Responsible investment

The materiality analysis shows that responsible investing is a key sustainability issue. Bellevue comprehensively implements ESG criteria in its investment processes and portfolios, taking into account the growing regulatory requirements.

Various sustainability approaches have been embedded into our ESG framework, which we have systematically implemented and are continuously developing.

Bellevue’s ESG investment guidelines basically comprise the following elements:

Exclusion criteria based on norms and values

We are committed to adhering to internationally recognized norms and systematically exclude from the managed investment portfolios any companies that seriously violate human rights, the environment or labor norms, or are involved in corruption. To this end, we apply the MSCI ESG controversies methodology and standards. MSCI ESG Controversies is intended to reflect all areas of adverse impact covered by the Organisation for Economic Co-operation and Development’s (OECD) Guidelines for Multinational Enterprises on Responsible Business Conduct. In addition, MSCI ESG Research provides a mapping of ESG controversy cases to the underlying principles of the following global norms: the UN Global Compact (UNGC), the UN General Principles of Business and Human Rights (UNGP) and the International Labor Organization (ILO) Conventions (both core and broad).

MSCI ESG Research has a dedicated team of analytical staff who identify and assess the severity of controversy cases that involve companies in its coverage universe on an ongoing basis. ESG analytical staff review the reported allegations and apply consistent scoring and a color-coded flag for each controversy case, based on the severity of impact in each case, the alleged role of the company in each case and the status of each case (which is determined by the state of resolutions, if any, between involved stakeholders). MSCI ESG Controversies – evaluation framework:

In contrast to exclusions based on violations of global principles and standards, value-based exclusions are based on social, ethical or moral values. Thresholds have been defined for the percentage of overall revenues that can be generated from business areas with high ESG risk scores such as conventional weapons, thermal coal and tobacco production. Companies that exceed the generally accepted annual revenue thresholds in the business areas below are excluded:

Controversial business areas and the sales limits defined therein are unchanged compared to the previous year.

Compliance with these sales limits is systematically monitored, even though our core investments are in healthcare facilities. The specified revenue thresholds serve primarily for the practical implementation of the exclusion criteria and are based on empirical values in collaboration with institutional investors and industry experts. More far-reaching and/or stringent exclusion criteria may be applied for individual strategies with a dedicated sustainability focus.

Bellevue maintains an exclusion list, which is monitored and updated on a quarterly basis. Based on this list, just short 900 companies from across our investment universe were excluded from direct investment as at the end of 2024. Compliance with exclusion criteria is monitored monthly by an internal risk management unit.

ESG integration

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. This approach gives our portfolio managers a holistic picture of an enterprise.

The environment subcategory focuses on aspects such as whether a company systematically measures and discloses its emissions or carbon intensity or such as monitoring the CO₂ intensities of companies in the context of the average value for the relevant industry. The Social subcategory covers aspects such as product quality, data privacy policies, employee development and gender balance/diversity at management level. Examples of Governance issues are board independence, board compensation and corporate ethics.

To integrate sustainability criteria into the investment decision-making process, we use an ESG rating per issuer consisting of various sub-scores. These are based on data from MSCI ESG Research and Morningstar Sustainalytics, the relevance of which varies depending on the sector. The analysis focuses on the ESG key issues, i.e. the sustainability aspects in which a company performs particularly well or poorly.

However, ESG ratings should always be interpreted with caution and scrutinised critically. ESG rating methods are based on a predefined systematic approach that does not always result in an objective or «fair» assessment of risks. In fact, such methods often systematically disadvantage start-ups and small-cap companies relative to large-cap companies. A lack of manpower and experience in handling ESG issues can result in a company being underrated. Also, the given comparison group used to determine ESG ratings within a certain industry may not be entirely applicable. That is why our portfolio managers always take a closer look at potential or ostensible «ESG laggards» (CCC, B rating) and reach out to the ESG specialists at our external ESG research providers and at the companies with lagging ESG ratings. Investments in «ESG laggards» must be documented in detail. Bellevue Asset Management does not apply a «best-in-class» approach for the reasons mentioned above, unless otherwise dictated by a specific investment strategy.

