Responsibility
Responsibility at Titanium
Titanium’s primary responsibility is to act in the best interests of the customer. Titanium’s business is based on customer orientation, professionalism, insight and trust. In its operations, Titanium also aims to take sustainable development into account and respond to its customers’ growing interest in sustainable investing.
From the point of view of asset management, responsible investing means that, when making investment decisions, the risks and opportunities related to the environmental factors, social responsibility and good governance are taken into account besides financial factors.
Titanium wants to participate in promoting and strengthening the implementation of responsible investing in professional investment activities. In order to participate in the development and reporting of responsible investing, Titanium Fund Management Company Ltd has signed the UN Principles for Responsible Investment and is a member of Finland’s Sustainable Investment Forum (FINSIF).
Titanium constantly strives to bring new perspectives and ideas to develop the responsability of its operating methods.
Titanium Fund Management Company Ltd has published the Principles for Responsible Investing to help to understand the choices made in investment operations.
Consideration of sustainability risks at Titanium
9 March 2021
Sustainability risk refers to an environmental, social or governance-related event or circumstance whose occurrence may have a material adverse impact on the value of an investment.
Titanium Fund Management Company Ltd
Titanium Fund Management Company Ltd aims to manage its sustainability risks by incorporating the consideration of sustainability risk into its investment decision-making processes. The method and extent of taking sustainability risks into account varies from one financial product to another. With regard to real estate funds managed by Titanium Fund Management Company Ltd, sustainability risks are managed by preparing due diligence reports during the acquisition phase of investments and by assessing the investment, tenants and contractors in new construction projects. With regard to financial products that invest in equities and/or ETFs, Titanium Fund Management Company Ltd aims to manage sustainability risks by, among other things, reviewing the ESG ratings given to companies by external ESG risk assessors when making new investments and, in particular, utilising the Best-in-Class strategy and thematic investing in the selection of equities and ETFs. As a result of these strategies, companies that are exposed to lower-than-average sustainability risks compared to other parties in the sector are selected as the funds’ investments. Taking sustainability risks into account is expected to have a positive long-term impact on the return on financial products offered by Titanium Fund Management Company Ltd as sustainability risks decrease.
Titanium Investment Services Ltd and Titanium Life Ltd
A large proportion of the sustainability risks relevant to Titanium Investment Services Ltd and Titanium Life Ltd are directly related to the financial products for which they provide advice on. The method and extent of taking sustainability risks into account therefore varies between different financial products. Titanium Investment Services Ltd and Titanium Life Ltd aim to focus their existing partnership relationships on such operators and advice on such financial products that have begun to take sustainability risks into account in their own operations and investment decisions for the financial products subject to advice. When offering a financial product, the suitability and/or appropriateness of the product is assessed, but sustainability risk aspects are not currently taken into consideration in the actual investment advice or personal recommendation concerning insurance. If the customer highlights the importance of taking sustainability risks into account, they are offered suitable investment options that take sustainability risks into account. To the extent that Titanium Life Ltd offers insurance as an insurance intermediary on behalf of an insurance company, Titanium Life Ltd takes sustainability risks into account in its operations in accordance with the instructions of the insurance company it represents at any given time.
Personnel and consideration of sustainability risks in remuneration policies
9 March 2021
Titanium regularly trains its personnel in sustainability issues and the consideration of sustainability risks.
Titanium aims to manage its own sustainability risks related to society and governance by monitoring the well-being and satisfaction of its employees, among other things. Titanium uses incentive schemes that reward its employees, tied agents and insurance agents for long-term work in line with the long-term interests and objectives of the customer and the company (e.g. accrued sales bonuses and employee options).
In Titanium’s view, the sustainability of operations (e.g. taking sustainability risks into account) supports the long-term success of companies operating sustainably and the return on financial products. The remuneration schemes applied at Titanium are aligned with Titanium’s business strategy and reflect Titanium’s long-term benefit. Therefore, Titanium considers that its remuneration policies are consistent with the consideration of sustainability risks. Sustainability risks are taken into account in all of Titanium Fund Management Company Ltd’s own products. Thus, Titanium Fund Management Company Ltd’s employees do not receive any rewards for offering financial products whose investment activities do not take sustainability risks into account.
No consideration of adverse impacts of investment decisions, investment advice or insurance advice on sustainability factors
Titanium Fund Management Company Ltd, Titanium Investment Services Ltd and Titanium Life Ltd (“Titanium”) do not currently take into account the principal adverse impacts of their investment decisions, investment advice or insurance advice at the company level in accordance with Article 4 of the Regulation (EU) 2019/2088 of the European Parliament and of the Council on sustainability-related disclosures in the financial services sector (“SFDR”). Principal adverse impacts refer to the impacts of investment decisions or investment advice that have negative impacts on sustainability factors. Sustainability factors include environmental, social and employee matters, respect for human rights and anti-corruption and anti-bribery matters.
Titanium has assessed that the data required to meet the requirements is limited, poorly comparable and partly unreliable. Market practices for the assessment, measurement and monitoring of principal adverse impacts are not yet fully developed and established. For this reason, Titanium is unable to provide investors with a high-quality and informative statement on the principal adverse impacts (PAI statement).
Thus, Titanium does not currently take into account the principal adverse effects on sustainability factors. As market practices become more precise and the availability of data improves, Titanium will assess its opportunities to take into account the principal adverse impacts on sustainability factors. The assessment is carried out at least once a year.

