The Group aims to bring about change by asking companies that do not meet the
ethical criteria to justify their objectionable conduct. Dialogue therefore encourages
companies to act responsibly in the interests of the environment, their employees,
the community and other stakeholders. Companies are excluded from the Group’s
investment universe only if they fail to respond positively and risk repeating
their objectionable conduct.
In order to ensure impartiality during assessment and exclusion procedures, the
Group set up the Council on Ethics, a consultative body comprising Group heads of the departments most involved
in investments and the head of the Corporate Social Responsibility unit as well
as two external academics.
The Council is charged with assessing the justifications given by the companies
and, where they are non-existent or unsatisfactory, drawing up reasoned proposals
to exclude companies that violate the Group’s ethical criteria. The Chief Financial
Officer (CFO) is ultimately responsible for deciding on exclusions.
If the reasons for exclusion no longer apply, the Council on Ethics may suggest
the readmission of companies to the Group’s investment universe.
The system provides for constant monitoring of investments, including checks
designed to prevent the acquisition of securities issued by excluded companies.
A half-yearly report is also sent to the Corporate Centre’s Group Risk Management
service.