Sustainability and Responsible Investing Policy

 

Irrespective of its size, every company has a proportional impact on economic and social progress. At 3KIP our values remain the cornerstone for fulfilling our mission. Corporate social responsibility and sustainability are part of the Company’s long-standing commitment to contribute positively to economic growth and social progress, thereby generating value for all stakeholders over time.

The sustainability and responsible investment policy adopted by 3KIP is supported by an Integrated Management System which includes the following:

  • A procedure and issue sheet for assessing double materiality for the Company and its shareholders
  • Guidelines on the application of sustainability criteria in risk and opportunity assessment

 

Introduction

At 3KIP each investment has value. To this end we have a “bottom-up” management system that focuses on the fundamentals of the companies in which we invest, and in particular on:

  • the company’s Management team
  • the sector in which each company operates
  • the company’s ability to generate profits over time and
  • the price at which the company’s shares are traded, which is to say its value for money.

Since March 2021, 3KIP's policies have been in line with: the new EU Sustainable Finance Reporting Directive; the EU Climate Change Taxonomy; as well as the specifications relating to the inclusion of sustainability risk assessment criteria in the investment decision-making and new product design process, the provision of investment advice, and the provision of relevant information to investors.

In this context, this sustainability policy (issued in March 2021) is the revised 2nd version and its content is as follows:

Commitment Statement

The 3KIP principles, as already expressed by shareholders and the company’s entire Management team and all employees, include the duty to operate in the long-term interests of customers and beneficiaries of our activities. Acknowledging the importance of adopting ‘Rules’ that will transform this mission statement into reality, we decided to utilise the international initiative known as the “UN Principles for Responsible Investment” (UN PRI) and we declare our commitment to voluntarily follow these ‘Rules’ to incorporate relevant criteria into our strategy and decision-making, giving priority to substantive issues of sustainability and in particular in relation to environmental and social sustainability and corporate governance. Our objective is to ensure sustainable returns and to contribute to issues relevant to investors and society as a whole.

 

Purpose and objectives

Respect for and protection of fundamental human rights, respect for and protection of the environment, and combating corruption are key factors in economic prosperity and sustainability both now and in the future. 3KIP operates in accordance with the principles and standards laid down by the statutory framework but seeks, in addition to those, to perform its mission reliably, responsibly, and transparently, respecting the needs of customers and all those affected by its operations.

The Sustainability Policy has been renamed the 3KIP “Sustainability and Responsible Investment Policy” and includes the following additional sections:

- Purpose and objectives: The purpose of this policy is to ensure that our investments can generate value for our stakeholders over time and for society as a whole by investing in a better -and more human- future.

Our key mission focuses on humans and the quality of life now and in the future, and can be achieved by implementing a more holistic (uniform and comprehensive) assessment of investment decisions and investments.

In this context, the Sustainability and Responsible Investment Policy complements the existing Investment Management System and related policies that have been adopted by the Company.

Scope

Implementation of this policy is tied into the current statutory framework and recognised international standards which the European Union incorporates into the sustainability information disclosure guidelines (see relevant Annex).

By implementing the Sustainability and Responsible Investment Policy, 3KIP seeks, insofar as these matters pertain to it, to actively contribute to achieving the 2030 Sustainable Development Goals and the European strategy for a sustainable and fair transition to an inclusive, non-coal-dependent economy.

Responsibility for implementing this policy lies with the Company’s Board of Directors which evaluates the results of the policy each year. Responsibility for coordinating and monitoring implementation of this policy lies with the Compliance Department in collaboration with all competent Divisions and Company stakeholders.

This policy applies to all activities which the Company performs in its dual role both as an investment advisor and as manager of individual and collective portfolios.

The Company communicates its policy to all its shareholders and collaborates with its customers and associates on the results of its implementation. It also participates in actions designed to disseminate information about the results of evaluation of sustainability criteria in order to take them into account in the context of continuous performance improvements.

Core principles

Implementation of the Sustainability and Responsible Investment Policy starts from the Company’s own internal environment and extends out to its sphere of influence, in other words the Company’s shareholders, individuals and groups of persons who are affected by or affect the Company’s operations.

