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Impax Asset Management

PRI reporting framework 2017

Export Public Responses

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LEA 01. Description of approach to engagement

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. 貴社に正式なエンゲージメントポリシーがあるかどうか示してください

01.2. エンゲージメントポリシーがカバーしている内容を示してください。

          Engagement processes and policies for on-going monitoring and escalation.

01.3. エンゲージメントポリシーのURLを記載してください。[任意]

01.4. エンゲージメントに対する貴社のアプローチの概要を説明してください。

Engagement is an important part of our ESG analysis and the investment process more broadly. Impax is a fundament-driven investor with a long-term investment horizon. We engage with companies when we have identified specific ESG-issues or concerns, when we require further information regarding an ESG-aspect (that is not publicly disclosed) or in order to encourage improvement in company ESG policies, processes and disclosures. We engage individually and together with other investors.

Engagement allows us to:

  • Manage risks; proactively identify and mitigate issues
  • Enhance company analysis; how companies respond to engagement is highly informative and this information is included in our ESG-analysis and our proprietary ESG-scoring of our companies
  • Strengthen our investee companies over time; improving transparency, quality, processes and resilience

Our engagement work can be divided into the following types:

  • Engagement with smaller companies
  • Longer-term strategic engagement priorities
  • Collaborative engagement
  • Pre- or post AGM engagement
  • Company due diligence & monitoring

We engage as part of our regular meetings with companies or through additional conference calls, meetings or emails or as part of joint communications with the investment community.

We maintain an engagement database detailing engagement issues, timings, outcomes and current status. It is reviewed regularly for unresolved issues requiring follow-up.

01.5. 補足情報 [任意]

LEA 02. Reasoning for interaction on ESG issues

02.1. エンゲージメントの方法および対話を行う理由を明示して下さい。


          Monitoring, due diligence and escalation


          Escalation of an issue


02.2. 補足情報。[任意]


Process for engagements run internally

LEA 03. Process for identifying and prioritising engagement activities

New selection options have been added to this indicator. Please review your prefilled responses carefully.

03.1. 貴社内のスタッフが実行するエンゲージメント活動を特定し、優先順位を決定する正式なプロセスが貴社にあるかどうか示してください。

03.2. 貴社内のスタッフが実行するエンゲージメントを特定し、優先順位を決定する際に使用する基準を説明してください。


          Monitoring (ESG-analysis), due diligence, escalation.

03.3. 補足情報。 [任意]

Our engagement work can be divided into the following types:

1. Engagement with smaller companies

We focus on smaller companies to strengthen governance structures, introduce sustainability policies, processes and disclosures, for companies to manage effectively their most material ESG-risks. Impax has developed a proprietary cost-effective framework to advice companies on how to develop robust, material and cost-effective sustainability reporting.

2. Longer-term strategic engagement priorities

Every year we assess and state the engagement priorities for the next 12 months, based on market developments and emerging ESG and sustainability issues that we have identified and that are relevant and material for our companies. We then identify the companies most exposed to the issues in question and focus our engagement on those companies. While we assess these priorities every year, they may not change annually; they are often of long-term nature.

3. Collaborative engagement

We regularly engage on ESG issues, specific sectors and companies together with other investors and partners with or without a lead or coordination from responsible investment organisations. These are collaborative engagements where outreach may particularly benefit from a larger group of shareholder involvement or in cases where an issue is being escalated.

4. Pre- or post AGM engagement

We engage with many of our companies either before or after AGM and proxy voting. It is predominantly related to governance and issues such as election of directors, board structures and management remuneration. Where we vote against an AGM resolution, we aim at informing the company before the AGM, or at least after the AGM.

5. Company due diligence & monitoring

As part of our 10-step company analysis, we often engage with companies to find information and clarification regarding specific governance issues, environmental and/or social risks that have not been clearly addressed, explained or disclosed by the company. This is part of our on-going monitoring of our companies.


Company monitoring and escalation

The Impax investment team has established internal processes and uses various external research tools to monitor our investee companies regarding their financial, operational, strategic, sustainability and governance developments that highlight possible areas of concerns and priorities for engagement.

