Chap 9 Flashcards

1
Q

CHAPTER 9
INVESTMENT MANDATES, PORTFOLIO ANALYTICS AND CLIENT REPORTING

The veteran founder of Vanguard, John Bogle, called our society a “double-agency” one – namely, a society in which corporate agents (as a practical matter, corporate CEOs) “who are duty-bound to represent their shareholders face money manager/agents who are themselves duty-bound to represent their mutual fund shareholders and their other clients, often pension funds.”

According to Bogle, there is a similarity between the agency problem that corporate governance is designed to address and the agency problems that occur within the investment chain. As with corporate governance, these investment chain agency problems can be addressed (though not completely solved)…

A

…by careful alignment and accountability:

▶ alignment should be designed so that the timeframes and structures of portfolio manager assessment and remuneration closely reflect the performance experienced by the clients and the timeframes over which they need performance to be delivered; and

▶ accountability should mean that portfolio managers respond to the clearly expressed intentions of the clients and report as fully as required.
Client mandates can deliver these two elements, if they are designed well.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
2
Q

A. Clarifying client needs and objectives

The first step in the effective design of a mandate is that the client should be clear about their needs and should be able to describe these in the requests for proposal (RFP) that they issue for a mandate. Doing so will require them to define their investment goals and beliefs.

A

Institutional clients will typically be keenly aware of the goals that they are trying to achieve (their risk-adjusted return target over the appropriate time horizon), but may find it harder to define their investment beliefs.

Nevertheless, it is these beliefs that will help them to define how they believe they will create value and to set their investment approach. The investment beliefs – that might be expressed in a

Statement of Investment Principles

– ought to guide the overall approach towards ESG and will help to frame any mandate agreed with an investment manager.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
3
Q

B. Aligning investment with clients’ beliefs

As suggested by a PRI report, asset owners should ensure that mandates align investment across asset classes with their beliefs and strategies:
“Attention should be paid to aligning timeframes through fees and pay structures, ensuring that ESG issues are fully integrated into investment decision-making, and ensuring that the investment manager engages with companies and issuers, and votes shareholdings.

A

C. Proposing ESG-aware investment mandates

The ICGN Model Mandate Initiative: Model contract terms between asset owners and managers provides a helpful framework and proposes best practices for ESG-aware investment mandates around:

▶ the monitoring and use of ESG factors;

▶ the integration of ESG factors into investment decision-making;

▶ adherence to good practice around stewardship; and

▶ voting and reporting requirements.

As the document states:

“As important as setting standards within fund management contracts is how clients can effectively call their fund managers to account in respect of these mandates.

The intended standards will most effectively be delivered where managers are made accountable on a regular basis for their delivery against them.”

According to the 2016 PRI report, referred to above, investment mandates should require investment managers to:

▶ Implement the asset owner’s investment beliefs and relevant investment policies.

▶ Integrate ESG issues into their:
» investment research;
» analysis; and
» decision-making processes.

▶ Invest in a manner consistent with the asset owner’s **time horizons, understanding the key risks that must be managed to achieve the asset owner’s portfolio goals.

▶ Implement effective stewardship processes, including:

» engagement with companies and issuers on ESG issues; and
» for listed equities, voting all shareholdings.

This engagement should align with the asset owner’s responsible investment and related policies.

▶ Engage constructively and proactively with policymakers on responsible investment and ESG-related issues. This engagement should align with the asset owner’s responsible investment and related policies.

▶ Report on the actions taken and outcomes achieved. The reporting should enable the asset owner to:

» assess the manner in which the investment manager has implemented the asset owner’s investment beliefs
and policies; and

» understand how this has affected investment performance and ESG outcomes and impacts.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
4
Q

D. Linking sustainable investing to the mandate

On occasions, the specific ESG (or other) requirements of a client are not included in the contractual mandate itself, but in a side letter, which also has contractual status.

An insight into this model is provided by the

*****Brunel Asset Management Accord.

This document sets out a pension manager’s approach to long-term investment and ESG factors,

but in a form of words that it believes is less-suited to the hard legal language of a specific contract, but more to a softer form of agreement whereby the fund managers are enabled more clearly to understand the client’s perspective and so, align to it.

A

For the purposes of this chapter, we talk about mandates in a way that encompasses side letters or any other legal documents that frame the agreement between a client and a fund manager.

The issue of time-horizons of the asset owner, and the overall investment philosophy, incorporating the institution’s understanding of ESG factors and their impact on value over those time-horizons, goes to the core of delivering mandates that actually encourage fund managers to respond appropriately to ESG risks and opportunities.

As the ICGN’s Model Mandate puts it:

“The time horizon of most asset owners is considerably longer than that of fund managers. Thus for long-term portfolios, the factors and risks which matter to the asset owner are somewhat different from those typically considered within fund management processes. But as these factors and risks will impact their long-term returns, many asset owners are keen to see more effective integration of these longer-term factors into investment processes.”

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
5
Q

E. Defining the sustainable investment strategy

In order to incorporate the longer-term perspective discussed in sub-section D above and an ESG mindset into the mandates that the asset owners give fund managers, asset owners need themselves to have developed

a clear understanding of their views on ESG and investment more generally.

It has become common now for asset owners to set out their investment beliefs – namely, a philosophy of what the institution believes will drive returns and deliver value over the relevant time-horizon.

Most asset owners these days incorporate a perspective on ESG factors.

A

The Pensions and Lifetime Savings Association (PLSA) produces a **Stewardship Checklist for its members, which encourages just such a development of a broader philosophical approach.

In this checklist (useful not just to pension schemes but for all asset owners) there are three key bullet points.

PLSA Stewardship Checklist

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
6
Q

As the PLSA indicates, the investment philosophy is often shaped by the overall purpose of the organisation, set by its founding documents.

For many asset owners now, it is vital that ESG is integrated within that purpose.

