Responsible Investment Policy 2025
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 a responsible corporate citizen 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 derivatives, 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. AIM Capital recognizes 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.
AIM Capital takes into account the adverse impacts of sustainability risks regarding the Funds it manages to the extent that such risks form an intrinsic part of other risks, such as market risk and operational risk. The Funds invest into financial products that do not promote environmental or social characteristics or have sustainable investment as an objective.
Assessment of potential sustainability risks as well as potential rewards is integral to our investment process. We seek to analyse ESG issues as one of many factors in our due diligence process. Our team assesses every aspect of a business’ 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 continues to monitor data available to it in respect of PAI with the aim of implementing the consideration of adverse impacts in conjunction with application of regulatory deadlines.
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 our 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 this needs 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
Extract from remuneration policy regarding sustainability integration
AIM Capital’s remuneration policy seeks to ensure that the remuneration (fixed and variable) paid to employees promotes effective risk management while not encouraging excessive risk-taking. To be able to ensure this, the policy contains guidelines on how the company seeks to identify, measure, govern, internally report and control the risks associated with remuneration systems in our business.
It is of importance to AIM Capital that the employees integrate ESG thinking into applicable parts of the investment process. Employees are encouraged to seek new and better ways to improve work with sustainability risks and adverse impacts in the investment process. Employees are also encouraged to pursue new and improved ways to create ESG-friendly products and services.
Employee efforts that lead to either the identification of new sustainability risks or AIM Capital being able to mitigate adverse sustainability impact, are endorsed by the company. Such efforts among others are to be taken into consideration when variable remuneration is being considered. By linking ESG issues to remuneration, the company hopes to achieve financial impact on employees whose compensation is linked with ESG measures driving better ESG performance.
Compliance with laws, regulations and professional standards
The Company and its employees must comply with all applicable laws, rules and regulations, both internal and external, and with all applicable ethical, fiduciary, prudent, and due diligence standards that are expected from experienced investment professionals.
Disclosures
The disclosures of AIM Capital explain the details of how AIM Capital complies with the disclosure requirements in accordance with the European Regulation (EU) 2019/2088 of 27 November 2019 on sustainability‐related disclosures in the financial services sector (“SFDR”).
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.
Assessment of the guidelines
The up-to-date nature of the guidelines is assessed by the Board of Directors at least annually and if needed. The policy has been approved by the Board of Directors on 25.8.2025.