Where material concerns or anomalies at an investee company have been confirmed, the Impax investment team will intervene and escalate matters in order to mitigate risks and preserve shareholder value.

We will immediately contact the investee company management team and where relevant and possible members of the company board. Typically, we would request a conference call with the management team, to discuss the concern in detail. We would also contact the company’s brokers for information.

If the investee company is unresponsive to engagement or we view, upon clarification with the management team, that the company is taking an approach that is significantly increasing shareholder risks and the company is unwilling to consider less risky approaches, we would escalate our activities as follows:

  • Intervene or engage together with other institutions on the issue
  • Feeding back to company’s advisors especially regarding voting matters
  • Highlighting the issue and/or joint-engaging regarding the issue through institutional platforms like the UN PRI
  • Filing or co-filing resolutions at General Meetings

We believe that we can be more constructive and ultimately in the long-term more influential with our investee companies, if we maintain good relations and where possible interact and engage directly with the company on specific concerns. Public statements or filing resolutions would be last resort activities in exceptional circumstances.

Ultimately, if the interventions were not successful and we consider that the risk profile of the company has significantly deteriorated or company strategy or governance structures have altered, to a degree where the return outlook and the company strategy and quality no longer meet our expectations, the company would be excluded from our investable universe and/or sold.

LEA 04. Objectives for engagement activities

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04.1. 貴社内のスタッフが実行する貴社のエンゲージメント活動に具体的な目的を定義しているかどうかを記載してください。

04.2. 貴社内のスタッフが実行する貴社のエンゲージメントを受けた企業の行動を監視しているかどうかを記載してください。

04.3. 貴社内のスタッフが実行するエンゲージメント活動のためにマイルストーンと目標を貴社で定義しているかどうか示してください。

04.4. 貴社内のスタッフが行うエンゲージメント活動の進捗を監視のうえ評価するために以下のいずれかを実施しているかどうか示してください。

04.5. 補足情報。[任意]

Process for engagements conducted via collaborations

LEA 05. Process for identifying and prioritising collaborative engagement

New selection options have been added to this indicator. Please review your prefilled responses carefully.

05.1. 協働的なエンゲージメントを特定し、優先順位を決定する正式なプロセスが貴社にあるかどうか示してください。

05.2. 協働的エンゲージメントを特定し、優先順位を決定する際に使用する基準を説明してください。

05.3. 補足情報 [任意]

Collaborative engagements and joint-representations with other institutions and investors are an important part of Impax’s engagement work. We initiate collaborative engagements where the engagement and outreach may particularly benefit from a larger group of shareholder involvement or in cases where an issue is being escalated. Collaborative engagements can also be preferred and effective when approaching an issue or risk that is affecting a larger group of companies; a sector-level engagement.    

LEA 06. Objectives for engagement activities

New selection options have been added to this indicator. Please review your prefilled responses carefully.

06.1. 貴社が関与する協働的なエンゲージメントに目的が定義されているかどうか示してください。

06.2. 貴社の協働的なエンゲージメントを受けた企業の行動を監視しているかどうか示してください。

06.3. 協働エンゲージメント活動に関連したマイルストーンと目標を貴社で定義しているかどうか示してください。

06.4. 貴社のエンゲージメント活動の進捗を監視し、評価するために以下のいずれかを実施しているかどうか示してください。

06.5. 補足情報 [任意]

We maintain an engagement database where the engagement issues, actions, timings and outcomes are detailed. We review the database regularly and if an issue remains unresolved, we follow-up with the company.

However, for more general nature e.g. sector-level collaborative ESG-engagements, we do not always monitor and evaluate to the same degree as we do regarding company engagements of specific issues.

General processes for all three groups of engagers

LEA 09. Share insights from engagements with internal/external managers

09.1. エンゲージメントから得た考察を、貴社内の運用担当者や貴社外の運用会社と共有しているかどうかを記載してください。




09.2. 補足情報。[任意]

Engagement is an important part of our ESG-analysis, which in itself is an integral part of the investment process. Engagement outcomes are important in investment decisions and need to be shared within the investment team. "Engagement" is a standing agenda item during our weekly Investment Committee meetings and engagements, both individual and collaborative, including the issues, actions, status and next steps are discussed and minuted.