Not least because, since October 2019 changes to the ***UK’s Occupational Pension Scheme Investment Regulations (2005) have required pension schemes to set out in their Statement of Investment Principles

(SIP) their policies on how they consider financially material ESG factors within their investment approach,
as well as the extent to which they undertake stewardship, including engagement and voting. New reporting requirements, in line with Europe’s Shareholder Rights Directive II, will reinforce this. The starting point for the investment process often starts with how ESG is viewed in the context of an investment philosophy or purpose.

A

Two reasonably representative examples of how such purposes are articulated by major global asset owners are shown below:

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
7
Q

As the PLSA indicates, the investment philosophy is often shaped by the overall purpose of the organisation, set by its founding documents.

For many asset owners now, it is vital that ESG is integrated within that purpose.

Not least because, since October 2019 changes to the *UK’s Occupational Pension Scheme Investment Regulations (2005)

have required pension schemes to set out in their Statement of Investment Principles

(SIP) their policies on how they consider financially material ESG factors within their investment approach,
as well as the extent to which they undertake stewardship, including engagement and voting.

New reporting requirements, in line with Europe’s Shareholder Rights Directive II, will reinforce this.

The starting point for the investment process often starts with how ESG is viewed in the context of an investment philosophy or purpose.

A

Two reasonably representative examples of how such purposes are articulated by major global asset owners are shown below:

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
8
Q

From CPP Investment Board (Canada):

A

“CPP Investments invests the assets of the CPP with a singular objective – to maximise returns without undue risk of loss taking into account the factors that may affect the funding of the CPP.

Our investment strategy is designed to capitalize on our comparative advantages while ensuring we maintain our commitment to responsible investing”.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
9
Q

From AustralianSuper:

A

“We work hard to maximise investment returns over the long term, so members can enjoy a better future. As long-term investors, we focus on investing in a mix of quality assets that can grow members’ savings over time.

We balance this with an understanding of the risks we need to take to achieve this objective and deliver competitive returns against our peers.

Our four core investment beliefs are the foundation of our investment approach.

A rigorous governance framework and disciplined investment process help us allocate and manage members’ savings and maintain our position as one of Australia’s leading super funds.

Our four investment beliefs:

  1. We return all profits to members.
  2. We believe in active management – both asset allocation and stock selection.
  3. We use our scale to reduce costs and better structure investments.
  4. We’re aware of our responsibility to the broader community, consistent with our obligations to maximise benefits to members.”
How well did you know this?
1
Not at all
2
3
4
5
Perfectly
10
Q

How the purpose and investment beliefs and philosophy see ESG impacting investment performance – whether as risk factors or value creators – will shape how ESG is integrated into mandates and what the asset owner
will expect of its fund managers.

A

This is well-articulated in a McKinsey article from October 2017.

The article provides a framework for considering how to develop a policy and philosophy, and then how it can practically be implemented.

It states that:’

“A sustainable investment strategy consists of building blocks familiar to institutional investors: a balance between risk and return and a thesis about which factors strongly influence corporate financial performance.”

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
11
Q

Responding to these two building blocks, McKinsey suggests that there are two fundamental questions that asset owners need to ask in developing their ESG investment philosophy:

A
  1. Are ESG factors more important for risk management or value creation?

“If the mandate focuses on risk management, then the strategy might be designed to exclude companies, sectors, or geographies that investors see as particularly risky with respect to ESG factors, or to engage in dialogue with corporate managers about how
to mitigate ESG risks. If value creation is the focus, on the other hand, investors might overweight their portfolios with companies or sectors that exhibit strong performance on ESG-related factors they believe are linked to value creation.”

  1. What ESG factors are material? McKinsey notes that this is much less straightforward than the simple statement of the issue might make it seem, and that there are substantial reporting projects dedicated to identifying what is material at a sector level, let alone an individual company level. The nature of the investment portfolio also adds a layer of complexity, the firm argues:

“The selection of material factors is often influenced to some extent by exposure to asset classes, geographies, and specific companies.

For example, ***governance factors tend to be especially important for private equity investments, since these investments are typically characterised by large ownership shares and limited regulatory oversight.”

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
12
Q

EMBEDDING ESG INVESTMENT

A

Explain how ESG screens can be embedded within investment mandates/portfolio guidelines to: generate investment returns; and manage portfolio risk.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
13
Q

Once the asset owner client has developed its investment philosophy and beliefs, this then needs to be translated into the specifics of the mandates that it awards to its fund managers.

As McKinsey indicates, there are two key elements of this:

A
  1. Is ESG a risk management tool or a source of investment advantage?
  2. Which aspects of ESG most matter from the perspective of the asset owner?

Determining the answers to these questions will be the starting points for shaping the mandates awarded.

Furthermore, in shaping the detailed expectations, the answers will need to be reflected in the terms of the individual mandates themselves.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
14
Q

Example

Pension fund concerned about climate change

A pension fund has strong beliefs regarding the impending impacts of climate change.

▶ The fund might establish multiple mandates investing in new technologies, including renewable energy generation.

▶ The fund’s mainstream equity and debt mandates may well include screens that exclude fossil fuel investments.

▶ The fund may require that any sovereign bond mandate includes an active ESG overlay that seeks to limit exposure in countries where the physical impacts of climate change are likely to be most acute.

A

Example

Foundation investment portfolio concerned about human rights abuses

A foundation investment portfolio, where the investment beliefs feature major concerns regarding human rights abuses, might be more likely to:

▶ apply a screening approach across portfolios requiring the exclusion of any investment facing significant allegations; and

▶ ***screen out exposures to certain countries where human rights abuses are perceived to be a frequent occurrence or where human rights standards are deteriorating at a rapid rate.

______

Naturally in practice, the investment beliefs and so the mandates that are created to reflect them, are rarely as one-dimensional as the two examples above might imply.

Furthermore, the client will always have an expectation of investment returns being generated alongside delivery of whatever broader expectations it places on the investment approach.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
15
Q

The McKinsey article also provides a helpful framework for understanding the different ways in which ESG considerations can be reflected in an asset owner’s investment approach and so, be fully operationalised in the work of its fund managers.