A breakdown of Bellevue’s liquid investment strategies (net invested assets of Bellevue’s equity and fixed income strategies excluding cash, Private Equity, Ventures, company pension fund and dedicated derivative strategies) by MSCI ESG rating is given below:

Breakdown of MSCI ESG ratings as of December 31, 2024

Compared to the previous year, ESG leaders (MSCI ESG ratings of AA and AAA) once again increased from 21.5% to 31.4% of net invested assets. Similarly, ESG laggards (CCC and B) were reduced from 3.6% to 0.9%. In the middle of the good MSCI ESG ratings, individual portfolio reallocations resulted in a shift in strength from BBB to BB, although this is not particularly significant from a sustainability perspective. 3.2% of net invested assets could not be rated (2.9% in the previous year). The MSCI ESG rating distribution shown above covers around 97% of Bellevue’s total assets under management (previous year: 94%).

Following the introduction of the EU Sustainable Finance Disclosure Regulation in March 2021 and the Delegated Regulation (EU) 2017/565 on MiFID II sustainability preferences (art. 2, para. 7–9), Bellevue established the two investment categories of «investments with sustainable characteristics» and «sustainable investments». In the absence of a uniform European-wide classification system, the two categories are applied in the investment processes of the respective strategies to the best of our knowledge based on current practices and the, in some cases limited, data available, in accordance with clearly defined principles.

Investments with sustainable characteristics (EU SFDR)

Most of Bellevue’s investment strategies take into account social, environmental as well as governance-related characteristics (ESG), in accordance with the provisions of Article 8 of the EU Disclosure Regulation 2019/2088 (EU SFDR), but do not have sustainability as their objective. In principle, the aim is to invest all of the assets of the relevant strategies in investments with sustainable characteristics. However, as there is not yet a sufficient amount of ESG data available in every asset class and sector and, given that some companies do not yet have an ESG rating, a minimum allocation threshold to investments with sustainable characteristics has been set as a percentage of total invested fund assets.

For strategies with a considerable allocation to small and mid-cap investments and/or significant emerging market exposure where ESG research coverage is low, the minimum allocation threshold to «investments with sustainable characteristics» is 50%. Strategies that are less affected by these factors must adhere to a higher minimum allocation of 75% to «investments with sustainable characteristics». Taking into account the new ESMA guidelines on the use of sustainability terms in fund names, this minimum proportion was raised from 75% to 80% for the Bellevue Sustainable Healthcare Fund.

Detailed information on the individual investment strategies as well as the methodology can be found in the product-specific documents available via the following link:

https://www.bellevue.ch/all-en/all/about-us/sustainability/responsible-investment

Sustainable investments (MiFID II and EU SFDR)

In addition to taking into account the most important adverse effects on sustainability factors (PAIs) at portfolio level, Bellevue has defined minimum allocations to sustainable investments for every investment strategy pursuant to Article 2 (17) of the Disclosure Regulation 2019/2088. This defines a «sustainable investment» as an investment in an economic activity that contributes to the achievement of an environmental and/or social objective and does not significant harm with respect to such objectives. Furthermore, the investee companies must follow good governance practices.

Investments are included under the «sustainable investment» allocation if, firstly, they have a positive alignment with at least on of the 17 UN Sustainable Development Goals and, secondly, if they meet the aforementioned sustainability characteristics and, thirdly, if they have no significant adverse impact on sustainability factors. The MSCI ESG methodology is also used to measure contributions towards the UN SDGs (see section on «Alignment with UN SDGs»). Minimum thresholds of 25% and 50% were defined for the sustainable investment category. Here as well, the existing ESG-related research coverage and the specific investment focus (e.g. small and mid caps) play an important role.

Based on the above definitions and the methodologies applied, approximately 92% (94% in the previous year) of the liquid net invested assets at Bellevue as of December 31, 2024, qualified as «investments with sustainable characteristics» and 74% (62% in the previous year) as «sustainable investments»:

Investment products with sustainable characteristics (based on EU SFDR)

Sustainable investment (based on EU SFDR)

A sector-wide comparison of these ratios within the meaning of the EU SFDR is still not possible due to a lack of harmonization of the applicable classification schemes and valuation methods.

