Pursuant to EU Regulation 2019/2088 of 27 November 2019
The Goodyear Pension Fund was created in 2002. It is incorporated as a non-profit association under the supervision of the Commissariat Aux Assurances. Its purpose is to provide retirement benefits for the employees of Goodyear S.A. and Goodyear Tires S.A. in Luxembourg.
In order to achieve this objective, the pension fund invests in financial assets.
Financial investments are made in accordance with the investment policy filed with the Commissariat Aux Assurances (CAA).
This investment policy determines the way in which the pension fund intends to obtain a long-term return in order to cover its pension commitments. The policy aims to be prudent in its investments, while taking into account environmental, social and governance (ESG) factors.
The pension fund is aware of the need to act at its level in the choice of investments that ensure
The pension fund wants to assert in all transparency this will to reach these sustainable goals in a progressive way. Therefore, in the framework of its contractual relations with its partners, the pension fund requires, in general, that the latter follow an approach aimed at progressively integrating ESG factors into their management, in particular in the dispensation of their duty to advice.
The pension fund's investment philosophy is based, among other things, on the conviction that issues related to sustainability factors are and will remain a major concern in the coming years. The pension fund believes that combining non-financial fundamentals with traditional financial criteria will help build even more sustainable life insurance policies in the long term.
As part of its investment process, the Goodyear Pension Fund, through its asset manager, takes an approach to sustainability risks that derive from the integration of ESG criteria**. The pension fund, through its asset manager, implements a framework for integrating sustainability risks into investment decision-making processes. This framework is based on, inter alia
These methodologies contribute to the management of sustainability risks in two complementary ways:
* In accordance with article 3 of the European regulation ** In accordance with article 6 of the European regulation
Exclusions are one of the pillars of the Pension Fund's approach to address sustainability risks and key negative impacts. The exclusion lists are based on data from third party providers and allow the asset manager and thus the Goodyear Pension Fund to exclude assets from potential investments that are exposed to high sustainability risks.
The sectoral exclusion policies focus on the following ESG factors:
As part of the Goodyear Pension Fund’s holistic risk management approach ESG factors are integrated in our risk control processes through its asset manager. The reporting of ESG assessments is a standing agenda item in the risk governance bodies. For actively managed security investments, the Goodyear Pension Fund has chosen to directly integrate ESG factors into its investment decisions, through its asset manager and potentially third-party fund managers. This means that ESG data and information flows directly into the analysis of investments as do traditional financial and business information. Data considered include indicators like ESG ratings and controversy flags, which help identifying companies which might be vulnerable to ESG risks, but also underlying data on polluting activities, revenue shares of critical products, industrial action, etc. to allow a more detailed analysis. For investments in passive instruments ESG integration is applied where possible.
At the Goodyear Pension Fund, adverse impacts of an investment decision on sustainability factors (“Adverse Sustainability Impacts”) are adequately considered during the investment decision process through its asset manager. Sustainability factors’ mean, environmental, social and employee matters, respect of human rights, anti-corruption and anti-bribery matters. The asset manager assesses and monitors Adverse Sustainability Impacts with adverse sustainability indicators. It has procedures in place to identify how its investment management activities are linked to Adverse Sustainability Impacts and how to prevent, mitigate and remediate them.
The Goodyear Pension Fund has identified the following sustainability issues as the most relevant Adverse Sustainability Impacts, (“Principal Adverse (Sustainability) Impacts/PAIs”)
The prioritization of the PAIs (and the key performance indicators (KPIs) derived from the PAIs) as well as the applied metrics related thereto may vary for different asset classes and there will be re-prioritization over time. This is inter alia related to the fact that both, data availability and data quality on the PAIs vary across asset classes and will further evolve over time