A

DIMENSION OF INVESTING
ELEMENTS OF SUSTAINABLE INVESTING

Investment mandate
• Consideration of ESG factors, including prioritisation.
• Targets

Investment beliefs and strategy
• Rationale for ESG integration.
• Material ESG factors.

Investment operations enablers:
✓ Tools and processes
• Negative screening.
• Positive screening.
• Pro-active engagement.

✓ Resources and organisation
• ESG expertise and capabilities.
• Integration with investment teams.
• Collaborations and partnerships.

✓ Performance management
• Review of external managers (screening and follow-up). • Follow-up on internal managers (including incentives).

✓ Public reporting
• Accountability.
• Transparency.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
16
Q

Fund managers themselves, hoping to win mandates that reflect ESG concerns, will seek to develop their
own policies that fully integrate ESG approaches into their portfolio management.

This is both an element of marketing their approach and differentiating themselves in a crowded investment marketplace.

An overarching policy also helps to train and shape the mindset of the investment teams themselves.

An ESG policy should formally outline the investment approach and degree of ESG integration within a firm

A

Such an ESG policy is an opportunity for a fund manager to highlight the relevance, or in some cases the lack of relevance, of responsible investment norms and principles (like those issued by the PRI) to a firm’s investment strategy or strategies.

A number of investment strategies face inherent challenges, some of which may be due to:

▶ the lack of ESG data within their scope; or
▶ a relative scarcity of methodologies and best practices to apply ESG integration within an asset class.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
17
Q

Here are two examples of ESG philosophies from leading fund management firms.

RBC Global Asset Management:

“We invest in sustainable great companies at attractive valuations and steward them for the long term.

We use intangible, ESG and business assessment combined with strong risk analysis to achieve this.

Financial analysis and ESG assessment are intertwined
in judging a business.

Businesses thrive over the long term when they invest in ESG intangible factors that lead to stronger more sustainable financials.

We consider ESG factors as non-traditional sources of risk and opportunity which we believe should form part of every company assessment…

The relevance of particular ESG issues varies from industry to industry, which is why we believe it is important to integrate ESG into the company assessment … rather than as a pre-screen or overlay.

It facilitates engagement and ensures ESG risks and opportunities are incorporated into the fundamental valuation analysis driving financials.”

A

Generation Investment Management:

“Our investment process underpins our differentiated thinking about the dynamics that drive and influence the performance of companies.

We construct portfolios of sustainable companies with the confidence derived from our deep research and analysis.

A sustainable company is:

(1) one whose current earnings do not borrow from its future earnings;
(2) one whose sustainability practices, products and services drive revenues, profitability and competitive positioning; and
(3) one that provides goods and services consistent with a low-carbon, prosperous, equitable, healthy and safe society.”

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
18
Q

These philosophical statements then need to be operationalised into ESG policies that cover a range of practical issues.

Regardless of the investment strategy or asset class, such an ESG policy needs to address the manner in which the portfolio manager:

A

▶ addresses ESG issues at portfolio reviews;

▶ establishes the rationale and methodology for ESG portfolio-level assessment;

▶ assesses exposure to ESG risk within the risk management function;

▶ determines ESG impacts to the portfolio;

▶ responds in the investment decision-making process to ESG implications; and

▶ discloses ESG exposure to the fund’s investors.

How well did you know this?
1
Not at all
2
3
4
5
Perfectly
19
Q

Portfolio managers should also find ways to embed ESG information within annual or interim reports alongside financial information and manager commentary to fund investors.

Annual reports may include:

A

▶ ESG activities across the portfolio;
▶ frequency of engagement; and
▶ highlighted activities and their outcomes.

Portfolios with private or unlisted securities exposure may choose to report portfolio performance against key performance indicators (KPIs) over a given investment period and relative to peers.

Reporting ESG information with consistency and continuity helps ensure compliance with the portfolio’s ESG policy, responsiveness to ESG-related portfolio issues and effective portfolio oversight.

20
Q

Different asset managers adopt different responsible investment strategies because their investment philosophy and investment processes may fundamentally differ.

For instance:

▶ some active investors focus on fundamental company-specific research, while others may emphasise quant models; and

▶ some will be more event-driven, while others are more focused on identifying companies with a long-term track record of delivering superior financial performance.

As a result, different managers will integrate ESG in different ways:

▶ as a threshold requirement before investment can be considered;

▶ as a factor that informs the valuation;

▶ as a risk assessment that offers a level of confidence in the valuation;

▶ as a basis for stewardship engagement; or

▶ as a combination of two or more of these methods, which is very often the case.

A

These variations in style should be readily apparent to asset owners (and the investment consultants that advise them).

Therefore, they should help determine which is the most appropriate provider of services to fulfil the client’s needs, consistent with their investment beliefs and philosophy.

The usual way that consultants and clients seek to understand and test fund managers’ capabilities and approaches is through an RFP process
(an invitation to pitch for potential business), usually followed up with interviews of short-listed candidates.

Naturally, the client wants to gain confidence that the fund manager can deliver satisfactory financial returns while staying within relevant risk parameters.

But, with regard to ESG considerations, the client wants to understand:

▶ whether the approach to integration is sufficiently robust to deliver an appropriate portfolio structure;

▶ that the fund manager is capable of delivering with certainty any hard constraints on the portfolio (such as
negative screens);

▶ that the manager can deliver appropriately effective engagement to preserve and enhance value; and

▶ that the manager actually delivers in practice what it sets out as its approach in these respects in its policy documents and other assertions.

Unless the fund manager can deliver all these necessary requirements (with the last being perhaps the most important), it is unlikely to make it through the due diligence process.

21
Q

The RFP process

The RFP process is a formalised one, and a little formulaic in most cases.

The questions asked are generally high level, and although they sometimes ask for examples of delivery to ensure that the fund manager can demonstrate the truth behind its assertions, the resulting information will rarely reveal much of the substance of what is going on.