Principal adverse impacts on sustainability factors (PAI)

Bellevue takes into account the principal adverse impact (PAI) of its investment decisions on sustainability factors in its investment processes and portfolio management activities. PAI indicators can be considered both explicitly and implicitly. In explicit consideration, thresholds are determined for each PAI criterion, defining when a specific PAI criterion has a «principal adverse impact» on a sustainability factor ( «supercritical»). If an issuer is assessed as having a «principal adverse impact», it cannot be categorized as a sustainable investment, no matter if the issuer makes a positive contribution to one of the UN’s 17 Sustainable Development Goals.

In implicit consideration, aspects of the relevant PAI indicators are incorporated into the ESG ratings methodology developed by MSCI ESG, resulting in indirect consideration of PAI performance by defining minimum rating scores that are used to calculate the share of sustainable investments or of investments with sustainable characteristics for each investment fund.

Within the framework of a PAI analysis, sustainability factors such as carbon intensity, programs to reduce carbon emissions, water- and waste-related controversies, or gender mix at board level, for example, are explicitly taken into account.

The consideration of adverse impacts on sustainability is subject to data availability. The required data is not always available in sufficient quantity and quality for every entity in which Bellevue invests. As a result, the list of PAI indicators taken into account is continuously reviewed based on data availability and data quality.

As at 31 December 2024, 8.3% of net invested assets had a supercritical PAI value (19.2% in the previous year), with 2.8% (7.7% in the previous year) attributable to originally sustainable investments, which were therefore downgraded to ‘unsustainable’ by this proportion. The investments with supercritical PAI values are distributed across the following categories:

Proportion of ‘supercritical’ PAI values by category

ESG stewardship

As a responsible long-term investor, Bellevue supports all measures and proposals designed to increase the value of portfolio companies over the long term in the interests of shareholders and investors. This includes engagement activities as well as the exercising of voting rights at general meetings of shareholders.

Engagement

This commitment to active investment management also highlights the importance of engagement as a key element of our ESG framework. Portfolio managers are engaged in an active and constructive dialog with the executives and other relevant representatives of portfolio companies on environmental, social and governance issues. If there are any indications of a significant controversy related to ESG issues, they are constructively discussed with the investee company and subsequent developments (e.g. change in strategy or processes, improvement of ESG rating) documented over time. Engagement activities are undertaken in the context of materiality and proportionality considerations. The level of engagement can vary depending (among other things) on the size of the position held by an investment strategy, the market capitalization of the investee company, and the entity’s stage of corporate development.

ESG engagement activities are recorded as part of the regular documentation for company meetings and have been systematically recorded in a proprietary tool since 2022.

In 2024, our portfolio managers worked on a total of 22 engagements, with 7 engagements being finalised. In 3 cases, a full success was recorded and in 4 cases our engagement activities were at least partially successful. A further 4 exposures were terminated as the position was sold for fundamental reasons.

Breakdown of ESG engagements by country in 2024

Breakdown of ESG engagements by dimension in 2024

Breakdown of ESG engagements by company size 2024

Selected ESG engagement case studies show that our portfolio managers and analysts are in very close contact with companies and through constructive dialog they endeavor to bring about the best possible corporate performance in terms of sustainability criteria too. Qualified opinions of third parties such as proxies are included in the process, although ultimately we always act in the interests of our investors.

Engagement Case (Example) – Ypsomed (Switzerland)

In 2024, we conducted a very constructive and goal-oriented engagement with Ypsomed. The Swiss company offers, among other things, a comprehensive range of technologies and services for injection systems used in self-medication. For example, the highly demanded GLP-1 medications can be administered using Ypsomed pens. Our engagement activities focused on the following two key areas:

1) Is the company engaged in a satisfactory exchange with MSCI ESG analysts, and does it consider the ESG rating of A, which was in place at the beginning of the engagement, to be appropriate?