LEA 10. Tracking number of engagements

10.1. 貴社がエンゲージメントしている企業の数を追跡しているかどうかを記載してください。



10.2. 補足情報。[任意]

We maintain an engagement database where the engagement issues, actions, timings, outcomes and next steps are detailed. We review the database regularly and if an issue remains unresolved, we follow-up with the company in question.

We also disclose publically the number and types of engagements done during a year.

Outputs and outcomes

LEA 11. Number of companies engaged with, intensity of engagement and effort

11.1. 報告年度に貴社がエンゲージメントを行った上場株式ポートフォリオの数を明示してください。





28 Number of companies engaged
13 Proportion (to the nearest 5%)

Specify the basis on which this percentage is calculated




13 Proportion (to the nearest 5%)

Specify the basis on which this percentage is calculated

11.2. ESG問題に関連して報告年度中に企業と複数かつ現実的で詳細にわたる議論ややりとりを行ったエンゲージメントの割合を記載してください。








11.3. 報告期間の協働的なエンゲージメントの中で、貴社が主導したエンゲージメントの割合を記載してください。 [任意]





11.5. 補足情報。[任意]

In 2016 our engagement work divided as follows:

  • Engagement with smaller companies, 9%
  • Longer-term strategic engagement priorities, 18%
  • Collaborative engagement, 51%
  • Pre- or post AGM engagement, 12%
  • Company due diligence & monitoring, 11%


In 2016 our collaborative engagements were increasingly focused on more in-depth, longer-term specific ESG issues at the company-level, together with Impax's partners and less broad, lighter-touch sector or thematic collaborative engagements.


LEA 12. Engagement methods

12.1. 貴社のエンゲージメントが以下のどの項目を含むか明示してください。

          Advice. Detailed advice for especially smaller companies regarding establishing material, cost-effective sustainability processes and reporting. Longer-term and in-depth engagements.

12.2. 補足情報 [任意]

LEA 13. Engagements on E, S and/or G issues

13.1. 報告年度におけるエンゲージメントがESGを対象としたかについて明示するとともに、ESG問題のおおよその内訳を記載してください。


43 環境のみの割合(%)
9 社会のみの割合(%)
35 コーポレートガバナンスのみの割合(%)
13 ESGが重複する割合(%)
Total 100%


52 環境のみの割合(%)
15 社会のみの割合(%)
0 コーポレートガバナンスのみの割合(%)
33 ESGが重複する割合(%)
Total 100%

13.2. 補足情報。[任意]

In 2016 our collaborative engagements were increasingly focused on more in-depth, longer-term specific ESG issues at the company-level, together with Impax's partners and less broad, lighter-touch sector or thematic collaborative engagements.

LEA 14. Companies changing practices / behaviour following engagement

14.1. 報告年度に貴社や貴社のサービスプロバイダーのエンゲージメント活動を受けて、企業が実務を変更した、または実務を変更するように正式に約束した事例件数を追跡しているかどうか明示してください。

14.2. 報告年度に貴社や貴社のサービスプロバイダーのエンゲージメント活動を受けて、実務を変更した、または実務を変更するように正式に約束した企業の数を記載してください。






14.3. 補足情報。

We focus our engagement on smaller companies and their governance and sustainability processes and structures. These companies are often positively disposed regarding ESG improvements, however often face limits to resources, both regarding staff and funds. The outcomes of these engagements often take time to crystallise, but we are encouraged by the continued and increased positive outcomes from our engagements, especially with US-based companies.

LEA 15. Examples of ESG engagements

15.1. 報告年度に貴社または貴社のサービスプロバイダーが実行したエンゲージメントの事例を挙げてください。

          Small company engagement. US materials recycling company, advice regarding establishing sustainability processes and reporting, following Impax's cost-effective, material framework.

To give the company clarity on how cost-effective, material sustainability reporting can be established.

