CODOFINE - Position on the USCCB Guidelines and other Local Guidelines (2015-03)

Following the Assessment 2015-01 of the EXCELSIS Rating Committee as to the SP 500 Catholic Values Index, the Council of Doctrinal Financial Ethics (the "Codofine") was requested by the OFCCFO's president to clarify its position with regard to the text entitled "Socially Responsible Investment Guidelines" as issued by "the United States Conference of Catholic Bishops" in November 2003 (the "USCCB Guidelines"), and more broadly, any other texts relating to ethical finance disclosed by a national recognized Christian authority (the "Local Guidelines").

The Codofine points out that the Fundamental Charter of Christian Ethical Finance (the "Charta") does not refer explicitly to Local Guidelines in its preamble as the drafting committee could not list exhaustively all the sources which are potentially applicable to the Christian Ethical Financial Activities and Actors.

The Codofine is of the opinion that the Local Guidelines and the Charta complement each other. The Charta considers "that it is essential that financial activities of any kind, are regulated, from now on, by a common Christian ethical frame" in order to foster the emergence of a consolidated Christian financial sector.

As a consequence, the Codofine opines the followings:

1- The Charta has a broader scope than the Local Guidelines: for instance, the USCCB Guidelines are specifically Catholic and are designed for the United States of America, so that certain provisions of the USCCB Guidelines may derogate from the Charta to "take account of the local cultural specificities" according to Article 4 of the Charta ;

2- The Charta is presumed to include implicitly every Local Guidelines, including the USCCB Guidelines although these are not explicitly referred to in the preamble of the Charta ;

3- The Charta provides for a common international Christian ethical frame, by listing practical objectives and conducts, on a transactional or organizational level, and summarizing fundamental principles deemed to complement and harmonize the Local Guidelines ;

4- The stakeholders, activities, products, behaviors, concepts and organizations in the banking, financial or insurance sectors, which comply with Local Guidelines shall be presumed to be compliant with the Fundamental Principles of the Charta provided that no obvious inconsistency arises.

The Codofine