Integrating ESG into pension schemes’ Statements of Investment Principles

“We believe that pension schemes should recognise that the key, material ESG risks and opportunities of their investments can have a material impact on their longer-term performance.”

The growing importance of ESG

Environmental, social & governance (ESG) issues have rapidly grown in prominence throughout the investment world. We believe that pension schemes should recognise that the key, material ESG risks and opportunities of their investments can have a material impact on their longer-term performance. This idea is reflected in new legislation regarding trustees’ fiduciary duties and schemes’ Statements of Investment Principles (SIPs).

The importance of ESG has been recognised by the Department for Work & Pensions (DWP) in its consultation paper: “Clarifying and strengthening trustees’ investment duties.” (September 2018)

In it, the DWP proposes that, when preparing SIPs, a trustee/ scheme must show the extent to which the underlying manager is taking material ESG issues into consideration when selecting investments. More recent legislative changes have supported this view – detailing climate change, social impacts and regulatory updates that could impact investments – and should be taken into consideration by trustees. This also applies to the design of any default investment strategy for defined contribution (DC) benefits offered by the scheme.

Our 51 questions

To help with this, we have drafted 51 questions that should improve ESG disclosure in SIPs. By answering these questions, the trustee can demonstrate how they view key, material ESG-related issues. The questionnaire can also show the degree to which ESG-related considerations were part of the invest decision-mak- ing process.

The questions come under five broad headings (see below) and can be found in this document.

  1. Define who you are as a scheme – what makes you unique?
  2. Explain your purpose/goals and philosophy – why invest?
  3. How does your philosophy relate to ESG integration? – what is your stance?
  4. State your expectations of investments? – what do you expect to achieve?
  5. State your expectations of managers – what do you want from them?

Final thoughts…

The changes to regulations regarding SIPs present a real opportunity for trustees to improve how they communicate with their underlying managers. It will also help them protect their reputations and enhance how they are viewed externally.

Further, they are a concrete way for trustees to demonstrate what they expect of their underlying investment managers in terms of how they integrate material ESG considerations into their investment decision-making. Ultimately, this should have a longer-term positive impact on the returns gained by pension schemes and on their underlying members.

Determining the extent to which managers integrate ESG factors into investment decisions

    ESG / SRI / RI / Sustainability / Ethical / Stewardship / Impact investing factors into investment decisions

  1. Does your group use these terms at all to describe any part of its investment? If so, please detail, making sure to explain any differences in nomenclature. Please use terms consistently (and as defined by you) throughout this questionnaire. (We use “ESG” to refer to this area throughout the survey, but please use the most appropriate term for you in your response.)
  2. Please state how, if at all, the group sees the difference between financial and non-financial factors in an investment context.
  3. Firm’s own culture with regard to ESG

  4. Describe briefly how / the extent to which your firm’s culture sees ESG and its relevance to the ability to sell products, its significance within an overall marketing context, its importance (longer term) to the ability of the firm to be competitive, as well as its ability to make investment decisions.
  5. Please detail any direct impacts that the group, itself, has experienced from the market’s (or clients’) expectations on transparency / integration of ESG into the firm’s own business.
  6. To what extent does your organisation support ESG-related bodies or associations? Include any relevant signatory status / membership along with the date your group began supporting the ESG-related body.
  7. If your firm regularly completes industry body ESG type surveys, please list these.
  8. Do these surveys impact on the firm’s own ESG / SRI / CSR / Sustainability reporting? If so, please explain the extent to which this is the case.
  9. ESG structure & teams – ALL ASSET CLASSES

