Sycomore AM : report in compliance with French regulation (« Article 173 »)

In accordance with the provisions of Article 173 of Law No. 2015-992 of 17 August 2015 on the energetic transition for green growth, Sycomore Asset Management has prepared a report, covering the 2017 financial year, which presents how it integrates environmental, social and governance (ESG) criteria into the investment policy of the Sycomore AM funds and how it manages ESG risks.

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Sycomore Sélection Responsable : report in compliance with French regulation (« Article 173 »)

In accordance with the provisions of Article 173 of Law No. 2015-992 of 17 August 2015 on the energetic transition for green growth, Sycomore Asset Management has prepared a report, covering the 2018 financial year, which presents how it integrates environmental, social and governance (ESG) criteria into the investment policy of the Sycomore Sélection Responsable fund and how it manages ESG risks.

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Sycomore Partners : report in compliance with French regulation (« Article 173 »)

In accordance with the provisions of Article 173 of Law No. 2015-992 of 17 August 2015 on the energetic transition for green growth, Sycomore Asset Management has prepared a report, covering the 2018 financial year, which presents how it integrates environmental, social and governance (ESG) criteria into the investment policy of the Sycomore Partners fund and how it manages ESG risks.

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Sycomore Francecap : report in compliance with French regulation (« Article 173 »)

In accordance with the provisions of Article 173 of Law No. 2015-992 of 17 August 2015 on the energetic transition for green growth, Sycomore Asset Management has prepared a report, covering the 2018 financial year, which presents how it integrates environmental, social and governance (ESG) criteria into the investment policy of the Sycomore Francecap fund and how it manages ESG risks.

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Sycomore Long / Short Opportunities : report in compliance with French regulation (« Article 173 »)

In accordance with the provisions of Article 173 of Law No. 2015-992 of 17 August 2015 on the energetic transition for green growth, Sycomore Asset Management has prepared a report, covering the 2018 financial year, which presents how it integrates environmental, social and governance (ESG) criteria into the investment policy of the Sycomore Long / Short Opportunities fund and how it manages ESG risks.

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Sycomore Allocation Patrimoine : report in compliance with French regulation (« Article 173 »)

In accordance with the provisions of Article 173 of Law No. 2015-992 of 17 August 2015 on the energetic transition for green growth, Sycomore Asset Management has prepared a report, covering the 2018 financial year, which presents how it integrates environmental, social and governance (ESG) criteria into the investment policy of the Sycomore Allocation Patrimoine fund and how it manages ESG risks.

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ESG integration policy

This document provides an overview of Sycomore AM’s integration policy for extra-financial or environmental, social and governance (ESG) considerations. This policy lies at the heart of the firm’s mission statement: to bring a human dimension to investing. It provides a basis for dialogue with Sycomore AM’s stakeholders and serves as a framework and guide for the firm’s approach as a responsible investor. The document also presents the principles, analysis tools and human resources dedicated to ESG integration, as well as Sycomore AM’s transparency, voting and engagement policy.

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Voting policy

Pursuant to the provisions of Articles 319-21 and 321-132 of the French Financial Markets Authority (AMF) General Regulations, Sycomore Asset Management has established a voting policy, updated as needed, which outlines the conditions under which it intends to exercise the voting rights linked to the securities held by the funds which it manages.

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Report on the exercise of voting rights

Pursuant to the provisions of Articles 319-22 and 321-133 of the French Financial Markets Authority (AMF) General Regulations, each year Sycomore Asset Management draws up a report on the conditions under which the voting rights linked to the securities held by the funds which it manages were exercised.

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Exclusion policy of companies related to controversial weapons

In line with the Ottawa (1997) and Oslo (2008) Conventions, Sycomore Asset Management excludes any direct investment, through both equity and bonds, in companies producing, selling, stockpiling or transferring anti-personal mine or cluster munitions.

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Engagement Policy

This document constitutes Sycomore Asset Management’s engagement and shareholder dialogue policy. It sets out the grounds for Sycomore AM’s engagement, its objectives, along with the tools, processes and practices leading to its implementation.

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Policy for the selection of order execution entities

Pursuant to the provisions of Article 314-75-1 of the French Financial Markets Authority (AMF) General Regulations, Sycomore Asset Management has established a policy for the selection and evaluation of entities which provide aid in making investment decisions and execute orders.

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Anti-bribery and corruption policy

This Policy defines clear principles which outline Sycomore AM’s position on Bribery & Corruption.

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Natural capital strategy

This document summarizes the approach adopted by Sycomore AM regarding environmental issues and the concept of natural capital. It provides a structure as to the duties imposed by article 173 of the French law governing Energy Transition for Green Growth, voted on August, 17th 2015, which enforcement decree, n°2015-1850, was published in the French Official Journal on December, 29th 2015. Indeed, the spirit and intent of the law reinforce institutional investors’ publication requirement first, as to the inclusion of environmental, social and governance (ESG) criteria in their investment policy, and second their policy regarding the contribution to the energy and ecological transition and the fight against global warming.

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RI Transparency Report

The PRI Reporting Framework is a key step in the journey towards building a common language and industry standard for reporting responsible investment (RI) activities. This RI Transparency Report is one of the key outputs of this Framework. Its primary objective is to enable signatory transparency on RI activities and facilitate dialogue between investors and their clients, beneficiaries and other stakeholders.

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AFG -FIR-Eurosif Transparency Code – SRI equity funds

Socially Responsible Investment is a key feature in the strategic positioning and management of Sycomore Sélection Responsable, Sycomore Happy@Work, Sycomore Eco Solutions, and Sycomore Shared Growth (formerly Sycomore European Growth), as well as Sycomore Sélection Crédit, which is covered by a separate transparency code. This is our 8th edition of the SRI Transparency Code covering the period from December 31st 2018 to the publication date stated in the document. Our full answers to the SRI Transparency Code are available by clicking on the link below and are available in the annual reports for each of our open-ended SRI funds and on our website.

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AFG -FIR-Eurosif Transparency Code – Sycomore Sélection Crédit & Sycomore Next Generation

Sycomore Asset Management has been active in Socially Responsible Investment (SRI) since 2008. SRI is a key feature of the strategic positioning and management of Sycomore Sélection Crédit, Sycomore Next Generation, Sycomore Sélection Responsable, Sycomore Happy@Work, Sycomore Eco Solutions, and Sycomore Shared Growth (formerly Sycomore European Growth). The four latter funds are covered by a separate transparency code. This is our 8th edition of the SRI Transparency Code covering the period from December 31st 2018 to the publication date stated in this document. Our full answers to the SRI Transparency Code are provided below and are available in the annual reports for each of our open-ended SRI funds and on our website.

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SYCOMORE ASSET MANAGEMENT CLAIMS MANAGEMENT POLICY

In accordance with regulations, Sycomore Asset Management has and maintains an operational procedure for the reasonable and rapid handling of complaints addressed by its clients.

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Sycoway as an Investor 2018

Report published on June 30th 2019 relating to the asset management company Sycomore AM and complying with the requirements of Article 173-VI of Law 2015-992 of August 17th 2015 pertaining to the “energy transition for green growth”, for the year 2018.

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