The larger fund managers have RFP teams who deal with the flow of questions and hold a bank of answers, which builds and extends over time with input from practitioners, but this may occasionally come at the detriment of tailoring of responses .

The result is that clients will only be able to ask the second- and third-level questions that actually get closer to the truth of the underlying processes in the face-to-face interviews of the short-listed candidates, which are typically the second part of a manager due diligence process. The RFP questioning process does at least have the benefit of narrowing the field to a shortlist of potential providers.

A

Investment integration

Asset owners have their own investment philosophies and preferred investment styles, so as clients, they will seek to test whether the responsible investment strategy adopted by the fund manager is coherent with their broader investment strategy and aligned with their preferences:

▶ some clients might be more interested in investing with a quant-fund manager running a smart beta product; while

▶ others might prefer a fundamental stock-picking fund manager with a concentrated portfolio of companies. The important thing is that both strategies integrate ESG issues in a relevant and value-adding way, given the
specificities of their respective investment processes.

22
Q

Therefore, clients’ key questions will always be around the investment decision-making process. Typically this operates on two levels:

  1. An analysis of the formal process and in particular, how ESG is integrated. This will usually also incorporate an assessment of the portfolio as it stands (perhaps using some of the available analytical tools) to take a view as to whether it is consistent with the assertions as to ESG integration.
  2. A discussion of the process as it has been applied to individual assets, usually framed by the client identifying an asset that is questionable from an ESG perspective and testing how it was that the asset in question was deemed to be appropriate to fit within the portfolio.
A

It is this systematic approach of assessing the overall portfolio and testing hard cases that usually reveals whether there is any real substance to the ESG element of the investment process.
The client is attempting to get under the skin of the fund manager’s decision-making processes, to understand what actually determines whether an asset will be included in a portfolio or not, and the decisions that lead to different weightings within the portfolio. It is only through highlighting the factors that may lead to these concrete investment decisions that the fund manager can genuinely demonstrate that its ESG integration approach:

23
Q

Therefore, clients’ key questions will always be around the investment decision-making process.

Typically this operates on two levels:

  1. An analysis of the ***formal process and in particular, how ESG is integrated. This will usually also incorporate an assessment of the portfolio as it stands (perhaps using some of the available analytical tools) to take a view as to whether it is consistent with the assertions as to ESG integration.
  2. A discussion of the process as it has been applied to ***individual assets, usually framed by the client identifying an asset that is questionable from an ESG perspective and testing how it was that the asset in question was deemed to be appropriate to fit within the portfolio.
A

It is this systematic approach of assessing the overall portfolio and testing hard cases that usually reveals whether there is any real substance to the ESG element of the investment process.

The ***client is attempting to get under the skin of the fund manager’s decision-making processes, to understand what actually determines whether an asset will be included in a portfolio or not, and the decisions that lead to different weightings within the portfolio.

It is only through highlighting the factors that may lead to these concrete investment decisions that the fund manager can genuinely demonstrate that its ESG integration approach:

▶ is real and robust; and
▶ can be replicated effectively over time.

24
Q

Furthermore, it is only through understanding how these factors drive concrete investment decisions that the client will begin to have confidence in the robustness of the way ESG is integrated in practice.

Should the fund manager be appointed, future dialogue (the regular review meetings, typically annually, though sometimes more frequent) will again focus on assessing the overall portfolio for consistency with the asserted ESG integration and testing individual investment decisions to assess whether the investment process remains as promised and continues robustly to integrate ESG into decision-making.

It is ***consistency of investment approach that an asset owner tends to be seeking.

A

As well as testing the investment process with hard cases, clients will usually look at metrics – notably portfolio turnover and Sharpe and other ratios – to see if these are consistent with what they understand of the investment process.

Increasingly, there are now also ESG portfolio assessment tools to help facilitate the assessment of the portfolio as a whole.

These look at the overall ESG assessment of the portfolio constituents (typically an overview of the portfolio assessed against each category of E, S and G)

and identify outliers within the portfolio, comparing these to the benchmark.

While these assessments are subject to the challenges around ESG analysis (most notably they are typically highly dependent on the disclosures made by individual companies, which are of variable quality and detail), they at least offer a basis for clients to test and challenge the effectiveness of ESG integration.

Clients might also request the fund manager to provide them with an ESG performance **attribution analysis, providing some insights into the **value added by ESG factors on stock selection.

Clients can use these insights to test and challenge whether the portfolio manager continues to invest in line with the method that they were hired to deliver.

25
Q

Engagement and voting

The other key area of client expectation lies around effective stewardship delivery.

Clients will probe and test the effectiveness of fund manager voting and engagement approaches – both policy and delivery.

There are two crucial bases of assessment for any asset owner:

▶ Who does the stewardship work: specifically, is it delivered by a specialist stewardship team or is it the portfolio managers (or how do these individuals successfully work together)? **

▶ The closely connected issue of: how significant are the resources assigned to stewardship?

A

It should be no surprise that resourcing poses a real challenge to the effectiveness of engagement.

As a recent study by the Institute of ***Chartered Secretaries and Administrators (ICSA) states:

“One factor mentioned by both **issuers and investors were ** investors’ resource constraints.

***With many major investors often holding thousands of firms in their portfolios it is only natural that their resources are stretched to engage meaningfully with all companies.”

While teams are being expanded, this challenge remains – certainly UK company chairs believe that limited investor resource is a major limitation on effective engagement, and a repeated frustration for them.

The ICSA study suggests that there has been an increase in the quantity of engagement but companies perceive that this growth in activity was “not always accompanied by an increase in the quality of engagement”.

26
Q

As discussed in depth in chapter 6, prioritisation of engagements is a key way in which fund managers have
to respond to resource constraints.

Asset owners will want to understand how the fund manager prioritises engagements, both in terms of focusing on individual assets and in terms of prioritisation of particular issues for engagement.