We suggested that strong initial sustainability reporting can be short, but very much to the point and would have the following elements (step-by-step):

1. Discussion around the most material non-financial (environmental, social) risks for company.
2. Establishing a small number of key metrics (KPIs) around these main or most material risks for company.
3. Reporting the annual statistics around these metrics (e.g. C02 emissions (direct/indirect), toxic emissions, staff accidents/incidents, food/product safety)
4. Setting targets around these metrics and establish regular reporting on how well they have been achieved.
5. Establishing management systems and processes  to enable achieving the targets (e.g. ISO 14001, OHSAS 18001, HACCP).

This can be 2-3 pages, no sizable, glossy CSR reports required.


This has been an on-going dialogue with mainly company IR over a number of months and has involved several conference calls and email exchanges to develop the process to this point. 


On the back of this engagement, the company has committed to sustainability reporting and is in the process of implementing it.

          AGM-related governance engagement. Finnish water treatment company.

Objective is to improve company remuneration-related practices, disclosures and transparency.

ISS QuickScore has a weak score for the company's remuneration practices and disclosures.


Email exchanges, including detailed explanation of issues and one conference call with the company IR and head of sustainability and governance


Company’s ISS QuickScore already improved from 8/10 to 7/10 due to their clarifications regarding stock options, LTIP to ISS after our initial email exchange with company. Company will be introducing LT performance periods going from 1 to 3 years, Claw-back policy, in place, they will now be externally disclosing it (on the back of our engagement and recommendation), they will be publicly disclosing severance pay for NEOs (not just CEO). Questions around TSR – we view share ownership as better for alignment than using TSR as a performance parameter. In the future, when company announces a new Director, they will immediately state independence “status” to ISS/Glass Lewis (on the back of our feedback), we discussed the Finnish practice of bundling all directors together in the proxy votes. They will see if this could be changed going forward.

          Collaborative engagement with Impax's two investment partners, US testing company focus on establishing more robust sustainability processes and reporting.

Objective is to understand the company's human rights and clinical trial policies and processes and to generally encourage improvement of company's ESG policies, practices and disclosures.


Letter to company IR (written and signed by the three asset management firms) detailing who we are, why ESG policies, processes and disclosures are important to investors and why they are beneficial for companies to develop. The letter was followed by a conference call with the company IR.


Positive call, which was followed-up with an email detailing which peer companies have strong sustainability reporting and also detailing concrete next steps for company to develop KPIs and sustainability reporting. Follow-up call is scheduled.

          Collaborative investor engagement, driven and coordinated by an NGO. Letters followed by individual company meetings regarding the sustainability of global food companies' product portfolios.

Research by Chatham House and others has indicated that it will not be possible to limit temperature rises to 2°C – the goal agreed at the UN Climate Change Conference, COP21, in 2015 – if livestock production and consumption are not addressed, posing regulatory risk to the industry. Further to this, the wider-ranging sustainability impacts of the increased demand for animal products seen over the last 50 years could prove costly, with a recent University of Oxford study suggesting that if unaddressed, public health and environmental costs could be up to $1.6 trillion globally by 2050. The collective impact and possible accumulation of these factors creates supply chains that are inherently more susceptible to disruption. FAIRR is coordinating a collaborative engagement opportunity to call on companies to think strategically about building sustainable protein supply chains, diversifying their protein ranges and mitigating the various risks associated with future supply chain disruption.

Objective is to initiate long-term company dialogues on this important topic.


Letters outlining the sustainability challenges and possible opportunities and sent to 10 global food producers and retailers, by 40 investors, coordinated by FAIRR, followed by calls / meetings.


Impax participated in two company engagement meetings on this topic (two UK food retailers). Very positive and interesting dialogues, however these are long-term issues, which will require follow-on discussions over the next few years. But importantly the first discussions on this topic have been established and food companies have been made aware that investors are focusing on these issues.   

          Board diversity, governance, Japanese companies

Since Japan established the Corporate Governance Code in July 2015, we have seen slow, but steady improvement of independence of Japanese boards. However, the majority of companies have no female representation either at boards or at the top management levels.

The objective of this engagement was to initiate discussions about this, find out about and suggest policies and processes that are supportive for establishing more diverse management teams and boards. 


Letters to four Japanese companies, (written and signed by the three collaborating asset management firms) detailing who we are, why diversity is important to investors and why it is beneficial for companies. The letter proposed a conference call for an initial discussion.