2) Has Ypsomed already taken steps to further optimize the area of «Product Safety & Quality»?

In addition to our interactions with Ypsomed representatives, we maintained a direct dialog with MSCI ESG analysts and acted as an intermediary between the two parties in our role as an asset manager. Thanks to the intensified exchange, it was ensured that Ypsomed’s high standards for product safety and quality, as well as the existing quality mechanisms (e.g., in supplier management), were fully reflected in publicly available reports and duly recognized by MSCI ESG.

As a result of the engagement, a rating upgrade was successfully achieved. Since May 2024, Ypsomed has held an AA rating, which corresponds to the second-highest rating category at MSCI ESG.

Proxy voting

Bellevue also protects the long-term interests of its investors by making active use of its voting rights at the general shareholder meetings of investee companies through proxy voting.

International Shareholder Services (ISS) provides us with proxy advisory services. ISS has many years of experience in proxy advisory and sets the bar with its voting policies. However, there is no obligation to vote in the same way as ISS recommends. Bellevue may vote against the recommendations of third-party organizations if it deems that their voting recommendations are not in the best interests of investors. Bellevue Asset Management AG actively exercises its voting rights as a rule.

Voting rights can be exercised in person by attending a general meeting; electronically via online voting platforms or through an appointed representative or representatives/proxy voting firms.

Overview of voting activities in 2024

In 2024, our portfolio managers and analysts participated in 409 general meetings (2023: 572) and cast votes on 781 (909) of a total of 804 (934) possible proposals, which represents a participation rate of 97.1% (97.3%). This figure can be below 100% because some markets require an equity blocking period in connection with voting, which would in turn restrict trading in the securities concerned. In order to maintain portfolio liquidity, however, no voting takes place in such cases.

Detailed information on our voting activity is given in the following tables:

Meeting overview

Ballot overview

Proposal overview

Climate-change factors – CO₂ emissions at portfolio level

As at 31 December 2024, for the second time in succession the environmental and climate-related portfolio evaluations refer exclusively to our investment strategies for listed securities (approx. 98% of total assets under management); private equity investments (approx. 1%) and derivatives-based strategies (approx. 1%) cannot be systematically assessed at the present time due to the lack of data and/or of viable methodological approaches.

In order to categorize financed carbon emissions, we have broken down invested assets by investment sector and investment region, as depicted below:

AuM by sector

AuM by country

As a highly specialized provider of healthcare investment solutions, approx. 92% of our investments are in the healthcare sector, 4% are in the manufacturing, consumer, tech, communications, and financial sectors, and only 2% are in the energy, commodities, utilities and real estate sectors. Around 70% of the invested positions are domiciled in the US, European positions account for 23% of total investments and 7% is domiciled in Asia and emerging markets.

With respect to the TCFD, as of December 31, 2024, financed CO₂ emissions – i.e., the CO₂ emissions at the investment portfolio level – were systematically calculated for the second time. Using the PCAF method (Partnership for Carbon Accounting Financials, see box below for methodology), the respective Scope 1, Scope 2 and (largely estimated) Scope 3 emissions per portfolio position were recorded as of the reporting date using MSCI ESG data. The table below lists the calculated financed Scope 1, 2 and 3 emissions (absolute amount in million metric tons of CO₂e) at portfolio level as of December 31, 2024, as well as the respective data quality score (Data Quality Score according to PCAF)³:

¹⁾ Aggregate GHG emissions financed for Scope 1 and 2 (on the basis of EVIC). Based on reported emissions data when available. Otherwise estimated. Units: t CO₂e. Calculated using MSCI ESG data inputs and methodology.
²⁾ Aggregate GHG emissions financed for Scope 3 (on the basis of EVIC). Based on reported emissions data when available. Otherwise estimated. Units: t CO₂e. Calculated using MSCI ESG data inputs and methodology.
³⁾ PCAF Data Quality Score: Standardized measure for determining the data quality of the financed emissions; score 1 = highest quality/certain (reported and verified emissions of issuer in line with the GHG protocol); score 5 = lowest quality/uncertain (calculated based on emissions factors for the sector per unit of revenue). Calculated using MSCI ESG data inputs and methodology.
⁴⁾The strategy also invests to a large extent in government bonds and derivatives, which cannot be covered by this methodology. This explains the comparatively lower data coverage ratios.

