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The Scott Trust Limited (Guardian Media Group)

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

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

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

other (1) description

          The values of GMG itself have been key in developing an RI policy that reflects these principles. Additionally, our investment consultant advises on above norms.

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

Investment Policy Statement ("IPS"): this is the key investment policy document covering investment policy and specifically details Responsible Investment Policy.

Statement of Investment Principles ("SIP"): this document further guides our approach to responsible investing and is shared with all of our external investment managers. This was updated significantly in 2015 following two major responsible investment initatives by GMG:

1. Becoming a Signatory of the UN PRI.

2. Making the decision to divest from fossil fuels over the medium term.


Additional information on these key policy elements is given below:


Investment Policy Statement ("IPS")

This details GMG's overall investment policy, including Responsible Investing. This is a strategic document setting out the framework for all aspects of investment policy including responsible investment. This states that GMG is aware of the wider responsibilities of business and believes that companies should seek to act in an ethical manner. GMG recognises the financial materiality of Environmental, Social and Governance (ESG) issues for companies and the market.


The IPS states that GMG's Investment Committee has the responsibility to oversee our initiatives with respect to socially responsible investing and monitor our progress as a signatory to the Principles for Responsible Investment. They will review annually the progress made in respect of ESG integration and implementation of responsible investing, as reflected in the annual RI Transparency and Assessment Report


The IPS further states that GMG will make a special effort to include socially responsible, sustainable, and/or responsible investment strategies (collectively "SRI" strategies) that are more consistent with the organization's principles. The Investment Committee will seek to include SRI managers in manager searches when institutional quality options are known and available. We will favour such managers assuming they demonstrate reasonably comparable investment characteristics (i.e., competitive performance, fees, team stability, etc.) relative to their non-SRI peers. However, the Investment Committee will not restrict itself solely to SRI options since A) such options may not be available in all asset classes of interest to the portfolio and/or B) available options may be notably less compelling relative to non-SRI alternatives. In addition, best efforts will be made to participate in active ownership strategies, such as shareholder engagement initiatives, within the equity portfolio.


Statement of Investment Principles ("SIP")

This was adopted in 2008 and is updated on an ongoing basis. This guides GMG's overall approach to responsible investing and is shared with all investment managers on appointment to ensure alignment of the investment portfolio with the sustainability focus. We encourage all of the underlying managers in the fund to be mindful of their reporting of ESG and to collaborate with us where possible to improve the level and quality of disclosure.


The SIP states that the companies in which the fund invests should seek to act and behave in an ethical and responsible manner and follow similar values to those of the Group itself. GMG believes long term sustainability must be at the heart of the investment approach in order to be consistent with the Group's values, create long-term returns and meet the expectations of our readers.


As a consequence, while taking due regard of the fund's primary duty of generating strong risk adjusted-returns, GMG believes that working to incorporate environmental, social and governance issues into investment analysis and decision-making processes is important. GMG also believes that the incorporation of these issues in analysis may positively impact financial returns over the long term.


The SIP was also updated in 2015 to reflect GMG becoming a PRI signatory and agreeing to incorporate the six core principles of the PRI into its investment analysis and decision-making processes. GMG believes that application of the principles improves alignment of the investment portfolio with its overall mission and with the broader objectives of society.


The SIP was also updated following the significant public announcement in April 2015 of GMG's intention to divest from fossil fuels over the medium term and to invest proactively in strategies which are aimed at supporting the possibility of a lower carbon future.


This decision is based on two principles - a belief this it is incumbent on us all to protect the environment for future generations; and concern that carbon reserves may become stranded as policymakers take a more proactive stance against climate change.


Application of Responsible Investment in the Portfolio

These policies are applied to the investment fund in five key pillars:

  • UN PRI – proactively pursue commitments under UN PRI. We reported one year early, for the voluntary 2016 period after becoming a signatory, and sought feedback from UN PRI.
  • Engagement – we will engage with our investment managers on all aspects responsible investment. We aim to improve behaviour in the investment industry, disclosure and the provision of new sustainable and responsible investment products. We are also developing a direct policy, in order to engage with portfolio companies directly. During the period, we joined both ShareAction’s Charities Responsible Investment Network (CRIN) and the Institutional Investors Group on Climate Change (IIGCC). Both of these collaborative groups will be used for direct engagement. GMG also dedicated new staff resources during the period for engagement.
  • ESG integration – we aim to invest in managers taking a proactive approach to integrating ESG in  a material way in their investment process. Substantial re-allocations were made during the period to managers with a clear focus here. To emphasise this commitment, this was made a distinct new policy pillar during the period. Agreed commitments will bring the portion of the total fund judged to be particularly proactive on ESG to over a third.
  • Divestment – our investment fund has pledged to divest from fossil fuels over the medium term
  • Proactive Investments – we are seeking to invest in solutions to a sustainable and low carbon economy. A new commitment to a private equity fund developing renewable power generation in emerging markets

SG 02. Publicly available RI policy or guidance documents

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

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.


02.4. Additional information [Optional].

The above link to the investments part of our website contains an additional link to a copy of our Statement of Investment Principles, which sets out our overall approach and investment principles. It also explains the decision to divest and proactively invest in a lower carbon future.

SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Our internal investment policies cover conflicts of interest and require the GMG Board, Investment Committee members and relevant staff members to disclose any real or perceived conflicts of interest that may exist in connection with their responsibilities. Individuals affected are required to abstain from decisions relating to such matters.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)