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Sustainable Investing Policy

(Information valid from March 10, 2021)

Introduction

Credit Suisse Asset Management strives to become a sustainability leader in the financial industry. In September 2019, we announced our plan to increasingly incorporate environmental, social, and governance considerations – the ESG factors – into the investment process of several of our strategies. Following this announcement, we have been making every effort to accelerate our sustainable investing agenda and implement it across many of our core asset classes. Working in close cooperation with Institutional Shareholder Services Inc. (ISS), our partner for proxy voting, we have increased our proxy voting coverage by defining specific regional proxy voting policies, and we will continue to do so. Finally, in order to reinforce our commitment to sustainability, we have strengthened our dedicated in-house ESG team.

We take a systematic approach to sustainable investing. This means that ESG factors are taken into account at various stages throughout the investment process. Our sustainable investment strategies employ ESG criteria when defining the investment universe (ESG exclusions), integrate ESG factors directly into the investment process, extend traditional research views to encompass sustainability considerations, and reflect on ESG factors when selecting and defining exposure to securities (ESG integration). We then monitor the resulting portfolio in terms of its sustainability characteristics. We support sustainability initiatives through proxy voting, active participation in annual general meetings (AGMs), and engaging with investee companies. In addition, we also provide detailed ESG reporting to enhance portfolio transparency for our clients. Lastly, Credit Suisse Asset Management and Credit Suisse participate in several sustainability networks and initiatives.

Going forward, we have pledged to further develop and promote sustainable investment products and services that seek to generate financial returns while incorporating ESG considerations. We are convinced that our focus on sustainability not only accords with but also explicitly assists us in our fiduciary duty to preserve and increase the value of our client portfolios. However, responsibility toward our clients is not the only factor that drives us to pursue sustainability – we, too, are increasingly faced with the consequences that financial investments have on our environment and our society.

1. Credit Suisse Asset Management’s Sustainable Investing Policy

At Credit Suisse Asset Management, we systematically engage in sustainable investing. Sustainable investing refers to the process of considering environmental, social, and governance information (ESG factors) when making investment decisions. To ensure that our sustainable investment products meet the standards set by our clients and the standards we set ourselves, we have established dedicated sustainable investment principles that are governed by the Sustainable Investing Policy. Credit Suisse Asset Management’s Sustainable Investing Policy applies to all portfolios whose investment process includes ESG considerations and/or that have a defined sustainable investment objective. A dedicated ESG team governs and maintains the Sustainable Investing Policy.

Credit Suisse Asset Management’s Sustainable Investing Policy is aligned with the Credit Suisse Sustainable Investment Framework.

1.1. Ambitions of our sustainable strategies

Portfolios pursuing a sustainable investing strategy integrate ESG factors into the investment decision-making process, thereby aiming to create more sustainable portfolios and achieve an improved expected risk/return profile; some of them target specific sustainable investment objectives. The importance of and focus on individual ESG factors may vary depending on the overall investment strategy and investment universe.

In accordance with the MSCI ESG Key Issue Hierarchy,1 Credit Suisse Asset Management considers, quantifies, and publishes monthly scores of the following ESG factors for its sustainable equity and fixed income portfolios:

Environmental (E)

  • Climate change (including various carbon emission data points)
  • Environmental opportunities (including varous data points on renewable energy and technology)
  • Natural capital (including clean water and biodiversity data points)
  • Pollution and waste (including waste management and toxic emissions data points)

Social (S)

  • Human capital (including health and safety data points)
  • Product liability (including product safety and responsible investment data points)
  • Stakeholder opposition score, social opportunities (including access to healthcare and communications data points)

 

Governance (G)

  • Corporate govenance (including ownership, control, and remuneration data points)
  • Business behavior (including business ethics and tax transparency data points)

1 For further information on the MSCI ESG Key Issue Hierarchy and the methodology for the calculation of the individual factors, please refer to: MSCI ESG Ratings and MSCI ESG Ratings Methodology.

The published scores of the ESG factors on the portfolio level are calculated by a weighted aggregation of the available scores of the underlying securities. Aggregated scores for environmental, social, and governance aspects as well as an overall ESG portfolio score are published for our equity and fixed income portfolios.

