6 (A share class) on a scale of 1 to 7, which reflects the exposure up to 110% of its assets

on equity markets, which present a high risk/return profile.

Completed draft on 01/09/25015. Non contractual document.

This document is designed exclusively for information purposes. Warning: the quantified data, comments

and analysis contained in this document reflect the feeling of Edmond de Rothschild Asset Management

(France) on the markets, their evolution, their regulation and their taxation, given his expertise, economic

analysis and information owned to this day. They cannot however constitute an any commitment or

guarantee from Edmond de Rothschild Asset Management (France). Any potential investors

must consult their investment service provider or advisor in order to form their own opinion as to the risks

inherent in each UCITS and on whether the risks are appropriate to their own financial and personal

situation. For this purpose, it shall take note of the key investor information document for the investor

(DICI) to each UCITS delivered prior to any subscription and available freely on request at the Edmond de

Rothschild Asset Management (France)’s headquarter or on its website www.edram.fr. The reference to

the label of this UCITS is without prejudice to future results of such UCITS or asset manager. For more

information regarding the Novethic SRI label, see www.novethic.fr . You can also visit our website

www.edram.fr to know more on our SRI expertise.

Ce document is provided by :

Edmond de Rothschild Asset Management (France)

47, rue du Faubourg Saint-Honoré - 75401 Paris Cedex 08

Public limited company with Executive and Supervisory Boards and a capital of €11,033,769 euros

Authorised by the AMF under reference GP 04000015

332 652 536 R.C.S. Paris

Tél : +33 (0)1 40 17 25 25 - Fax : +33 (0)1 40 17 24 42