ESG and Responsible Investment Policy
Our commitment to sustainability
ESG Policy – Executive Summary
Ayaltis’ commitment to sustainability is applied both externally, as part of ESG incorporation into the investment process, and internally through the adoption of sustainable business practices, starting from the promotion of a healthy, respectful, and sustainable working environment.
We integrate ESG considerations within the investment process: Ayaltis incorporates ESG factors into its investment and operational due diligence processes into alternative investments. The ESG due diligence findings are formally documented within the research and operational due diligence reports which are presented to the Investment Committee. Moreover, ESG considerations can be hardwired into client investment mandates in accordance with specific investor preferences.
We have an ESG Team to set the agenda for all sustainability-related activities: Ayaltis has organized an ESG Team that comprises key people across core different functions, including: investment, business, operations compliance and operational teams. The role of the ESG Team is to set the agenda for all ESG activities within Ayaltis. The ESG Team escalates any matters to the Board and shall respond to any requests for information or action by the Board. The Board of Ayaltis has the ultimate responsibility on the approval of any changes in the ESG policy or in the ESG integration in the investment and non-investment processes and across the firm.
We believe that mitigating ESG risks strengthens downside protection: This commitment incorporates transparency and fairness into all our activities. To this end, Ayaltis believes that an assessment of Environmental, Social and Governance (ESG) issues is a crucial part of investment and operational risk management across all the investments. This investment universe comprises a wide variety of investment managers, investment strategies and investment vehicles in the alternative space. A common thread through each of these investments is the belief that mitigating ESG risks strengthens downside protection and enhances the investment community’s reputation.
We seek appropriate disclosure on ESG issues in the entities we invest: Ayaltis is also committed to raise awareness among market participants and its stakeholders, including clients, employees and shareholders on ESG issues. We seek appropriate disclosure on ESG issues by the entities in which we invest and promote active dialogue around ESG issues.
We promote best practice in the industry through active engagement: Ayaltis engages on a regular basis on ESG matters with its underlying managers through a dedicated ESG questionnaire and active dialogue. The main objective is to gather updated information on results, priorities and leading practices by external managers, as well as fostering dialogue on ESG themes among stakeholders.
We are an equal opportunity employer with staff from a variety of backgrounds, cultures and nationalities: Ayaltis aims to recruit the best talent available as an equal opportunity employer. Our current staff members come from a variety of backgrounds, cultures and nationalities. Ayaltis is committed to promote work-life balance, through the adoption of flexible working arrangements and other practices.
We promote volunteer work and community engagement by team members. Ayaltis welcomes initiatives by its staff to carry out fundraising and charitable donations in favour of NGOs.
Roles and responsibilities
Ayaltis integrates its commitment on sustainability and sustainable investing in its own governance structure at the levels of Supervision and Implementation, as outlined below.
The Board of Ayaltis is responsible for oversight and monitoring of the performance and progress of the company regarding corporate responsibility, sustainability and sustainable investing.
The CEO is also a member of the ESG team, with the role of promoting the integration of ESG principles within corporate strategies and coordinating the implementation of the ESG Policy and responsible investment initiatives, reporting to the Board on their progress.
Supervision responsibilities include:
- periodic verification of the level of application of the Policy and related procedures, through dialogue with the ESG Team;
- oversight to ensure the adoption of appropriate procedures for the operational implementation of the Policy, in agreement with the ESG Team and Investment Teams and with the coordination of the CEO;
- continuous dialogue with investors and other stakeholders, in particular the underlying fund managers;
- promotion of the culture of sustainability within Ayaltis and among the other peers and stakeholders of the company.
We have an ESG Team to set the agenda for all sustainability-related activities.
Ayaltis has organized an ESG Team that comprises key people across the different functions: Investment, Business, Compliance and Operational teams.
The role of the ESG Team is to set the agenda for all ESG activities within Ayaltis. The team meets quarterly to review activities, targets and achievements. Notes of each meeting are reported to the Board for assessment and review. The CEO shall provide direct communication to enable the ESG Team to escalate unresolved issues to the Board and to respond to any requests for information or action by the Board.
Implementing Responsible Investments not only applies to dedicated ESG personnel but is integrated into the activities of any role in the company. Ayaltis engages all employees to support and align with the Policy as part of their day-to-day role in the workplace.
The pre-trade compliance checks on ESG criteria are carried out as part of the due diligence process conducted by the research analysts on any investment. On the operational side, the CRO reviews all the material and has a veto power on all investment decisions. Post trade monitoring is carried out on the investment side by the assigned research analyst.
For impact investments, Ayaltis may engage external advisors to provide an independent assessment and review of the impact generated by its investments.
Continuing Education and Performance assessment
Compliance with all applicable laws and regulations is of paramount importance. All Ayaltis staff receive training in these areas on joining the firm and at least annually thereafter, including modules on anti-bribery and corruption, market conduct and information security. In addition to our compliance training programme, Ayaltis encourages ad hoc training to suit the needs of individual members of staff. We also support several employees who undertake studies for relevant professional qualifications, including CFA and CAIA.
The ESG policy can be updated or reviewed, in light of changes in the regulatory and market context or in the priorities of Ayaltis on ESG issues and sustainable investments. The Board of Ayaltis has the ultimate responsibility on the approval of any changes/integration in the ESG policy or in the ESG integration in the investment and non-investment processes. The ESG Team can propose integration, revisions or updated to the Board and is responsible to communicate the content of the new policy within the organization. The ESG policy is made public through the website of Ayaltis and through its media channels.