1.2. Key principles of our Sustainable Investing Policy

At Credit Suisse Asset Management, we place great importance on the systematic consideration of sustainability factors as part of our sustainable investment strategies. We are convinced that a clear governance of our approach to sustainability enables our sustainable strategies to achieve their investment ambitions. Our Sustainable Investing Policy is based on five key principles: fulfilling our fiduciary duty to our clients, ESG exclusions, ESG integration and/or sustainable thematic investments, active ownership, and transparency toward clients.

1.3. Principle 1: Safeguarding the fiduciary duty to clients

We are convinced that our focus on sustainability helps Credit Suisse Asset Management fulfill its fiduciary duty to act in the best interest of its clients. In our view, considering ESG factors offers our investment teams the means to make better-informed decisions. In addition to our fiduciary responsibility toward our clients, we are committed to mitigating the negative consequences and fostering the positive effects that our financial investments have on our environment and our society, where possible.

1.4. Principle 2: Application of ESG exclusions

Credit Suisse Asset Management has defined the following three categories of exclusions:

  • Norms-based exclusions
    We exclude companies that fail to comply with international treaties on controversial weapons such as the Convention on Cluster Munitions, the Chemical Weapons Convention, the Biological Weapons Convention, and the Treaty on the Non-Proliferation of Nuclear Weapons.
  • Values-based exclusions
    We exclude companies that derive more than 5% of their revenue from conventional weapons and firearms, tobacco production, gambling, or adult entertainment. We also exclude companies that derive more than 20% of their revenue from tobacco distribution and conventional weapons support systems and services. In addition, a revenue limit of 20% applies to investments in coal (coal mining and coal-based electricity generation). This threshold can be further lowered over time to reflect the transition toward a low-carbon society.
  • Business-conduct exclusions
    Companies found to systematically violate international norms, where the breaches are particularly severe, or where management is not open to implementing necessary reforms, are placed on a watch list and may be excluded from the firm-wide investment universe. This process is governed by a dedicated committee that keeps the final list of excluded companies and is responsible for ensuring that the list is communicated to investment teams in a timely manner.

    Business-conduct-based exclusions are considered a last resort. We prefer to engage with investee companies with the aim of increasing our impact on preventing future breaches. Companies that are able and willing to take action may be subject to a period of prolonged engagement in which Credit Suisse and company management agree on targets and timelines for improvement.

Values-, norms-, and business-conduct-based exclusions are defined in the Credit Suisse Sustainable Investment Framework. These exclusions may evolve over time.

The exclusions described above are applied in the following manner:

Credit Suisse Asset Management excludes firms that violate norms related to controversial weapons, such as personal mines, cluster munitions, and nuclear weapons, as defined according to the recommendation of SVVK-ASIR, from all of its actively and passively managed portfolios of listed equity and fixed income securities. Further exclusions from passively managed portfolios are based on the rules governing the construction of specific ESG indices that the portfolios aim to replicate.

Credit Suisse Asset Management applies norms-, values-, and business-conduct-based exclusions to actively managed sustainable portfolios of listed equity and fixed income securities. In the case of norms-based exclusions, Credit Suisse Asset Management applies additional exclusions, setting thresholds on revenues from, for example, the production of delivery platforms and components for controversial and/or nuclear weapons.

1.4.1. Specific exclusions applied for investment products awarded the Febelfin "Towards Sustainability" label

More specific exclusions are applied for investment products that have been awarded the Febelfin "Towards Sustainability" label.2

Some investment products are subject to a defined investment universe that reflects the funds' investment approach. They are also subject to more stringent exclusions:

  • Norms-based, values-based, and business-conduct-related exclusions
  • More stringent exclusions and thresholds across sectors including coal mining, conventional and unconventional oil and gas extraction, generation of electricity, and violations of the United Nations Global Compact (UNGC) principles

As a result, the following companies, countries and sectors are excluded from the investment universe of those investment products:

  • Breaches of the UNGC principles: Companies whose activities clearly infringe upon the UNGC are excluded. The ten UNGC principles define fundamental responsibilities in the areas of human rights, labor, environment, and anti-corruption. These principles are derived from the Universal Declaration of Human Rights, the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work, the Rio Declaration on Environment and Development, the United Nations Convention Against Corruption, and the Organization for Economic Co-operation and Development’s Anti-Bribery Convention.
  • Country exclusions: We do not finance countries (via government debt or indirectly via state-owned companies) that are subject to international sanctions or that violate basic principles like those stated in the UNGC.
  • Illegal and controversial weapons: Manufacturers of controversial weapons such as land mines and cluster bombs, as well as manufacturers of nuclear, biological, and chemical weapons, are excluded.
  • Conventional weapons and firearms: Companies that derive more than 5% of their revenue from manufacturing conventional weapons or firearms are excluded. Companies that derive more than 5% of their revenue from the production of tailor-made components, which are developed primarily in order to be integrated into a weapon system, are excluded as well.3
  • Tobacco products: Companies that derive more than 5% of their revenue from manufacturing tobacco products and companies that derive more than 5% of their revenue from distributing those products are excluded.
  • Coal extraction: Companies that derive more than 5% of their revenue from coal extraction are excluded.
  • Unconventional oil and gas extraction: Companies that derive more than 5% of their revenue from unconventional oil and gas extraction (e.g. oil extraction from tar sands and/or oil and gas extraction through hydraulic fracking of shale and/or from arctic drilling) are excluded. Companies planning to expand their activities to cover unconventional oil and gas extraction are also excluded.
  • Conventional oil and gas extraction: Oil and gas extraction companies that derive less than 40% of their revenue from activities related to natural gas extraction or renewable energy sources are excluded.
  • Electricity generation: Electricity utilities with carbon intensity that is not aligned with a below-two-degrees scenario (in 2021 max. gCO2/kWh of 393, in 2022 max. gCO2/kWh of 374) are excluded.

If no carbon-intensity data are available, the following rules apply:

– Electricity utilities for which more than 10% of power production is based on coal are excluded.
– Electricity utilities for which more than 30% of power production is based on oil and gas are excluded.
– Electricity utilities for which more than 30% of power production is based on nuclear sources are excluded.
– Electricity utility companies with expansion plans that would increase their negative environmental impact or that run contrary to a below-two-degrees scenario are excluded.
– Electricity generation companies that are constructing additional coal- or nuclear-based power production installations are excluded.

  • Phase-out of unaligned oil and gas extraction and electricity generation: We invest in companies involved in conventional oil and gas extraction and electricity generation that are best in their peer group selectively and to a limited extent. Our portfolios can consist of no more than 5% of such companies, i.e. companies that do not comply with the above requirements for conventional oil and gas extraction or electricity generation.
  • Gambling: Companies that derive more than 5% of their revenue from gambling are excluded.
  • Adult entertainment: Companies that derive more than 5% of their revenue from adult entertainment are excluded.

The list of investment products that follow these guidelines are available on the Towards Sustainability webpage.

 

2 The label aims to reassure investors that the financial product is managed with sustainability in mind and is not exposed to unsustainable practices. Further information can be found at www.towardssustainability.be
3 The investment team decides if a company is classified as a weapons manufacturer according to the definition of “Towards Sustainability”. This assessment is part of our investment process, which is based on a fundamental bottom-up approach.

1.5. Principle 3: Application of ESG integration and/or investing with a sustainability objective

Application of ESG integration means that Credit Suisse Asset Management incorporates ESG factors at various steps of the investment process by combining financial information with information about environmental, social, and governance aspects. The ESG integration approaches vary by asset class and investment style and depend on the availability of ESG data and tools.

Investing with a sustainability objective means that Credit Suisse Asset Management implements investment strategies that allocate capital to companies offering solutions to societal challenges and pursue a sustainable investment objective. A sustainable investment objective is achieved through a dedicated investment process focused on investments in themes and sectors whose economic activities address specific ESG challenges, e.g. through sustainable thematic investing. Typically, this means investing in companies, securities of companies (such as green bonds), or strategies that address one or more of the United Nations’ Sustainable Development Goals, or investing with a dedicated environmental or social investment objective. For passively managed strategies, this means replicating an index with a sustainability objective.

1.6. Principle 4: Application of active ownership

Credit Suisse Asset Management ensures that investee companies follow good governance practices by engaging with them and by exercising voting rights.