Part of a responsive fund manager’s approach to prioritisation will be to understand what are clients’ key priorities and how these might best be reflected in the fund manager’s programme of activity.

An asset owner will seek to understand through the due diligence process how they can best influence their fund manager and how responsive to their priorities the chosen fund manager is likely to be.

A

Concentrated portfolios are more easily resourced from a stewardship perspective, and those firms that pride themselves on being active stewards are genuinely concentrated and so can commit significant resources to these activities.

And this leads to one way of addressing the resourcing issue: ***portfolio managers themselves becoming more actively involved in stewardship.

This is natural for fundamental active equity managers who hold concentrated portfolios of stocks and would typically maintain a constant dialogue with management.

Stewardship becomes challenging with larger portfolios of many stocks where managers may not have a direct dialogue with all the companies.

Fund management houses with more ***diversified portfolios are more likely to develop larger stewardship teams.

27
Q

The alternatives to building specialist stewardship resource internally are outsourcing and collective action.

Outsourcing

Outsourcing is done by almost all investors in the area of voting, where proxy advisers are hired to provide:

▶ a voting platform and the pipework; and
▶ advice on how to vote.

Different investors lean to different extents on such advice, but few ignore it entirely – not least because of that issue of the breadth of portfolios and the difficulty of addressing all votes in a concentrated period especially for a potentially long tail of small investments.

Voting service providers are somewhat controversial because companies tend to believe that they have too much influence on voting decisions and thus press for higher standards of conduct; increasingly investors ask these providers to apply their own voting templates but few investors reveal the extent to which their voting differs in practice from the voting recommendations of their advisers.

Investors in turn may express frustration that companies often seek more dialogue with the proxy advisory firms than they do with investors themselves.

Some asset owners take control of voting directly; others ask their fund managers to reflect their policies; but the majority tend to leave voting decisions entirely in the hands of their fund managers.

They tend to do this having assessed the alignment in voting policies and approaches as part of the due diligence process, with this alignment playing a part in their choice of manager.

They will also seek to assess the quality of voting decision- making over time as part of the ongoing monitoring process.

As with monitoring of the investment process and investment decision-making, this is best done by talking about hard cases that the client itself identifies.

A

Collective action

The other way in which investors can share resources is through collective vehicles.

28
Q

The alternatives to building specialist stewardship resource internally are outsourcing and collective action.

Outsourcing

Outsourcing is done by almost all investors in the area of voting, where proxy advisers are hired to provide:

▶ a voting platform and the pipework; and
▶ advice on how to vote.

Different investors lean to different extents on such advice, but few ignore it entirely – not least because of that issue of the breadth of portfolios and the difficulty of addressing all votes in a concentrated period especially for a potentially long tail of small investments.

Voting service providers are somewhat controversial because companies tend to believe that they have too much influence on voting decisions and thus press for higher standards of conduct; increasingly investors ask these providers to apply their own voting templates but few investors reveal the extent to which their voting differs in practice from the voting recommendations of their advisers.

Investors in turn may express frustration that companies often seek more dialogue with the proxy advisory firms than they do with investors themselves.

Some asset owners take control of voting directly; others ask their fund managers to reflect their policies; but the majority tend to leave voting decisions entirely in the hands of their fund managers.

They tend to do this having assessed the alignment in voting policies and approaches as part of the due diligence process, with this alignment playing a part in their choice of manager.

They will also seek to assess the quality of voting decision- making over time as part of the ongoing monitoring process.

As with monitoring of the investment process and investment decision-making, this is best done by talking about hard cases that the client itself identifies.

A

Collective action

The other way in which investors can share resources is through collective vehicles.

29
Q

Assessing the quality of engagement and voting

Since resources are always limited, clients should always ask how the fund manager ensures use of its resources is most effective.

Fund managers should be able to set out a thought-through structured approach to targeting engagement and delivering change for the benefit of clients.

A

Example
Fund manager and direct engagement

A fund manager might undertake direct engagement with a few of the larger holdings in the portfolio where concerns on material ESG issues have been identified.

This might be complemented with broader engagement on a number of issues with a larger number of companies through specialist providers.

Finally, the fund manager might identify one key issue (e.g. climate risk disclosure) where systemic change is required and which might best be addressed through collaborative engagement initiatives.

30
Q

It is likely that any structured approach to resource efficiency will always need to encompass some form of collective body as such vehicles assist both in terms of effectiveness and in efficiency.

Voting is also considered by clients as a key aspect of stewardship. Voting often gets more attention in client assessments because the datapoints on voting are clearer, for example:

A

▶ How does the fund manager vote in general?

▶ By what process does the manager reach its decisions?

▶ How did the manager vote on specific controversial matters?

31
Q

It is likely that any structured approach to resource efficiency will always need to encompass some form of collective body as such vehicles assist both in terms of effectiveness and in efficiency.

Voting is also considered by clients as a key aspect of stewardship. Voting often gets more attention in client assessments because the datapoints on voting are clearer, for example:

A

▶ How does the fund manager vote in general?

▶ By what process does the manager reach its decisions?

▶ How did the manager vote on specific controversial matters?

32
Q

The most sophisticated clients use hard cases to test whether the policy and process actually lead to justifiable results in practice.

Assessing engagement is harder. Because engagement is nuanced and long-term, it is hard to have a clear view of its effectiveness.

It occurs in private meetings, so the visibility of even the activity itself is low, but the difficulty goes further than this: effectiveness is largely invisible even for the engager.

Any investor that asserts with certainty that they have made a change happen at a company is most likely overstating their case: in almost every case this simply cannot be known.

There may be a correlation between what an investor sought and what happened, but correlation is not the same as causation.

A

This is reflected in the performance measurements that investors themselves place around engagement.

Mostly developed by the stewardship overlay providers, these are schemes to reflect the changes made by companies as engagement progresses.

