Sustainability at portfolio level

Consideration of sustainability risks and integration of ESG criteria at investment process and portfolio level
Bellevue is addressing the issue of sustainability not only at the corporate level, but also in its investment practices and solutions. All our investment portfolios and funds are systematically reviewed for sustainability risks and breaches of elementary human rights (as defined, for example, by UN Global Compact principles). Besides upholding strict exclusion criteria – such as serious controversies that violate universal norms regarding the environment, human rights or good corporate governance – environmental, social and governance factors are integrated into the fundamental analysis of every company through an ESG integration process in which the associated financial risks or opportunities are evaluated with respect to future stock market performance. ESG ratings compiled by global leading ESG research providers are included in this process, which are interpreted with some degree of caution and, in certain cases, with a rather critical eye.

In accordance with the Paris Climate Agreement of December 2015, Bellevue Asset Management Ltd is committed to the climate goals and supports measures to reduce global warming. BAM attaches great importance to climate-friendly or CO2-efficient portfolios that contribute to achieving the goals of the Paris Climate Agreement. The CO2 intensity is regularly measured at portfolio level and assessed against the relevant investment universe or fund benchmark. 

Portfolio managers and analysts also conduct an active and constructive dialogue with the management or other relevant stakeholders of the invested companies regarding environmental, social and governance aspects (Engagement). Our voting rights are actively exercised at the AGM’s through proxy voting.

In the following, our management approach of sustainability risks and ESG integration approach are described in detail.


In accordance with Regulation (EU) 2019/2088 of the European Parliament and the Council of the European Union of November 27, 2019 on sustainability-related disclosures in the financial services sector, Bellevue Asset Management AG is committed to transparency with respect to:

  • policy for managing sustainability risks,
  • adverse sustainability impacts at entity level
  • compensation policies in relation to the integration of sustainability risks,
  • the integration of sustainability risks,
  • adverse sustainability impacts at financial product level,
  • the promotion of environmental or social characteristics in pre‐contractual disclosures,
  • sustainable investments in pre‐contractual disclosures,
  • the promotion of environmental or social characteristics and of sustainable investments on websites
  • the promotion of environmental or social characteristics and of sustainable investments in periodic reports

“Sustainability risks” is defined in Regulation (EU) 2019/2088 of the European Parliament and of the Council of the European Union of November 27, 2019 on sustainability-related disclosures in the financial services sector (Sustainable Finance Disclosure Regulation, SFDR) as an environmental, social or governance event or condition that, if it occurs, could cause an actual or a potential material negative impact on the value of the investment.

Bellevue Asset Management AG and its subsidiaries have integrated sustainability risks into the investment decision-making processes of all their actively managed strategies and associated funds with the aim of identifying, assessing and, if possible and appropriate, mitigating such risks.

While every investment strategy can be exposed to such sustainability risks to varying degrees, the projected impact of sustainability risks on the returns of the investment strategies will depend on the specific investment strategy.


The results of this integration and evaluation are summarized as follows:

For those investment strategies that promote environmental or social characteristics in the sense of SFDR, the projected negative impact on financial returns is lower compared to “non-ESG” investment strategies. This is attributed to the risk-mitigating ESG investment strategies, their future-oriented investment approach, their emphasis on sustainable financial frameworks, their activism in dealings with companies/issuers as well as their avoidance of non-compliant companies/issuers.

All investment strategies may invest in accordance with international environmental, social and corporate governance standards (hereinafter referred to as "ESG"). The investments or securities selected in accordance with such criteria can entail a significant subjective element. ESG factors that are integrated into the investment process may differ with respect to investment themes, investment categories, investment philosophy and the subjective application of ESG indicators that determine portfolio design and the underlying assets. Accordingly, no guarantee is made that every investment by an investment strategy will meet all of the ESG criteria.

ESG investment policy

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The ESG investment policy of  Bellevue Asset Management Ltd encompasses following key elements:


Bellevue Asset Management Ltd. is committed to adhering to internationally recognized norms and excludes companies with serious violations of human rights, environment, labor norms and involvement in corruption. No investments may be made in companies that seriously violate environmental standards, human rights and business ethics. This is measured by their compliance with principles and standards of UN Global Compact Compliance, UN Guiding Principles for Business and Human Rights  and the International Labor Organisation. Moreover, Bellevue Asset Management Ltd excludes investments in companies with activities in the field of controversial weapons.


In contrast to the exclusion of companies due to violations of global norms, value-based exclusions are based on social, ethical and moral views. Bellevue Asset Management Ltd tends to avoid companies with activities in areas that are classified as controversial according to prevailing social views, but can assess them for a possible investment on a case-by-case basis. Areas classified as ethically or morally controversial include:

  • Tobacco industry
  • Gambling
  • Adult entertainment
  • Nuclear energy
  • Thermal coal / Energy production from thermal coal
  • Palm oil
  • Conventional weapons
  • Fracking & oil sands

Company affiliations with animal experiments, medical genetic engineering and embryonic stem cell research may also fall into this category. As a healthcare investment specialist, Bellevue Asset Management applies a nuanced approach in this respect. Their healthcare strategies accommodate generally recognized principles where possible. They categorically rule out investments in companies associated with illegal activities, an example of which would be intervention in the human genome for cloning purposes. However, nowhere in the world can medicines be approved without animal studies, even today. Their healthcare experts prioritize compliance with humane animal research principles in line with the principle of the 3Rs: Replace, Reduce and Refine.