Being a shareholder and partial owner of a company comes with certain rights and duties. Above all, however, it presents an opportunity to effect positive change. To Credit Suisse, active ownership means exercising these rights and fulfilling our fiduciary duties on behalf of our clients who own shares in companies around the world through our funds. The two main elements of active ownership – engagement and proxy voting – constitute some of the most powerful tools in the pursuit of our environmental, social, and governance goals.

Through our funds and client portfolios, we hold shares in many companies in Switzerland, Europe, and across the globe. As shareholders, we have the opportunity to engage with companies on behalf of our clients, communicate our goals and expectations, and exert concrete influence with our voting power at annual shareholder meetings.

Furthermore, please find below our disclosures:

1.7. Principle 5: Reporting and transparency

Sustainability information at the product level can be found in our monthly fund fact sheets, which include a section dedicated to ESG factors. Fund fact sheets are available online and can be provided on request by relationship managers.

In addition to the monthly fund fact sheets about individual funds, selected Thematic Equity funds publish their own impact and engagement reports. Examples of these reports can be provided on request by relationship managers.

Example of the ESG section of a fund fact sheet

Sample fund fact sheet: The ESG section of a fund fact sheet contains four main sections: ESG overview, that is fund rating versus benchmark and individual scores, ESG rating breakdown, controversies, that is portfolio and benchmark exposure to companies involved in controversies, and carbon emission intensity of the portfolio and the benchmark.

2. Special topics

Treatment of derivatives and short positions

Derivatives may be used as technical portfolio management tools, for hedging purposes, or as an additional source of return. The use of derivatives must not be at odds with the responsible nature of the ESG strategy of a given product. The types of derivatives permitted are generally governed by the fund prospectus. The underlying assets are evaluated similarly to a direct investment in such assets according to the following rules for single-stock futures and single-name credit default swaps (CDS):

  1. Short positions in single stocks, single-stock options, and buying protection in single-name CDS are not allowed in companies that are excluded for norms-based business activity violations according to the Credit Suisse Sustainable Investment Framework.
  2. Short positions in single stocks, single-stock options, and buying protection in single-name CDS are allowed in companies excluded for values-based business activity violation according to the Credit Suisse Sustainable Investment Framework.
  3. Regarding (2) above, curve trades on companies excluded for values-based business activity violations according to the Credit Suisse Sustainable Investment Framework are allowed only if the notional value of the credit short position equals the notional value of the credit long position.

Limit on products for which no ESG data are available

A maximum of 20% of a sustainable investment portfolio may be invested in securities of entities or asset classes for which no ESG-related information is available. This applies in particular to asset classes for which ESG factors are insufficiently defined at present or which are not yet covered by external data providers (e.g. hedge funds). We expect this limit to be lowered over time as the availability of ESG investment concepts and ESG research coverage, external or internal, improves.

Specific rules for Thematic Equity funds

For those parts of our Thematic Equity portfolios for which no ESG-related information is available, we may use additional analyses, such as information obtained from additional data providers, our proprietary questionnaires, and pre- and post-trade compliance checks.

Example of a sustainable investment and impact questionnaire

Sustainable investment and impact questionnaire contains several questions related to the quality of the company’s products or services, ways of measuring their impact on people and the environment, privacy and data security, human capital development, governance, and environmental policies.

ESG data and research

We use a range of external ESG research providers and rating agencies in combination with our in-house sustainability and financial analyses. Specifically, we derive our external ESG research from MSCI, RepRisk, and ISS. Our core ESG data are fully integrated in our portfolio management software, Aladdin by BlackRock.

Portfolio monitoring

Credit Suisse Asset Management conducts pre-trade and post-trade compliance checks daily. In the event that certain violations of our exclusion criteria are revealed, we conduct an appropriate escalation process. All violations are archived. Credit Suisse Asset Management senior management is informed about any violations on a monthly basis. The data sources for our daily monitoring activities are our portfolio management platform, Aladdin by BlackRock (position data), and MSCI ESG (business exposure data), as well as individual third-party sources such as Evalueserve.

3. Regulatory disclosures

Transparency of sustainability risk policies

Pursuant to EU Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability-related disclosures in the financial services sector (the SFDR) Article 3, financial market participants shall publish on their websites information about their policies on the integration of sustainability risks in their investment decision‐making process.