The main recipients of this ESG Policy include senior management, employees and members of the ESG Teams, with specific reference to the responsibilities defined for each in the document itself. The ESG Policy is distributed and is available through the company intranet and it is also available for clients of Ayaltis.
Ayaltis’s approach to sustainable investment
As part of its strategy and approach to investments, Ayaltis recognizes the value of sustainability.
We believe that mitigating ESG risks strengthens downside protection and supports the selection and management of investments, providing several benefits:
- reinforcing the risk assessment of each investment;
- identifying and monitoring risk and opportunity drivers associated with sustainability issues;
- improving dialogue with managers and promoting the adoption of responsible investment practices;
- generating value and positive impacts for investors and
Sustainability is considered part of the added value in the core business of the company, which is to generate consistent returns for investors through active, diversified and transparent investment strategies.
For this reason, we integrate ESG considerations within the investment process, as appropriate to the relevant investment solutions.
The methods of integrating ESG factors in the various stages of the investment are briefly listed below; the ESG Team adopts tools and procedures to implement the sustainable investment approach defined by the company within its operations.
Multi-manager investment solutions
Sourcing and Due Diligence
ESG considerations are an integral part of the investment and operational due diligence that Ayaltis carries out for the appointment of new managers. The integration of ESG factors in the investment process has been motivated by the conviction that such factors have a direct effect on risk management and performance. The policy, which disciplines all investments irrespective of geography or asset class, drives the due diligence process of all third-party managers. Such due diligence, which is composed by an investment and operational section, is then reviewed by the Investment Committee before approving any investment.
The ESG assessment will include, as appropriate, the following areas across our investment managers, investment strategies and underlying investment vehicles:
Investment Manager ESG Assessment
- Investment manager corporate governance;
- Investment manager cash management and control policy;
- Investment manager key support staff independence, reporting lines and escalation procedures;
- Investment manager alignment of interests (for example, allocation to own investment strategies alongside external clients);
- Investment manager regulatory and compliance considerations;
- Reference checks of the investment manager via Ayaltis’ network of industry contacts;
- Independently commissioned background checks on investment manager principals and entities;
- Investment manager commitment to ESG standards, such as being a signatory to PRI. Investment Strategy ESG Assessment
- Investment manager integration of ESG factors into their investment process and strategy;
- Standalone ESG / responsible investment policy available for investors;
- Designated responsibility for ESG aspects within the investment strategy;
- Access to ESG data sets relevant to the investment Investment Vehicle ESG Assessment
- Investment vehicle corporate governance;
- Investment vehicle management and control policy;
- Investment vehicle key terms consistent for all shareholders;
- Investment vehicle independent administrator and track record
In addition, the following areas form part of the assessment:
– Environmental Issues:
- Climate action according to the Paris Agreement targets;
- Water & energy – consumption, efficiency, scarcity;
- New legislation regarding the use and disposal of plastic safety & quality standards;
– Social Issues:
- Human rights in managing global operations;
- Cyber security arrangements – understanding and managing the risks;
- Business ethics – fair hiring practices, pay, policies, tax;
- Safety & quality
– Governance Issues:
- Remuneration and Assessment – practices aligned with investor priorities and beliefs;
- Board and Executive members – composition, fair appointment practices, succession planning;
- Ownership structure;
- Compliance Policies – Anti Money Laundering, Conflict of Interests, Personal Accounts;
- Counterparty selection and
The due diligence, including the integrated ESG sections, is submitted for the approval to the Investment Committee of Ayaltis. The Fund is discussed and reviewed and follow ups regarding ESG could be asked before the formal approvement of the investment by the Investment Committee.
We seek appropriate disclosure on ESG issues in the entities we invest
The analysts are also asked to assess the manager’s effective application of responsible investment practices. Ayaltis promotes period engagement with approved managers on ESG issues and the adoption of sustainable investing practices.
Portfolio construction and risk management
The portfolio construction and risk management aim at evaluating the contribution of ESG factors to determining investment strategy and asset class. For those investment mandates that specifically requires it, the risk management also evaluates the alignment of the portfolio as a whole and the selected managers with the client’s sustainability priorities.
The chart below includes the points that are checked by our Research Team during the Due Diligence process.
Ayaltis’s commitment in addition to investments
Ayaltis’ commitment to corporate responsibility is applied both externally, as part of ESG incorporation into the investment process, and internally to promote a healthy, respectful and sustainable working environment.
Ayaltis is committed to minimize any direct environmental impact of its activity, by carefully analysing any potential risk and setting up best practice to limit its consumption of paper and energy, as well as emissions from corporate travel.
We are an equal opportunity employer with staff from a variety of backgrounds, cultures and nationalities. Ayaltis’ business success and reputation are founded on integrity and trust in everything that we do. Our future success depends on our staff, and Ayaltis recruits the best talent available as an equal opportunity employer, valuing talent, diversity and inclusion in the workplace. Ayaltis is committed to promoting work- life balance, through the adoption of flexible working arrangements and other practices.
We promote volunteer work and community engagement by team members, whenever consistent with job duties and responsibilities. Ayaltis welcomes initiatives by its staff to carry out charitable fundraising work and supports charitable donations and initiatives.
Ayaltis operates in a highly regulated sector where governance matters are taken very seriously. We seek to meet the highest standards of corporate governance in all jurisdictions. Ayaltis is committed to promoting best practice across the asset management industry.