The core principles relevant in implementing the Sustainability and Responsible Investment Policy are as follows:

- We invest in our staff, developing their skills and bolstering their participation in implementing strategy and achieving Company objectives. (see HR and Performance Incentives Policy)

- We use criteria to weigh up and prioritise material sustainability factors by which we take decisions. (see Sustainability and Responsible Investment Evaluation Procedure)

- Emphasis is placed on corporate governance and above all on transparency and accountability issues, including the disclosure of information about corporate sustainability.

- We support regulatory compliance and timely adaptation to recognised international standards in the publication and review of corporate information relating to issues that are material for corporate sustainability.

- We are investing in collective action and in collaboration with other businesses, bodies and above all stakeholders to promote and establish the principles of sustainability at national and European level.

- We generate added value by creating new products, initiatives and social investments.

  • - We seek to help ensure that customers’ needs are met in practical terms by systematically and responsibly providing them with information. 

Priorities and risk control 

The Sustainability and Responsible Investment Policy serves a dual function:

- to reduce the likelihood of negative impacts arising from Company operations.

- to increase the likelihood of a positive impact and value for shareholders and stakeholders by prioritising investments that meet the sustainability criteria laid down in the current statutory framework and any that may be specified in future guidelines issued by the competent bodies.

Effective implementation of our policy is ensured by developing targeted systems and methodological approaches in line with international reporting standards for information about sustainability and the European Union’s regulatory framework  on mandatory disclosure of information about the impact of economic activities on climate change, protection of human rights and other core sustainability factors. To select and weigh up the sustainability criteria, the Company has adopted and follows:

- the principles of the UN’s voluntary initiative on responsible investments, known as UN PRI (see an annex to the policy on core principles),

- the SASB international standard on ranking and weighing sustainability issues by sector and economic activity and

- the recommendations of EFRAG on the evaluation of corporate information relating to (a) the description of the business model, (b) the strategy followed to address risks and opportunities related to fundamental sustainability issues and (c) the degree of compliance with the existing statutory framework and in particular the European Directive on the Disclosure of Non-Financial and Diversity Information (EU NFRD 2014). In this context, the statements made by companies on their compliance with Article 8 of the Climate Change Taxonomy regulation are also evaluated.

 

The company recognises the importance of taking collective action as a key tool in implementing this policy and collaborates with the National Network for CSR, CSR Hellas (www.csrhellas.org) to promote more widely the principles of sustainability and responsible investment among the Greek business community, investors and other key stakeholders at both national and European level. 

The annual evaluation of the results of implementing this policy is part of the process of evaluating material sustainability issues for the company (see relevant content) and is approved by the Board of Directors. In addition, the overall results of the annual evaluation are included in the information provided to customers and stakeholders and posted on the Company’s website.

All new employees recruited by the Company are informed about this policy when they are recruited. The Company has a training course to implement its Sustainability and Responsible Investment policy.

Implementation criteria and tools

The evaluation system for companies that are included in the individual and collective portfolios 3KIP manages and those proposed to its customers when providing investment advice is tied into sectoral (relating to the sector and country those companies operate in) qualitative and quantitative criteria. An important criterion in weighing up the results of the evaluation are good governance / sustainability practices, and the inclusion of the precautionary principle, in other words the principle that no significant harm should be done so that neither the environmental nor social objectives are significantly harmed. The sectoral approach used by the Company is based on international SASB standards which are (a) in line with the principles of the Task Force for Climate-related Financial Disclosures and (b) have already been tied into the International Financial Reporting Standards.  

 

Related policies

In order to achieve its objectives, in the context of ensuring responsible business conduct, 3KIP has adopted and implements the policies on the following matters, among others:

  • Code of Conduct for Persons in Positions of Responsibility
  • Whistleblower Policy
  • Pre-employment screening
  • Gift entertainments & Anti-bribery Policy
  • Remuneration Policy
  • GDPR Policy (privacy policy for the personal data of customers)
  • Policy on the prevention of money laundering and terrorist financing
  • Active participation and voting rights policy

 

Sustainability and Responsible Investing Policy.pdf