ESG integration

ESG integration refers to the systematic inclusion of environmental, social and governance factors into the fundamental research process and the ensuing assessment of the associated financial risks or opportunities with respect to future stock market performance. This approach gives their portfolio managers a holistic picture of an enterprise. While the aggregate ESG scores generally used for this purpose are taken into consideration, their experts interpret them with caution and exercise critical judgment. Most ESG rating methods are based on a predefined systematic approach which, however, does not always result in an objective or fair assessment of risk. In fact, they tend to systematically disadvantage start-ups and small cap companies relative to their large-cap brethren. A lack of manpower and experience in ESG issues may result in a company being underrated. Another contributing factor is the application of a set of criteria dictated by the methodology that cannot be reliably applied to every company in a given sector. In the biotech industry, for instance, young companies still in the R&D stage may be systematically underrated because they are not yet generating (much) revenue from the sale of medicines, which naturally puts them at a disadvantage versus established healthcare giants in the highly weighted “access to healthcare” criterion. That is why the portfolio managers take an in-depth look at potential or ostensible ESG laggards and always make a point of talking in person to the ESG specialists of the cooperation partners. Accordingly, Bellevue Asset Management does not apply a minimum rating threshold and it will usually not adopt a best-in-class approach (systematic exclusion of companies that score below a minimum ESG rating) when it comes to making investment decisions.


Portfolio managers and analysts conduct an active and constructive dialogue with the management or other relevant stakeholders of the invested companies regarding environmental, social and governance aspects. If there are indications of substantial controversies in the area of ESG in the run-up to the company meeting, the portfolio managers/analysts are required to introduce these constructively in the company dialogue and to document progress (e.g. strategy and process adjustments, improvement of ESG rating) over time. Engagement activities can be carried out directly and bilaterally with the respective company or also bundled with other co-investors within the framework of a so-called collaborative engagement process. The UN PRI offers a "Collaborative Platform" where investors can publish initiatives and find allies for their engagement processes. Engagement will be undertaken taking into account materiality and proportionality considerations. The level of engagement can vary depending on the size of the position held by an investment strategy, the market capitalization of the company, the stage of corporate development an entity is in and other factors. ESG engagement activities are recorded as part of the regular documentation of the company meetings. Sometimes individual case studies are suitable for publication purposes, which can then be made available to a wider audience.

Furthermore, Bellevue Asset Management AG also protects the long-term interests of its investors by making active use of its voting rights at the annual general meetings of the companies in its portfolios via proxy voting.


Bellevue Asset Management endorses the climate goals of the Paris Agreement adopted in December 2015 and supports measures to mitigate global warming. considerable importance to green investment portfolios that can support progress towards the climate goals of the Paris Agreement is attached. Carbon intensity (tonnes of carbon emitted per USD 1 mn of sales) is measured regularly at portfolio level and scored based on the relevant investment universe or fund benchmark. It is worth pointing out that the majority of our investment is in the healthcare sector, which naturally is exposed to comparatively fewer carbon emissions than the industrial sector, commodities or the energy sector.

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Adverse sustainability impacts (PAI)

Bellevue Asset Management AG currently does not take an adverse impact of investment decisions on sustainability factors (so-called principal adverse indicators) into consideration due to the lack of market data required to determine the adverse sustainability impact and the corresponding weightings. Bellevue Asset Management AG will provide information on whether and how the most important adverse effects of investment decisions on sustainability factors will be taken into account by December 31, 2022 at the latest.

Compensation policy

The following basic compensation principles apply throughout Bellevue Group:

The methods used to determine compensation for the Board of Directors and the Group Executive Board and for all Company employees are transparent, understandable, fair and reasonable.

All pay packages are well balanced and take into consideration the operational and strategic responsibilities of each individual role as well as individual performance levels and the demands placed on each individual.

Compensation is commensurate with the position held and should reflect individual achievement of specific quantitative as well as qualitative goals as well as the operating results of Bellevue Group and the relevant Group companies.

Pay packages should be appropriate and competitive compared to the compensation offered by companies operating in the same field and labor market, and they must be sound and sustainable irrespective of the current course of business.

Variable compensation will be reduced or forfeited in the event of serious violations of internal or external rules, regulations or the law (incl. ESG/sustainability).

All governing bodies and individuals at Bellevue Group with the authority to make decisions concerning compensation policies and payouts must abide by and uphold these basic compensation principles. The latest Bellevue Group compensation report can be found here.


Our commitment to sustainability is reflected in Bellevue Asset Management AG’s status as a signatory of the UN Principles for Responsible Investment (UN PRI). As a responsible institutional investor, we have always been bound to act in the best interests of our stakeholders over the long run. In our role as a fiduciary, we recognize that environmental, social and corporate governance (ESG) topics will have even more of an impact on the risk/return profiles of investment portfolios and on performance. We acknowledge that applying these principles will lead to a better alignment of investor interests with the broader aims and interests of society.

Bellevue Asset Management AG is also a signatory to EUROSIF's transparency code for sustainable investment products and its BB Adamant Sustainable Healthcare (Lux) Fund has been awarded the Austrian Ecolabel for sustainable financial products.