It has been relatively difficult to reach and organise calls. We have had initial calls with two companies. While no concrete outcomes can be pointed to yet, the companies were quite interested in these issues and the first seeds have been sown in developing this. We will be following-up with the companies in the next 12 months on this topic.

          US buildings energy efficiency company. Engagement regarding entrenched board and under-developed sustainability processes and reporting.

Objective is to discuss: 1. company plans to declassify board (only 17% of S&P 500 companies have classified boards today), 2. the board average tenure is >12 years (board entrenchment) and 3. company's lack of robust sustainability processes and disclosures.


Email to company CFO to outline the objectives we would like to discuss. Email was followed by an initial conference call with the company CFO.


Company has currently no plans to declassify the board and long tenures of directors are managed through continuous training and education. However, the CFO said they are working on developing environmental and social policies, processes and disclosures. We discussed the importance of focusing on material issues and Impax will be sending our framework of "cost-effective and material" sustainability processes and reporting to assist company in this process. Impax is also to send names of peer companies that have good HSE processes and disclosures in place. Very encouraging call, with tangible next steps for improvements in the company HSE processes.

          Due diligence and monitoring engagement, update on ESG issues for US water infrastructure company.

Objective is to discuss the upcoming AGM-agenda, governance and sustainability changes and issues at the company.


Conference call with company General Counsel, Chair of Nominations Committee, Head of Sustainability and Head of External Engagements


Discussion about plans for management compensation in the 2017 AGM, no major changes. On the back of Impax' engagement in 2016, the company has established a double-trigger process for severance payments (from single-trigger). Company has established GHG reduction targets, Impax suggested for company to develop scientific GHG targets as well. We mentioned that it would be very useful to have impact data (water saved or GHG avoidance) through the company products and services. Company is trying to measure this, but difficult with many different end-markets and applications of their products. Company is declassifying its board from 2018 and are looking to improve gender diversity of the board. They also asked us to consider the following questions: 1. shareholder right to amend bylaws and 2. our view of level of over-boarding for directors, which we will follow-up on.

          Water risk engagement, water intense companies.

We have established which companies are most exposed to water (water intensity, consumption or withdrawals) in our investable universe. We are conducting engagements to understand the localised or facility-based water stress risks for the companies and encouraging them improve disclosure around local water risks. We have also asked companies about the use of shadow water pricing to reflect local water scarcity and risk. Questions also about water management and reduction targets.


Emails to water intense companies in our investable universe (food, water utility, industrial gases companies), followed by conference calls.


These engagements are still on-going, but the general observations are that water intense companies have quite rapidly improved their internal processes for measuring, quantifying and managing water risks, (and using tools such as Aquaduct for this) but reporting about this is lagging behind, we will be following-up on this. Companies are not using shadow pricing, but some were considering it.

15.2. 補足情報。

Impax's focus areas of Engagement for 2016/2017:

Entrenched Boards

  • Boards with average tenures of >10 years and no new directors in the last five years
  • Companies with entrenched boards often lack sustainability processes
  • Focus on US companies

Board diversity

  • Boards lacking diversity regarding gender and/or competencies
  • Focus on Japanese companies

Water risk management (most material sub-sectors)

  • Understanding water risk exposures at local or basin-level, water performance
  • Focus on companies in the water utilities and food sub-sectors
  • Sustainability processes, small companies
  • Providing companies with guidance to develop sustainability processes and reporting
  • Focus on smaller US companies

Sustainability processes, small companies

  • Providing companies with guidance to develop sustainability processes and reporting
  • Focus on smaller US companies



LEA 16. Disclosure of approach to ESG engagements

16.1. 貴社がエンゲージメントに関する情報を積極的に開示しているかどうかを記載してください。


16.2. 一般に開示されている情報が、顧客や受益者に開示されている情報と同じであるかどうかを記載してください。

16.3. 貴社が一般に積極的に開示しているエンゲージメントに関する情報の種類を記載してください。


16.4. エンゲージメントの情報を開示する頻度について記載してください。

16.8. 補足情報。[任意]

We are developing more detailed engagement reporting, which will be disclosed publically later in 2016.