IMPORTANT NOTE: The given CO₂ emissions must only be understood as abstract absolute amounts that will rise or fall as portfolio assets (AUM) increase or decline. Changes in portfolio assets, for example through subscriptions or redemptions of fund shares by investors, will have a significant impact on reported CO₂ emissions. As such, this data is NOT suitable for comparative purposes, i.e., these figures cannot be used for historical or comparative contextual analysis, nor as KPI/target values.

In contrast, the CO₂ footprint, i.e. the ratio of financed emissions (GHG Scope 1 and 2 and GHG Scope 3) to total invested assets, is more meaningful:

Financed emissions – CO₂ footprint (in t CO₂/mn CHF invested)

In addition to the financed emissions, the asset-weighted sum of aggregate CO₂ intensity, i.e. total portfolio carbon emissions in metric tons per USD 1 mn turnover (WACI Scope 1, 2, 3), has been calculated for each strategy:

¹⁾ GHG emissions in tons of CO₂ per USD 1 mn turnover for Scope 1, 2 and 3 emissions. Based on reported emissions data, if available, otherwise estimated emissions; units: Calculated using MSCI ESG data inputs and methodology.
²⁾ Estimated EU Taxonomy Alignment: Estimated maximum percent of weighted-average investee turnover that makes a substantial contribution to one or more of the EU Taxonomy’s climate or environmental objectives without having a significant adverse impact on the other objectives and that is also in compliance with minimum human and labor rights. Calculated using MSCI ESG data inputs and methodology.

The Starcapital Dynamic Bond and the Bellevue Global Income Fund are Bellevue’s most carbon-intensive investment funds. Both invest in energy and mining companies, two industries with the highest amounts of CO₂ emissions. Healthcare funds, in contrast, have lower if not the lowest CO₂ intensities. Examples here are the Bellevue Biotech (CH), Bellevue Sustainable Healthcare and Bellevue Healthcare Strategy funds as well as BB Biotech AG. The Bellevue Emerging Markets Healthcare Fund also has a very low carbon of 292 t CO₂/USD 1 mn turnover, which reflects the high weighting of healthcare services providers on the one hand and the in some case still moderate estimates of Scope 3 emissions on the other. The diversified healthcare strategies are therefore all within the range of the MSCI World Healthcare Index, which had a CO₂ intensity of 360.6 t CO₂/USD 1 mn turnover as of December 31, 2024.

By comparison, the Entrepreneur funds, the Bellevue Global Macro Fund and the StarCapital funds invest in a wide range of industries, including the energy and manufacturing industries, and therefore have higher average intensities than the healthcare strategies.

With 524.6 t CO₂/USD 1 mn turnover for all measurable Bellevue investment strategies (approx. 97% of Bellevue’s total AUM), the CO₂ intensity or WACI Scope 1, 2, 3, is approximately 30% below the calculated carbon intensity of the index-weighted constituents of the MSCI AC World Index (733.7 t CO₂/USD 1 mn turnover) and slightly below the previous year’s level (528.3 tonnes of CO₂/million USD sales).

With reference to the alignment of Bellevue’s investment strategies with the EU Taxonomy’s climate and environmental objectives, the Bellevue Entrepreneur Europe Small Fund with 12.2%, the StarCapital Dynamic Bond Fund (6.6%) and the StarCapital Multi Income Fund (just under 5.4%) also make moderate contributions to the environmental objectives of the EU Commission. Based on the total assets under management of Bellevue, the share of weighted-average turnover that meets at least one of the EU Taxonomy environmental and climate objectives is around 0.6%. This is mainly due to the fact that 92% of our investments are in the healthcare sector, which, by its very nature, cannot make a substantial contribution to any of the 6 environmental objectives of the EU Taxonomy (the weighted-average turnover within our EU Taxonomy-aligned healthcare investments is 0.04%; of the almost 300 healthcare investees, a mere 8 meet the applicable Taxonomy requirements to substantially contribute to at least one of the EU Taxonomy’s environmental objectives and their level of alignment is very low).

