Santiago Principles Self-Assessment

Ireland Strategic Investment Fund

Fund Details Fund Website Search Assessments PDF version
  • Pillar 1: Legal
  • Pillar 2: Institutional
  • Pillar 3: Investment
Principle 1

1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).

1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.

1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.

The National Treasury Management Agency (NTMA or the Agency) is a State body that provides a range of asset and liability management services to the Irish Government. The Ireland Strategic Investment Fund (ISIF or the Fund) was established pursuant to an act of parliament specifically the National Treasury Management (Amendment) Act 2014 (2014 Act) which was commenced on 22 December 2014.

As set out in section 38(3) of the 2014 Act – the Minister for Finance is the owner of the Fund. Section 31(1) of the 2014 Act provides that the NTMA is the controller and manager of the ISIF. Section 40 of the 2014 Act provides that the Agency shall determine an investment strategy for the assets of the Fund and shall consult the Minister for Finance and the Minister for Public Expenditure and Reform and have regard to any views expressed by them with regard to the investment strategy. Section 41(5) of the 2014 Act provides that the NTMA Investment Committee shall oversee the implementation of that strategy. 

Further details on the NTMA governance structure are available at:

Principle 6

6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.

As noted in the responses to GAPP 1, the NTMA is a State body which provides a range of asset and liability management services to the Irish Government. The NTMA was manager of the NPRF and is now the manager and controller of the Ireland Strategic Investment Fund. As discussed further in GAPP      1, ISIF was established on a statutory basis under the NTMA (Amendment) Act 2014 (2014 Act). The 2014 Act defined the governance structures by which ISIF operates to this day under the NTMA’s remit. Since its establishment in 1990, the NTMA has evolved from a single function agency managing the national debt to a manager of a complex portfolio of public assets and liabilities.

Overarching responsibility for all of the NTMA’s functions, including managing ISIF, rests with the Agency, which comprises a Chairperson and eight other members. Six of the Agency members, including the Chairperson, are appointed by the Minister for Finance and the three other members (the Chief Executive of the NTMA and the Secretaries General of the Departments of Finance and Public Expenditure and Reform) are ex officio members of the Agency. The Agency is responsible for setting the ISIF strategy.

The Agency has established four committees to assist in discharging responsibilities, each committee with its own formal terms of reference: (i) Investment Committee; (ii) Audit and Risk Committee; (iii) Remuneration Committee; and (iv) the State Claims Agency Strategy Committee. The remit of the Investment Committee relates only to the management of ISIF. The State Claims Agency Strategy Committee is specific to the State Claims Agency. The remit of each of the Audit and Risk Committee and Remuneration Committee cover the NTMA as a whole.

The Agency’s Investment Committee makes decisions about the acquisition and disposal of assets of the Fund in accordance with the investment strategy and within any such parameters as may be set by the Agency. The Investment Committee also advises the Agency on the investment strategy and oversees the implementation of the investment strategy.

The Investment Committee has five members, appointed by  the NTMA. Two members are selected from Agency members other than the ex officio Agency members (i.e. the Chief Executive and the Secretary Generals of the Departments of Finance and Public Expenditure and Reform). The other three members of the Investment Committee are not Agency members or NTMA staff and are appointed based on their substantial business and finance expertise; they are appointed by the Agency subject to the consent of the Minister for Finance. Investment Committee members are appointed for a period of up to three years, extendable by two additional three-year periods. NTMA appoints the Chairperson of the Investment Committee, choosing from one of the two Agency members on the Committee.

The ISIF Business Unit is the team within the NTMA charged with the day-to-day management of the ISIF.

More information on the governance of NTMA and established four committees is available at: 

Principle 18

18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.

18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.

18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.

18.3. A description of the investment policy of the SWF should be publicly disclosed.

Investment Strategy - Global Portfolio

The primary objective of the Global Portfolio Strategy (GPS 2.0) design is to provide cash or liquidity to (i) the Irish Portfolio to fund proposed investments and (ii) a number of initiatives as communicated, or directed by, the Minister for Finance with a secondary objective to grow that capital over time. The GPS 2.0 is a relatively low risk multi-asset class and multi-strategy investment approach      managed by external global asset managers. The GPS 2.0 was approved by the Agency, with its implementation delegated to management. 

Investment Strategy – Irish Portfolio

Consistent with its mandate, ISIF pursues commercial, risk-adjusted expected returns, varying according to the layer of the capital structure invested and the risk of the underlying investment. 

ISIF is designed to be a long-term fund, is not subject to liquidity requirements, and aims to be a source of permanent or patient capital. The Minister for Finance may, after consultation with the NTMA, direct payments (essentially dividend-     like payments) from ISIF to the Exchequer of up to 4% per annum of the ISIF’s value. No direction to make such a payment can be made before 2025. This right is separate from and in addition to the right of the Minister for Finance to direct that the ISIF be invested in certain investments in specified circumstances, according to Sections 42 and 42A of the 2014 Act. 

In the Irish Portfolio, ISIF generally takes minority equity stakes and invests on equal terms with private investors to: (i) generate a multiplier effect; and (ii) ensure compliance with the Market Economy Investor Principle for the purposes of EU State aid rules. 