  10. Does your group have an ESG policy covering all of its investments / all asset classes? If so, please list the asset classes to which the policy / policies apply.
  11. When was the group’s ESG policy / policies put in place? (List separately, by asset class, as appropriate).
  12. What internal support / structure does the group have for ESG integration? Please include details of Board / exec support, source of funding within the company, as well as committees and / or intra-departmental support for ESG.
  13. Describe the structure of your ESG team and / or ESG representatives, detailing how they relate to the overall business. Please include details of who these teams / specialists support and briefly how this relates to the investment processes by asset class. Detail which internal cost centre pays for the ESG team / resource. If the group does not have an internal ESG team but buys in external research, please name the internal cost centre for that expense.
  14. If the group has an ESG / RI / SRI / Stewardship team, or ESG specialists, please list the individual members and their roles. Include details on their tenure in the firm, experience within the ESG industry, as well as their reporting lines.
  15. How / on what basis are members of the ESG team (or specialists) remunerated? Also, what training is provided to support the career advancement of individual members / specialists?
  16. Does any ESG training extend to the actual investment teams? Please delineate by asset class, as appropriate.
  17. Do the ESG team or specialist ESG individuals have the ultimate call on whether an ESG issue / topic triggers a buy /top up / top slice/ sell decision? If so, provide details on which funds (ESG, SRI, RI, ethical, mainstream) for which this decision responsibility relates.
  18. ESG information sourcing – ALL ASSET CLASSES

  19. Does your group subscribe to an external ESG resource provider (e.g. Sustainalytics, MSCI, Vigeo, EIRIS, etc.)? If so, detail whether the information you receive is on ESG scores (plus background), ESG controversies, or other ESG-related information. State whether all asset classes within the firm use this information or if there are differences between the group’s asset classes and fund types in terms of their receiving ESG information. (E.g. equities receives complete ESG coverage while fixed income uses only ESG scores; or perhaps the group uses only ESG scores for its SRI / ethical funds but uses more complete information for its mainstream or ESG funds.)
  20. How long has your group used externally sourced ESG information? How has this use changed over time? Please delineate by asset class, where appropriate.
  21. Does the group use any other type of external information when examining / considering ESG issues, such as broker research, ESG information available on Bloomberg, etc? If so, please specify some of the main sources.
  22. Does the group have a central source for its ESG-related information internally? If so, please detail the types and depth of information sourced.
  23. Where is information (sourced internally or externally) kept within the group? Which parts of the business can access it? Please detail if the ESG information can be mined by topic, author, asset / company, and / or by date.
  24. Internal ESG scoring / rating – ALL ASSET CLASSES

  25. Does the group have its own internal ESG (or other term) scoring or rating system? If so, please provide details. Please delineate by asset class, where appropriate.
  26. What does the firm’s ESG scoring system measure? How frequently are ESG scores reassessed? Which team / group / individuals undertake this work?
  27. Once an asset / investment has been attributed an ESG score, how can this score change over time, if at all? Please include details on process, oversight, targets / hurdles, thresholds, engagement, time lines, etc.
  28. What weighting, if any, does the ESG score have in the buy / top up / top slice / sell decision-making process? Please delineate the various processes by asset class.
  29. If a potential investment / current holdings does not meet a particular ESG rating / hurdle / score, is it still considered to be investable?
  30. How do you foresee this rating system changing or evolving going forward, if at all?
  31. ESG integration into investment decision making process – ALL ASSET CLASSES

  32. Does the group consider ESG issues when making equity investment decisions? If so, please explain fully, including details on the overall process, work flows, team discussions, the extent to which any ESG (or related) scoring system (or other triggers) impacts an investment decision, etc. Please detail by asset class.
  33. What happens in the event that a potential investment scores well from a financial or balance sheet perspective but not so from an ESG perspective (or vice versa)? How are these two considerations (financial and ESG) weighed together in forming an investment decision? Detail by asset class (where the answers are different).
  34. In the event that a decision is made to sell a holding, based at least in part on ESG factors, how long will it be before that asset is reconsidered for investment purposes?
  35. ESG engagement – ACTIVE EQUITIES