We therefore again emphasize that our investment strategies seek to provide long-term capital growth by investing in companies with positive sustainable characteristics. None of our investment strategies has specified a minimum proportion of portfolio investment in environmentally sustainable economic activities as defined in Article 3 of the EU Taxonomy Regulation (2020/852). The EU Taxonomy-aligned turnover data above is for informational purposes only.

PCAF methodology (Partnership for Carbon Accounting Financials):

The financed emissions of a loan or an investment in a company are determined by multiplying the attribution factor by the emissions of the borrower or investee. Total funded emissions of a portfolio of listed equities and corporate bonds are calculated as follows:

The attribution factor represents the proportional share of a given company, i.e., the outstanding amount divided by EVIC for listed equity or the outstanding amount divided by total equity and debt for traded bonds to private companies:

The financed emissions from listed equity and corporate bonds can be calculated in different ways depending on the availability of financial and emissions data specific to the borrower and investee: Overall, PCAF distinguishes three different options to calculate the financed emissions from listed equity and corporate bonds depending on the emissions data used: Option 1: Reported emissions (verified/unverified); Option 2: emissions are estimated based on data collected from the borrower or investee company; Option 3: emissions are estimated based on sector-specific average emissions per economic activity.

The definitions of the PCAF data quality scores for listed equities and corporate bonds are as follows:

Climate-related goals and measures at the investment portfolio level

1) Bellevue Asset Management invests approximately 92% of its assets primarily in healthcare companies, thereby making a significant contribution to achieving social goals. The healthcare sector generally has significantly lower CO₂ emissions compared to other investment sectors. Nevertheless, we acknowledge our responsibility as an asset manager and contribute to global climate goals through the following measures: Limiting the absolute investment quota for issuers whose CO₂ intensity exceeds a critical PAI value (CO₂ intensity of more than 70 t CO₂ per million USD revenue AND higher than 50% of the relevant industry average) to a maximum of 50% of the assets of the respective investment strategy (for emerging markets and small-cap strategies, this limit is set at 75%).

2) Measuring the share of issuers that already have validated Science-Based Targets Initiative (SBTi) goals or have signed an intent to do so. The first measurement was conducted at the end of 2024 to establish a target range for future development. As of December 31, 2024, 12.5% of the managed assets had committed to an SBTi goal, while 20.6% of portfolio companies had already their SBTi targets, approved.

3) Conducting climate-related corporate engagements.

As mentioned under the ESG Integration/PAI Consideration section, CO₂ emissions are factored into sustainability assessments. This occurs in two ways: Implicitly, via the MSCI ESG rating, which is relevant for determining investment quotas with sustainable characteristics. Explicitly, by assessing the CO₂ intensity of each issuer. If an issuer’s CO₂ intensity exceeds 70 t CO₂ per million USD revenue (i.e., higher than the «low» value according to MSCI ESG methodology) and if this value is also 50% higher than the relevant industry average, then the issuer cannot be classified as a «sustainable investment», regardless of its contribution to any of the 17 UN SDGs.

Based on this methodology, a total of 22 issuers (equivalent to 1.1% of managed assets) were classified as not sustainable due to their CO₂ intensity as of the end of 2024. Additionally, according to MSCI ESG Research, 6 issuers (representing 0.2% of managed assets) had no initiatives in place to reduce carbon emissions.

Greenhouse gas emissions and the CO₂ footprint are also integral components of a company’s MSCI ESG rating and are therefore implicitly factored into the assessment and weighting of sustainable investments.

Regarding investments in the carbon sector (oil, gas, coal), the investment share, measured against managed assets, stood at 0.31% at year-end (previous year: 0.19%).

KPIs of responsible investments