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Impax Asset Management

PRI reporting framework 2017

Export Public Responses

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

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01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類、対象を示してください。

          Governance policy for Chinese companies

01.4. 組織の責任投資アプローチをカバーする投資ポリシーの策定時に使用した基準を明示してください。

other (1) description

          Conventions on Cluster Munitions and Land Mines

01.6. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。 [任意]

The ESG policy contains the following elements:

  • Overall approach, integrating ESG in the investment process
  • Rationale for integrating ESG

Main tools and processes for ESG integration:

  1. Normative Screen, UN Global Compact (quarterly screens)
  2. Impax Proprietary ESG-analysis (annual reviews)
  3. China / Hong Kong Governance-analysis (annual reviews)
  4. Controversial business activity screen, 3rd party (incl. controversial weapons)

Integrating ESG in the investment process, the materiality framework:

  • Governance (country-based KPIs)
  • Environmental Social (sector-based, most material KPIs)
  • Controversies
  • Proprietary ESG scores (Excellent, Good, Average, Fair and Excluded)

Active Stewardship:

  • Engagement as part of the investment process
  • Proxy voting as part of the investment process
  • Impax RI Memberships (platforms for RI dialogue and active stewardship)

SG 02. Publicly available RI policy or guidance documents

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02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。




Other, specify (1) description

          Impax's detailed Stewardship Statement
Positive environmental screening is an important aspect of our investments, document outlining our approach

02.4. 補足情報。 [任意]

Our overall ESG-policy and Stewardship statement cover the areas of environmental, social and governance factors, as well as the screening policy. These have not been attached / uploaded separately.

SG 03. Conflicts of interest

03.1. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

Our aim is to treat all our clients fairly at all times. Impax has a clear policy on identifying, recording, managing and disclosing any conflicts as necessary.

Impax arranges its business to minimise the potential for conflicts of interest and where they do arise it manages such conflicts to ensure that its own interests are never put ahead of those of its clients, and that one group of clients is not treated more favourably than another.

Conflicts of interest may arise as part of our investment, ESG and stewardship activities; however, we have arrangements in place to minimise their effects and to treat all clients fairly in relation to:

  • Varying client objectives and interests
  • Impax’s shareholder interests
  • Impax’s specific client interests
  • Impax’s employee interests
  • Impax’s corporate investments and interests
  • Impax’s inter-departmental interests

We have a Conflicts of Interest policy. The policy applies to all staff.

The Board of Impax Management Group plc has overall responsibility for ensuring the proper control over conflicts of interest. On a day to day basis, this responsibility is delegated to the Executive Committee, and is monitored by the Compliance department.


03.3. 補足情報。 [任意]

Possible sources of conflicts of interest and how they are addressed:

Varying client objectives and interests. Different clients may have different expectations, objectives and priorities regarding stewardship and Impax has a number of investors who are highly focused on stewardship issues and have very specific priorities. At the very outset of the client relationship it is determined how closely the stewardship priorities are aligned between the client and Impax. We have a number of clients who have retained their voting rights, in order to follow their specific stewardship objectives. For all other clients, we vote following our voting policies, utilising our ESG-analysis and knowledge of the companies in question and local and regional corporate governance best practice. We report the outcomes of our voting on our website, every quarter. Some of our clients have invested with us through separate accounts where their own specific responsible investment objectives are followed and expressed. We are not involved in stock lending, simplifying the management of proxy voting and reducing possible conflicts of interest relating to voting.

Impax’s shareholder interests. Impax is owned by individuals and financial institutions which each have their own investment, financial and stewardship objectives, which could create conflicts of interest. Impax’s investment process and stewardship activities are conducted following set and publicly disclosed policies and removed from the influence of shareholders.

Impax’s specific client interests. Impax could be managing investments for e.g. the corporate pension fund of a company that is also owned in one or several of Impax’s funds, which could create conflicts of interest. Impax’s investment process and stewardship activities are conducted following set and publicly disclosed policies and removed from any influence of specific clients.

