We have published our updated Responsible Investment Policy

Written By Miikka Hautamaki

Introduction

AIM Capital is an independent alternative investment fund manager (“AIFM”) authorized by the Finnish Financial Supervisory Authority (“FIN-FSA”). AIM Capital provides portfolio management services through managed accounts and open-ended alternative investment funds to institutional investors, such as pension funds, foundations, endowments, and insurance companies.

We are aware of our corporate responsibility and we are dedicated to being responsible corporate citizens and seek to have a positive impact on society and the environment. AIM Capital monitors industry standards and seeks to implement best practices related to ESG. AIM Capital also seeks to take an active role in conversations on this topic with our counterparties and in the investment community, to further the collective understanding more broadly.

This Responsible Investment Policy (“RI Policy”) has been designed to act as the basis for how AIM Capital manages assets in accordance with our responsible business objectives and relevant laws and governance. We believe that by taking an active approach to consider Environmental, Social and Governance (“ESG”) issues in our investment decisions, we reduce risks and explore new opportunities to serve our clients’ interests and society at large. AIM Capital aims to contribute to sustainable development through ESG integration and our commitment to the Principles for Responsible Investment (“PRI”) since 2015.

Scope

The RI Policy applies to all investment capabilities across our platform and is intended to provide a broad framework for our approach to ESG integration. For some discretionary asset management mandates, we may apply responsibility related policies set by the client. We do not apply the responsible investment criteria to index funds, index derivates, or passive exchange-traded funds, unless set otherwise by the client. The specific approach to ESG integration utilized by each portfolio manager will depend on multiple factors, including the objectives of the strategy, investment philosophy and process, asset class and investment time horizon.

Our Approach 

Responsible investment is an approach to investing that aims to incorporate ESG factors into investment decisions to better manage risk and generate sustainable, long-term returns.  We recognize that the integration of ESG factors can lead to superior long-term returns while at the same time having a beneficial impact over the long-term on the environment, on society and on our business through best-in-class governance. 

Assessment of potential risks as well as potential rewards is integral to our investment process. We seek to analyze ESG issues as one of many factors in our due diligence process. Our team assess every aspect of a business’s operations, including but not limited to:

-          Organization

-          Legal, regulatory and compliance framework

-          Investment team

-          Third party service providers

-          Conflicts of interest

-          Risk management

-          Internal processes

-          Governance and operational framework

-          Valuation and pricing policies and principles

-          ESG policies and statements, approach and reporting

AIM Capital considers ESG factors, as appropriate, in evaluating new managers and investments and monitoring portfolios on an ongoing basis. These factors can have far reaching operational, organizational, regulatory, financial, and strategic implications. When we are investing through external managers, we seek to incorporate ESG factors, where relevant, into our ongoing dialogue with them.  We request that all prospective managers respond to our request to complete the PRI Responsible Investment DDQ. 

AIM Capital reviews the external asset managers’ responsible investment practices prior to making any investment decisions and, thereafter, monitors them regularly. We use this review, which covers factors relating to responsible investment policies and statements, resource allocation to responsible investment, ESG integration, ESG reporting, exclusionary screening and owner engagement, for assessing the quality of the external asset managers’ responsible investment.

External managers are expected to notify AIM Capital of any material changes in their RI practices.  The type of asset that the external manager manages, and the particulars of the investment mandate will determine what this means in practice and will need to be assessed on a case-by-case basis.

Permitted Domiciles

We permit the following domiciles for funds: the EU, the USA, the UK, Switzerland, Bermuda, British Virgin Islands, Cayman Islands, Guernsey, Isle of Man, Jersey, EEA excl. the EU, Canada, Liechtenstein, Singapore and Hong Kong. We will review and, where necessary, update the list of permitted domiciles on an annual basis. In the review, we pay attention to the following public listings:

  • Global Forum standard of exchange of information on request for tax purposes

  • EU list of non-cooperative jurisdictions for tax purposes

  • Financial Action Task Force identified jurisdictions with strategic AML/CFT deficiencies

  • Financial Stability Board: Global adherence to regulatory and supervisory standards on international cooperation and information exchange

Implementation

AIM Capital’s Board has primary responsibility for establishing our ESG policies and implementing practices to incorporate ESG principles into our investment, monitoring, and reporting functions.

Miikka Hautamaki
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