Expressed as either milestones or objectives, the engagers measure progress towards concrete change or better practice over the three or more years typical of the engagement process. It is these metrics that clients can assess and challenge, as well as having direct dialogue with the engagement team to gain some confidence in the robustness and sense that lies behind the measurements.

33
Q

ESG AND DIFFERENT CLIENT TYPES
9.1.4

Explain the different client types and their objectives which influence the type of ESG investing strategy selected.

Different clients (institutional, retail or private) have different investment objectives, risk/return profiles and drivers. These will influence the type of ESG investing strategies they will consider most attractive.

A

Table 9.2 provides a (highly) simplified and generalised insight into the likely primary drivers towards ESG investing, and so the relevant risk/return profiles and implied favoured ESG approach, for broad groupings of investors.

As with all generalisations, there will be many individual exceptions to these indicative and broad- brush characteristics.

34
Q

Fund managers that integrate ESG across their funds and genuinely

join up their activities find that engaging with firms with the perspective of

equity and bond investment (and potentially other exposures also, for example through property portfolios)

is often the most productive route of all. The investment house’s overall approach to ESG thus matters to large asset owners, who will tend to probe whether this collaboration across the investment house happens effectively.

A

Growing fields (such as impact investing) have developed as offerings to high-net-worth individuals and foundations into more mainstream investment vehicles. They are at times offered to mainstream asset owners, although there are issues around the scalability of such investments.

In many cases, it is difficult for large asset owners to take an interest in such opportunities because they are not available in large enough pools for it to be worth the attention of the asset owner.

***Liquidity is also an issue for this form of investment: traditionally, a private market form of investing, money is often locked up for lengthy periods, and exiting a position may be difficult for an institutional or retail investor in need of liquidity.

35
Q

There will typically be annual performance discussions with fund managers once appointed; however, some clients may:

▶ insist on more frequent dialogue (this is likely particularly to be the case if financial or other performance has given rise to concerns); or

▶ choose to send a message that they care only about the longer term by waiting longer for any such discussions.

A

Performance (at least for assets that are freely traded or otherwise regularly valued) is likely to be assessed, or at least seen, more frequently than this.

One of the challenges for a client is always to ensure that its fund managers do not become more short-term in their approach because they are aware the client is considering performance on a regular basis.

36
Q

The Brunel Asset Management Accord highlights one way in which clients can do this.

The document emphasises that short-term underperformance is not in itself likely to give rise to undue concern for the client:

“Investment performance, particularly in the short term, will be of limited significance in evaluating the Manager.”

A

Rather, the list of issues that it identifies as likely to give rise to concerns are much more about culture and a failure to adhere to the expected investment process or style:

▶ Persistent failure to adhere to Brunel’s investment principles and the spirit of the Accord.

▶ A change in investment style, or investments that do not fit into the expected style.

▶ Lack of understanding of reasons for any underperformance, and/or a reluctance to learn lessons from mistakes. Conversely, complacency after good performance should be avoided.

▶ Failure to follow the investment restrictions or manage risk appropriately, including taking too little risk.

▶ Organisation instability or the loss of key personnel.

37
Q

Moving away from market benchmarking helps to change the mindset about performance and underperformance.

It is a very different thing for a client to seek absolute returns or performance of a certain number of percentage points above base rates than it is to seek performance ahead of the standard equity benchmarks.

Nonetheless, fund managers will be easily tempted to act in a more short-term way if they perform poorly against a general market performance, and clients who are concerned for long-term performance need to guard against this temptation.

A

As Brunel identifies, the crucial assessment in terms of ESG factors is whether the investment approach has been consistent with the process promised in the mandate and witnessed through the due diligence process. In many ways, the annual or other performance assessment is likely in practice to reflect the style of a due diligence process.

To provide insights into what these processes are likely to involve, the following case study includes a sample set of probing questions of the sort that an asset owner might deploy in discussions with a fund manager,

either before appointment as part of the due diligence phase or in ongoing regular conversations to assess whether the manager is performing in accord with expectations.

These are indicative only and intended to provide an idea of the nature of insight and discussion that an actively engaged asset owner will be seeking:

38
Q

Sample questions an asset owner might ask to gauge a fund manager’s ESG approach

Structural and cultural

You place great emphasis on the size and experience of your firm’s investment team.

▶ How do you ensure that you get a consistent level of quality in terms of ESG analysis from such a disparate group of analysts?
▶ Are there sectors or geographies where you currently worry that the analysis may be weaker?
▶ What do you do to address any weaknesses?

You highlight your interaction with other investment teams.
▶ What does this amount to in practice?
▶ Please provide concrete examples of how this has worked in the recent past, one with your ESG team, and one with one of the other teams.
▶ How has interaction changed in recent years? Property/infrastructure investments, direct and indirect
▶ In your estimate, which of your various property and infrastructure business holdings is best positioned in terms of preparedness for climate change and the physical disruptions which seem increasingly frequent from extreme weather events?
▶ Which of your holdings is the least ready given the differences in geographical exposure to disruption?
▶ What does that mean for your portfolio positioning?

Financial sector investments
Bank X has recently made a commitment on coal project financing.
▶ Do you believe that undertaking is strong enough to ensure its risk profile on carbon-intensive assets?
▶ Not least given the bank’s ongoing lending to oil and gas related projects, do you believe that it has a clear understanding of climate risk and potentially stranded assets in its lending portfolio?

How have you assessed the lending practices of non-bank lenders in your portfolio relative to their peers?

Please describe how you have analysed their risk management in light of the significant failures in the sector and tightening regulatory environment.

You are interested in Insurance Company AA.
▶ Have you discussed with Insurance Company AA its approach to the risk of exposure to disruptions arising from climate change?
▶ How have you assessed their overall transition risk exposure?
▶ Are you confident that the company understands its exposures fully and is equipped and skilled enough to be managing them appropriately?