Sustainability risk is defined as an environmental, social, or governance event or condition that, if it occurs, could have a material negative impact on the value of the investment. The materiality of sustainability risks is determined by the likelihood, magnitude, and time horizon of the risk materializing. Credit Suisse Asset Management believes that the integration of material environmental, social, and governance factors in financial analysis and investment decision-making is pivotal and can reduce risks and lead to improved investment outcomes over time. 

Sustainability-related issues are an integral part of our risk-review process, and we continuously capture these risks and integrate sustainability factors into our investment research, analysis, investment process, and risk management.

Credit Suisse Asset Management has established a Sustainable Investing Policy that specifies how ESG factors are integrated into the investment process in order to identify sustainability-related opportunities and to reduce sustainability risks.

Sustainability risks can be understood as a subcategory of traditional risk types (e.g. credit, market, liquidity, operational, and strategy risk) and are identified and managed in the context of risk-management processes. Since sustainability risks differ between asset classes and investment styles, they are defined at the portfolio level. Credit Suisse Asset Management identifies sustainability risks by considering the sector, industry, and company exposure of the portfolio either in absolute terms or relative to the benchmark. Proprietary analysis may be supported by specific materiality frameworks that define industry-specific ESG factors that are material to a company.

Transparency of adverse sustainability impacts at the entity level

SFDR Article 4 requires financial market participants to publish and maintain on their websites a statement on due diligence policies with respect to principal adverse impacts of investment decisions on sustainability factors.

The legal entities mentioned below in the Applicability section consider principal adverse sustainability impacts within the investment decision process.

Furthermore, financial market participants shall include in the information provided: 

  • Information about their policies on the identification and prioritization of principal adverse sustainability impacts and indicators
    Sectors and companies that are proven to have a detrimental impact on society or the environment are excluded from the investment universe of all portfolios as part of the regular due diligence process. Manufacturers of controversial weapons such as land mines and cluster bombs, as well as manufacturers of nuclear, biological, and chemical weapons, are excluded (norms-based exclusions).

    Techniques to identify and prioritize principal adverse sustainability impacts and indicators related to portfolios that follow a sustainable investment strategy are described in Credit Suisse Asset Management’s Sustainable Investing Policy, which defines, for instance, clear criteria for excluding companies that have a detrimental impact on society or the environment. These exclusion criteria are considered by the investment teams during the investment decision-making process and are monitored independently. In addition, Credit Suisse Asset Management identifies the ESG factors that may have adverse sustainability impacts by conducting proprietary analysis and making use of specific materiality frameworks that define industry specific ESG factors for its portfolios.
  • A description of the principal adverse sustainability impacts and of any actions in relation thereto taken or, where relevant, planned
    Currently, the extent to which principal adverse sustainability impact indicators as defined by the Regulatory Technical Standards (RTS Level 2) can be taken into consideration in investment decisions by a financial market participant is not yet fully determined. This is due to the fact that availability of data regarding those indicators is limited, and investee companies might not yet be in a position to provide all of the expected relevant ESG information. Acting as financial market participants in accordance with SFDR, the legal entities listed below in the Applicability section consider adverse sustainability impacts in their investment decisions and advisory processes to the extent possible. Once the standards for implementing adverse impact considerations are established, the entities will adapt their procedures accordingly. By June 30, 2023, they will include details of the assessment of principal adverse sustainability impacts for the reference period from January 1, 2022, to December 31, 2022, and engagement policies related to the reduction of impacts during the aforementioned reference period in their reporting.
  • Brief summaries of engagement policies in accordance with Article 3g of Directive 2007/36/EC, where applicable
    In accordance with Article 3g of Directive (EC) 2007/36 of the European Parliament and of the Council (Shareholder Rights Directive II – SRD II), Credit Suisse Asset Management aims to bring about positive change in investee companies by adopting active ownership practices. Credit Suisse Asset Management applies the Credit Suisse Engagement Policy to investments in shares of companies domiciled in the European Economic Area (EEA) and listed on a recognized trading venue in the EEA. More information can be found in the Credit Suisse Engagement Policy Statement and obtained on request from relationship managers.

