Responsible Investment Policy

Cohen & Company Financial (Europe)Limited (“CCFEL”) is committed to investing responsibly.

We encourage responsible and sustainable business practices in all of our investment strategies and in all the companies in which we invest.

Objectives

Integrating relevant ESG factors into our investment processes protects investment returns and protects value for our clients.

Principles

Cohen & Company Inc, (CCFEL’s Parent company) has been a signatory to the United Nations sponsored Principles for Responsible Investment (PRI) since January 2019. The six principles of the PRI are:

• Principle 1: Incorporating ESG issues into investment analysis and decision-making processes
• Principle 2: Being active owners and incorporating ESG issues into ownership policies and practices
• Principle 3: Seeking appropriate disclosure on ESG issues by the entities in which investments are completed
• Principle 4: Promoting acceptance and implementation of the principles within the investment industry
• Principle 5: Working together to enhance effectiveness in implementing the principles
• Principle 6: Reporting on our activities and progress towards implementing the principles

Implementation

• Considering ESG factors as part of the investment process, including companies/investment analysis, portfolio construction, and internal reporting and risk management. Factors considered include:
  • Human capital development
  • Accounting and financial reporting practices
  • Legal disputes/litigation costs/fines
  • Business ethics
  • Anti-corruption policies
• Including a section on “compliance with ESG criteria” in every credit report on insurers in which we invest
• Raising relevant ESG issues with the management of companies in which we invest as part of our due diligence and ongoing engagement
• Complying with all relevant local and international laws, including adherence to international protocols on banned products
• Avoiding companies whose practices or products cause significant social or environmental harm

Corporate Responsibility

It is our policy that all officers, directors and employees maintain the highest level of integrity in all dealings on behalf of the company. We believe the high level of integrity with which it conducts its affairs will be a major factor in our success.

You can read our Code of Business Conduct and Ethics here.

In addition, we strive to create a respectful and inclusive work environment. We do not tolerate any form of harassment or discrimination in the workplace by any employee for any reason. In order to provide equal employment and advancement opportunities to all individuals, all employment decisions are based on merit, qualifications, and abilities.

We are an equal opportunity employer and do not discriminate against employees or applicants on the basis of race, color, religion, gender, age, national origin, handicap, veteran status, marital or domestic partnership or civil union status, or sexual orientation.