A

Industrial sector investments
You are liaising with Industrial Business Y.
▶ Are you concerned by the allegations regarding worker treatment at Industrial Business Y?
▶ Have you built into your model any expectation of fines or substantial damages claims, and are you confident that the dividend remains secure in most realistic scenarios?
▶ Can you be sure that the business is sustainable when it relies on such employment practices to maintain profitability?
▶ Do you have concerns about the costs of any changes in facilities or working practices to avoid future such exposures?
▶ Do you believe the company will retain staff, and continue to be able to recruit appropriately skilled individuals?

You have a sizeable aggregate position in Company GG. The governance of the company is particularly weak.
▶ What makes you comfortable that the business is run and overseen effectively and will appropriately address emerging challenges?
▶ Is the complexity of the corporate structure more about financial structuring and tax minimisation than anything else?
▶ In which case is there a risk that the management and board (which suffers from poor independence and weak governance) may miss signals from the underlying businesses because information flow is weak through the complex corporate structure?
▶ How are you engaging with the company on these issues and what progress have you made so far?

You are liaising with Company BB.
▶ What do you think about Company BB’s exposure to corruption risks?
▶ Does it have satisfactory management structures to mitigate and manage such exposures?
▶ Are you confident in the company’s approach to money-laundering protections and in knowing the full backgrounds of its business partners?

Extractives sector investments
You have some significant holdings in oil and gas businesses.
▶ What is your reflection on the risks that they face in terms of stranded assets?
▶ Which of these companies best understands the risks of climate change for their business models?
▶ How are they considering transitioning their businesses to a more carbon-constrained world?

State-linked extractives company Z is also highly politicised.
▶ Are you content that its investments are commercial and will give economic returns, rather than more based in geopolitics on behalf of the government?

39
Q

Sample questions an asset owner might ask to gauge a fund manager’s ESG approach

Structural and cultural

You place great emphasis on the size and experience of your firm’s investment team.

▶ How do you ensure that you get a consistent level of quality in terms of ESG analysis from such a disparate group of analysts?
▶ Are there sectors or geographies where you currently worry that the analysis may be weaker?
▶ What do you do to address any weaknesses?

You highlight your interaction with other investment teams.
▶ What does this amount to in practice?
▶ Please provide concrete examples of how this has worked in the recent past, one with your ESG team, and one with one of the other teams.
▶ How has interaction changed in recent years? Property/infrastructure investments, direct and indirect
▶ In your estimate, which of your various property and infrastructure business holdings is best positioned in terms of preparedness for climate change and the physical disruptions which seem increasingly frequent from extreme weather events?
▶ Which of your holdings is the least ready given the differences in geographical exposure to disruption?
▶ What does that mean for your portfolio positioning?

Financial sector investments
Bank X has recently made a commitment on coal project financing.
▶ Do you believe that undertaking is strong enough to ensure its risk profile on carbon-intensive assets?
▶ Not least given the bank’s ongoing lending to oil and gas related projects, do you believe that it has a clear understanding of climate risk and potentially stranded assets in its lending portfolio?

How have you assessed the lending practices of non-bank lenders in your portfolio relative to their peers?

Please describe how you have analysed their risk management in light of the significant failures in the sector and tightening regulatory environment.

You are interested in Insurance Company AA.
▶ Have you discussed with Insurance Company AA its approach to the risk of exposure to disruptions arising from climate change?
▶ How have you assessed their overall transition risk exposure?
▶ Are you confident that the company understands its exposures fully and is equipped and skilled enough to be managing them appropriately?

A

Industrial sector investments
You are liaising with Industrial Business Y.
▶ Are you concerned by the allegations regarding worker treatment at Industrial Business Y?
▶ Have you built into your model any expectation of fines or substantial damages claims, and are you confident that the dividend remains secure in most realistic scenarios?
▶ Can you be sure that the business is sustainable when it relies on such employment practices to maintain profitability?
▶ Do you have concerns about the costs of any changes in facilities or working practices to avoid future such exposures?
▶ Do you believe the company will retain staff, and continue to be able to recruit appropriately skilled individuals?

You have a sizeable aggregate position in Company GG. The governance of the company is particularly weak.
▶ What makes you comfortable that the business is run and overseen effectively and will appropriately address emerging challenges?
▶ Is the complexity of the corporate structure more about financial structuring and tax minimisation than anything else?
▶ In which case is there a risk that the management and board (which suffers from poor independence and weak governance) may miss signals from the underlying businesses because information flow is weak through the complex corporate structure?
▶ How are you engaging with the company on these issues and what progress have you made so far?

You are liaising with Company BB.
▶ What do you think about Company BB’s exposure to corruption risks?
▶ Does it have satisfactory management structures to mitigate and manage such exposures?
▶ Are you confident in the company’s approach to money-laundering protections and in knowing the full backgrounds of its business partners?

Extractives sector investments
You have some significant holdings in oil and gas businesses.
▶ What is your reflection on the risks that they face in terms of stranded assets?
▶ Which of these companies best understands the risks of climate change for their business models?
▶ How are they considering transitioning their businesses to a more carbon-constrained world?

State-linked extractives company Z is also highly politicised.
▶ Are you content that its investments are commercial and will give economic returns, rather than more based in geopolitics on behalf of the government?

You hold a number of mining businesses. Their business models are inherently unsustainable.
▶ Which of these companies manages its E&S risks best and which retains the greatest downside exposures?
▶ Which has a better handle on health and safety issues, which better considers the implications of climate change (including the physical risks of extreme weather events) for their business?
▶ What has that analysis meant for your investment allocations?

Debt investments
The fund has a number of sovereign debt holdings, in particular exposures to CC and DD governments.
▶ Do you consider that those countries have appropriate and effective national responses to the challenge of climate change?
▶ Aren’t their nations and economies particularly exposed to extreme weather events and also to water shortages already, factors that will only intensify as climate change progresses over the time-horizon of your bond holdings?
▶ Will they be able to respond robustly and effectively to these challenges, without affecting economic activity and their ability to finance existing debt?
▶ What is your exposure to green bonds in the portfolio? Why is there only minimal exposure?