Impax’s employee interests. An Impax employee could own shares or have an interest in a company that is also owned in one or several of Impax’s funds, which could create conflicts of interest. Impax has strict checks, controls and reporting regarding trading and ownership of companies and shares by the Impax staff. Impax’s investment process and stewardship activities are conducted following set policies and removed from any influence of any employee interests.

Impax’s corporate investments and interests. Impax does not hold any proprietary positons or conduct any proprietary trading, but may make a seed investment into a new Impax fund. When this is the case the fund and the investment is treated like any other client and is subject to the very same policies and procedures regarding stewardship that any other client funds would be.

Impax’s inter-departmental interests. The Impax investing departments outside of the Listed Equity business, such as its Private Equity department, may have ownership or an interest in a company that is an investee company in an Impax Listed Equities fund. There are formal Information Barrier structures in place between the Impax Listed and Private Equity departments and Impax’s investment process and stewardship activities are conducted following set policies and removed from any influence of any inter-departmental interests.

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、ポートフォリオ対象企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

          Impax’ investment team, its lead analysts and portfolio managers, are continuously monitoring our investee companies regarding their on-going performance and developments. We continuously assess how our companies are impacted by internal and external factors and events and the effects these have on the company’s value and risks. Company developments are discussed in the investment team every day during our Morning Meeting, as well as during the weekly Portfolio Review Meeting (PRM) for our strategies. We use a proprietary risk management tool to highlight and alert the investment team regarding changes to investee companies’ risks, financials and value. The investment team meets or is in contact with our investee companies several times a year, follows closely the companies’ results announcements and investor conference calls. 

We use sell-side research to monitor and review our companies. We also continuously monitor our investee companies from an environmental, social and governance (ESG) perspective; we receive alerts regarding controversies in our companies from our external research providers. We subscribe to environmental, social and governance research by ISS, MSCI ESG Manager and Sustainalytics. These and other tools provide us with information from different perspectives on our investee companies regarding their financial, operational, strategic, sustainability and governance developments and highlight possible areas of concerns and priorities for engagement. We review and update our ESG-analysis of our companies every 12 months and more often in case of major developments or incidents. 

As part of our ESG analysis and voting, we assess and ensure that our investee companies adhere to the relevant Governance Codes. Departures from compliance to Governance Codes or best practice are clarified and noted in our ESG analysis. Departures from Code and/or governance best practice that constitute material risks for the company are followed-up by engagement, unless the departure is purely temporary or fully understood or accepted by the investment team. The investment team regularly meets or speaks with members of the board of our investee companies to discuss company strategy, governance structures and often management remuneration. 

Our ESG analysis aims to establish the quality of an investee company’s reporting, transparency and disclosures. We view it as an important aspect to assess the disclosures of all our investee companies (annual reports, proxy materials and sustainability data) to get an understanding of how a company reports and discloses and the level of transparency. We therefore would not rely purely on external or 3rd party analysis or scores regarding companies’ reporting and processes, but view this as an important part of our company monitoring.

The Impax investment team does not routinely attend investee companies’ General Meetings or file shareholder resolutions, but rather engages on issues of concern directly with the company. However, the investment team can attend investee company General Meetings from time to time, where practicable and where deemed to be the most effective way of communication with the company.

Impax’s in-depth financial and ESG analysis endeavours to be forward-looking and anticipate potential issues that may lead to incidents or significant losses in investment value. The Impax quarterly thematic overlay is aimed at anticipating policy, macro-economic and industry-specific issues impacting our investee companies in the quarters ahead. Concerns are raised with the investee company management.

Impax has policies and procedures in place to ensure that we comply with applicable laws and that the interests of clients are protected in the event that investee companies provide us with either inside or material non-public information. Such events may include confidential pre-soundings or pre-marketing activities in advance of capital raisings and other corporate events in order to gauge interest in, or support for, a specific transaction. Where Impax deems it necessary, we will enter into active talks with these investee companies, which may preclude us from dealing in the shares of the company concerned. This is pre-cleared with our Compliance department to ensure our wall-crossing procedures are adhered to, the Stop List updated, and that we act in the best interest of our clients.

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.