When ISIF is a cornerstone investor, it may seek preferential terms relative to non-cornerstone investors. In addition, while it may be the sole or largest debt provider to a company, ISIF generally seeks to represent less than 50% of the overall capital structure of its investee companies (counting debt and equity). The State aid aspect is critical. As a Government agency, ISIF must ensure that its investments do not breach EU rules preventing unfair financial support for private sector enterprises. Every ISIF investment is subject to a strict vetting and cost-based analysis process in this respect.

In the Irish Portfolio, ISIF invests both directly and indirectly through third-party managers, with a target ticket size for direct investments of generally above €10 million.

When it invests directly, ISIF has the flexibility to invest across the capital structure – from secured debt (rated or unrated) to venture equity.

Irish Portfolio Investment Process - External Milestones

External Milestone A: “Confirmation of Interest”

At the appropriate time during the Initial/Active Engagement stage, a Summary Investment Paper (SIP) is to be prepared and presented to an “Assessment of Interest Meeting”. The SIP is to be recommended by the Proposer and supported by the Proposing PMC Member.

External Milestone B: PMC Support

Following a more detailed assessment of the opportunity and receipt and review of the business plan, financial accounts/projections, economic impact, risk/return etc., a Preliminary Investment Proposal should be prepared and presented to the ISIF PMC for review and decision.

External Milestone C: Clearing Committee

All proposed transactions and sector strategies are presented to, and considered by, an internal management Clearing Committee, prior to the presentation to the Investment Committee for approval. This adds a further level of governance by assessing the opportunity across various areas of the NTMA, including representatives from legal and risk, in addition to the Chief Executive.

External Milestone D: Investment Committee Approval

Following completion of all material due diligence, a detailed “Investment Committee Paper” is presented to the Agency Investment Committee.

External Milestone E: Deal Execution / Contract Signing

A series of internal and external requirements must be followed and completed prior to deal execution / contract signing, including a detailed legal review by internal and/or external legal teams and a range of due diligence reviews and sign offs.

Risk Policies

ISIF has adopted a Portfolio Diversification Framework for the Irish Portfolio that sets investment limits based on maximum exposures by sector and by risk category. Compliance with the double-bottom line mandate is the overarching principle of ISIF’s strategy. Sectors include food & agriculture, energy, financials, healthcare, transport, tourism, industrial, IT, real estate and consumer discretion. Risk is scored on a scale of 1 to 5 based on the type of instrument and layer of the capital structure.

Furthermore, maturity, competitiveness, leverage and downside protection (e.g. through contractual clauses or seniority in the capital structure) of the respective investments are also considered. Investment limits are based on the market value of the investments. In addition, ISIF’s total exposure measured as market value plus undrawn commitments is monitored as it provides an indication of the portfolio’s future evolution. 

Limits are normally reset on an annual basis. As noted above, ISIF’s current investment strategy focuses on four main impact themes (Climate, Housing and Enabling Infrastructure, Indigenous Businesses and Food and Agriculture). Where possible, ISIF will target regional development across all of these impact themes. ISIF also has the flexibility to invest outside these themes if necessary, using a pool of capital under a National and Compelling theme which will be dedicated to unforeseen macroeconomic events such as the shock triggered by the Covid pandemic.

ISIF can diversify its portfolio outside of Ireland, in particular by investing in global funds that will deploy part of their capital to Ireland. Investments in global funds that invest in Ireland can enable ISIF to reduce its Irish exposure and gain a more globally diverse exposure, while still generating an economic impact in Ireland.

ISIF also performs an “all-weather” analysis to test how the Irish Portfolio performs under various scenarios of GDP growth and inflation. This is done by examining how the discounted cashflows of individual investments are impacted by growth and inflation and subsequently aggregating figures at portfolio level. 

At transactional level the ISIF applies a disciplined approach to designing capital structures and investment analysis. 

ISIF’s risk team is responsible for producing a risk assessment, for each investment and the Irish Portfolio as a whole. The investment proposal is passed to the NTMA Risk function, which analyses the risks and passes its feedback to the Investment Committee (and, for deals exceeding €150 million, to the Agency) prior to investment approval.

The latest ISIF Investment Strategy (16 June 2022) is published on the ISIF’s website:


ISIF is increasingly focused on monitoring investments in the Irish Portfolio as the Fund moves into a more mature phase. Currently ISIF monitors investments on an ongoing basis (for instance through quarterly calls and meetings) and this is formalized in quarterly reports to the Investment Committee and the Annual Control Report that is presented to the PMC. ISIF appointed a Head of Monitoring responsible for monitoring all Irish investments in 2019 and this team has continued to expand as the Irish Portfolio grows.  More recently, ISIF has centralised the portfolio management of the Discretionary Portfolio into a new Portfolio Management Division, which the Irish Portfolio Monitoring team is part of.  This division will measure, monitor and manage the portfolio bottom up and top down through various five lenses (Risk, Performance, Asset Allocation, ESG and Economic Impact).