40
Q

MEASUREMENT AND REPORTING

A

ESG reporting by investment managers is widespread, but varies in quality. It ranges from:

▶ general discussions of current debates and themes with no clear linkage to the work of the fund manager, sometimes associated with generalised aspirations or assertions; through to

▶ much more concrete discussions of the work actually done by fund managers and what has been delivered in practice to the shape of portfolios and in terms of change through engagement.

Investment firms produce annual (and often quarterly reports) describing:

▶ their processes;

▶ the themes that they have worked on; and

▶ case studies on ESG investing or stewardship, or both.

Investment firms that are signatories to the PRI are also required to submit an ***annual report on their activities. According to the PRI, the reporting process allows signatories to:

▶ evaluate their responsible investment progress against an industry-standard framework;

▶ receive ongoing feedback and tools for improvement;

▶ benchmark their performance against peers;

▶ see the big picture by understanding the state of the market;

▶ strengthen internal processes and build ESG capacity; and

▶ summarise activities for staff, clients, shareholders and regulators

41
Q

***The attribution of returns to ESG is challenging, not least because of the significant range of investment approaches that are included within the broad realm of ESG investing.

A

Furthermore, the more fully integrated ESG becomes into the investment process, the harder it becomes to disaggregate the ESG!!

42
Q

***The attribution of returns to ESG is challenging, not least because of the significant range of investment approaches that are included within the broad realm of ESG investing.

A

Furthermore, the more fully integrated ESG becomes into the investment process, the harder it becomes to disaggregate the ESG!!

43
Q

In ***2015, the PLSA published a disclosure guide for public equities

***developed by a group of pension schemes,

*** setting out some

pared down expectations for manager-reporting on both ESG integration and stewardship activities.

The disclosure on ESG integration asks for separate disclosure on both:

A
  1. identification of ESG risk; and
  2. the management and monitoring of ESG risks and opportunities, with suggested possible disclosures in respect of each.

The first three possible points offered as ways to demonstrate the identification of ESG risk and opportunity are:

▶ Examples of where and why the manager is prepared to take either stock or sector ESG risks or where it sees opportunities.

▶ Quantitative or qualitative examples of material ESG factors identified in fundamental analysis and stock valuation.

▶ Identification of long-term ESG secular trends and themes (as potential determinants of future growth/ valuation etc.) and the extent to which they have influenced portfolio construction decisions.

The proposed possible disclosures to demonstrate the management and monitoring of ESG risks and opportunities include:

▶ Stock level ESG analysis for top risk and performance detractors/contributors in the reporting period.

▶ Any material changes to portfolio companies’ ESG performance. Examples may include where the manager’s
view of ESG risk and opportunity differs from the market/rating agencies.

44
Q

LASTLY

The PRI’s 2016 Practical Guide to ESG integration for Equity Investing

(which builds on the organisation’s 2013 publication on aligning expectations)

includes multiple different case studies from fund managers outlining their approach to ESG integration and highlighting their assessments of how their ESG work has added value.

A

It is apparent that there are as many approaches to the integration of ESG factors as there are underlying investment approaches themselves.

What the asset owner will need to know is whether the ESG approach is genuinely aligned with the fund manager’s investment style, is delivered effectively in practice, and is aligned with their own investment needs and beliefs.

To guard against a fund manager cherry-picking ESG cases,

some clients seek to identify outliers so that they can test whether the asserted method for ESG integration is genuinely delivered in practice, consistently across the portfolio as a whole.

There is no set or agreed format for engagement disclosure, and so, each fund manager has their own model.

Typically, this includes statistics on activity, at a greater or lesser level of granularity.

It is no longer acceptable to provide statistics at organisation level that are not specifically tailored to the fund in question.

In addition, the typical disclosure includes a sample of written descriptions of individual engagement meetings; again, these should be tailored to the fund, but many fund managers reveal more about the focus of their activities than they intend ***** by the imbalance in their reporting towards their home market and region.

Many fund managers, and particularly the specialist stewardship providers, disclose their form of analysis of what engagement has delivered in the period through engagement

– either milestones or progress against KPIs –

their assessment of progress in engagements.

These are proprietary models and inevitably, somewhat prone to a little bias in the analysis, but clients are able to test these in detail.

At least, they provide some insight into delivery from engagement, which is more than a little opaque from the outside.

45
Q

LASTLY

The PRI’s 2016 Practical Guide to ESG integration for Equity Investing

(which builds on the organisation’s 2013 publication on aligning expectations)

includes multiple different case studies from fund managers outlining their approach to ESG integration and highlighting their assessments of how their ESG work has added value.

A

It is apparent that there are as many approaches to the integration of ESG factors as there are underlying investment approaches themselves.

What the asset owner will need to know is whether the ESG approach is genuinely aligned with the fund manager’s investment style, is delivered effectively in practice, and is aligned with their own investment needs and beliefs.

To guard against a fund manager cherry-picking ESG cases,

some clients seek to identify outliers so that they can test whether the asserted method for ESG integration is genuinely delivered in practice, consistently across the portfolio as a whole.

There is no set or agreed format for engagement disclosure, and so, each fund manager has their own model.

Typically, this includes statistics on activity, at a greater or lesser level of granularity.

It is no longer acceptable to provide statistics at organisation level that are not specifically tailored to the fund in question.

In addition, the typical disclosure includes a sample of written descriptions of individual engagement meetings; again, these should be tailored to the fund, but many fund managers reveal more about the focus of their activities than they intend ***** by the imbalance in their reporting towards their home market and region.

Many fund managers, and particularly the specialist stewardship providers, disclose their form of analysis of what engagement has delivered in the period through engagement

– either milestones or progress against KPIs –

their assessment of progress in engagements.

These are proprietary models and inevitably, somewhat prone to a little bias in the analysis, but clients are able to test these in detail.

At least, they provide some insight into delivery from engagement, which is more than a little opaque from the outside.