    At Credit Suisse Asset Management, we exert influence on companies’ business operations through proxy voting, i.e. the fiduciary exercise of our voting rights at general shareholder meetings, and through active engagement, i.e. via maintaining a permanent dialogue with companies and boards on sustainability-related topics. We believe that active ownership increases the value of the companies in which we invest over the long term, and ultimately improves the risk/return profile of our portfolios. Moreover, by accelerating the transition to a more sustainable economy, active ownership can create tangible benefits for people and the planet.
  • A reference to their adherence to responsible business conduct codes and internationally recognized standards for due diligence and reporting and, where relevant, the degree of their alignment with the objectives of the Paris Agreement
    At Credit Suisse Asset Management, we have recognized the role we play in addressing environmental, social, and governance challenges. We strive to facilitate investment products and services that produce environmental and social benefits in line with the United Nations’ Sustainable Development Goals while seeking to generate financial returns for our clients. Credit Suisse Asset Management believes that the most effective way to foster sustainable long-term change is through collective action. With this in mind, Credit Suisse Asset Management supports industry initiatives and engages with stakeholders and policymakers on key sustainability topics by actively participating in a number of sustainability networks and initiatives worldwide.

Credit Suisse Asset Management and Credit Suisse actively participate in a number of sustainability networks and initiatives.

Transparency of remuneration policies in relation to the integration of sustainability risks

Pursuant to SFDR Article 5, financial market participants shall include in their remuneration policies information on how those policies are consistent with the integration of sustainability risks, and shall publish that information on their websites.
Credit Suisse has a Group-wide compensation policy in accordance with the SFDR’s requirements.

Transparency of the promotion of environmental or social characteristics and of sustainable investments on websites

Pursuant to SFDR Article 10, financial market participants shall publish and maintain on their websites the following information for each financial product that either promotes environmental or social characteristics or has sustainable investments as its objective

  • A description of the environmental or social characteristics or the sustainable investment objective
    For investment funds following a sustainable investing strategy, this information is disclosed in the ESG section of the relevant fund fact sheets, which are available online and can be provided on request by relationship managers.

    For ESG real estate funds, the information is available in the “Sustainability-related disclosures” section online and can be provided on request by relationship managers.
  • Information on the methodologies used to assess, measure, and monitor the environmental or social characteristics or the impact of the sustainable investments selected for the financial product, including its data sources, screening criteria for the underlying assets, and the relevant sustainability indicators used to measure the environmental or social characteristics or the overall sustainable impact of the financial product
    For investment funds following a sustainable investing strategy, this information is available in the ESG section of the relevant fund fact sheets, which are available online and can be provided on request by relationship managers.

    For ESG real estate funds, the information is available in the “Sustainability-related disclosures” section online and can be provided on request by relationship managers.
  • The information referred to in Articles 8 and 9
    For investment funds following a sustainable investing strategy, this information is available in the ESG section of the relevant fund fact sheets, which are available online and can be provided on request by relationship managers.

    For ESG real estate funds, the information is available in the “Sustainability-related disclosures” section online and can be provided on request by relationship managers.
  • The information referred to in Article 11
    For investment funds that follow a sustainable investing strategy, this information is available in the “Transparency of the promotion of environmental or social characteristics and of sustainable investments” section of the annual report.

Review of disclosures

SFDR Article 12 requires financial market participants to ensure that any information published in accordance with Article 3, 5, or 10 is kept up to date. Where a financial market participant amends such information, a clear explanation of such an amendment shall be published on the same website.

The following table explains the amendments on disclosures related to SFDR Articles 3 and 5.

Table of revisions

  Date

  Article

  Explanation of amendments

  10.03.2021

  All

  Disclosures according to SFDR Level 1 requirements

 

Applicability

Regulatory disclosures in this document apply to the legal entities listed below.

  • Credit Suisse Asset Management (Switzerland) Ltd.
  • Credit Suisse Fund Management S.A.
  • Credit Suisse (Italy) S.p.A. – in respect to Asset Management
  • Credit Suisse (Hong Kong) Ltd. – in respect to Asset Management
  • Credit Suisse (Singapore) Ltd. – in respect to Asset Management
  • Credit Suisse Investment Partners (Switzerland) Ltd.

Further reading