  36. To what extent does the firm undertake engagement with its investee companies? Please detail how frequently engagement is used, what it is used for, at what point in the investment process engagement is undertaken, and by whom (within the firm) this is undertaken. (If the firm hires external bodies to undertake research on their behalf, please specify this and explain what is covered, the frequency, and the extent to which this is done on behalf of the group.)
  37. How, if at all, does this engagement include / reflect ESG considerations?
  38. Does the firm take an activist stance with regard to any issue(s)? If so, please describe.
  39. Whether or not the firm takes an activist stance in its engagements, does the firm set targets with investee companies for the purpose of improving the asset in some way (either in the shorter, medium or longer term)?
  40. Does the group take a thematic, sectoral, risk-based, or other approach to its ESG programme (for active equities)? Please explain fully, including top-down / bottom-up approaches.
  41. Please detail which representatives from companies that you typically meet with to discuss ESG issues / risks.
  42. Escalation of ESG concerns – ACTIVE EQUITIES

  43. How and to what extent, if at all, does the firm escalate ESG concerns with investee companies? Which team undertakes escalation? Where the firm hires out this escalation, please detail.
  44. What happens if companies react positively to ESG-related engagement? What happens if they take no action or react negatively? How do each of these scenarios impact the investment process?
  45. Are details of escalation / outcomes detailed in the group’s engagement reporting to clients?
  46. ESG due diligence for Fund of Funds – FoF PLATFORMS; INDIRECT INVESTMENT

  47. When undertaking due diligence on external mangers (for Fund of Funds or indirect investment), to what extent, if at all, does the group ask about the extent to which the external managers integrate ESG considerations into their investment decision making process? How is this done? Does the firm use a proprietary set of questions when assessing other managers? Which areas, specifically, do the questions cover and how are the responses weighed to help the firm determine which external managers to use?
  48. What kind of reporting, if any, does the group request from FoF managers in terms of ESG?
  49. For INDIRECT PROPERTY managers – does the firm use GRESB when considering external property managers? How is this evaluation used when selecting a manager?
  50. ESG reporting – ALL ASSET CLASSES

  51. Does the group actively report to its clients on its ESG-related engagements? Are any of these reports in the public domain? If so, please provide link.
  52. Please briefly detail the topics that are covered in the group’s Stewardship / RI / ESG / engagement reporting (including any proxy voting details, progress made against targets, and status update). In the report, does the group name the investee companies with which it undertakes engagement? Please explain why or why not.
  53. How frequently are engagement reports produced and which teams undertake this task? How does this reporting link, if at all, to the fund management teams?
  54. Does the firm supply ad hoc or bespoke reports to clients on ESG funds and / or issues on which the client is focused or concerned? If so, please detail where the group has done this in the past or in which areas it is willing to consider for potential clients.
  55. Do you benchmark your engagement reporting against other managers / best practice in the industry? How frequently do you take assessment of your engagement reporting to ensure that it is in line with other managers?
  56. ESG-related performance – ALL ASSET CLASSES

  57. Please provide, where possible, details on how the firm’s active equity funds with an ESG (or similar) theme or overlay perform as compared (over a similar time period) to a fund without this consideration. Please detail by asset class.
  58. What do you, as the manager, consider to be the ‘value add’ of integrating ESG considerations into the investment management process (as applicable)?
  59. Product-related questions on ESG

  60. For firms that market funds in France – do any of your products bear the “SRI label” that was set up by France’s Ministry of Finance in January 2016?
  61. Does the group have any funds (in any asset class) which utilise a negative screening or divestment approach by topic or theme? If so, please list below, along with details on the activity, industry, sector or theme in which the fund avoids investing. Please include threshold turnover limits or hurdle rates for the negative screens / divestment themes.
  62. Will the firm consider servicing specific ESG requests, such as measuring carbon emissions at the portfolio level, even if the group does not currently service such client requests? How flexible is the firm in responding to these types of ad hoc requests?
“The changes to regulations regarding SIPs present a real opportunity for trustees to improve how they communicate with their underlying managers. It will also help them protect their reputations and enhance how they are viewed externally.”

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Risk Warning

The value of investments, and the income from them, can go down as well as up and you may get back less than the amount invested.