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RBC Global 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

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.

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]

Integrating ESG

We believe that the proper disclosure and consideration of ESG risks and opportunities by the companies or countries in which we are invested will enhance the long term, sustainable performance of those investments. Accordingly, we seek to integrate ESG factors into our investment process when doing so may have a material impact on our investment risk or return. As a general rule, we will not exclude any particular investment or industry based on ESG factors alone. We believe it is important to consider those factors within our overall investment process rather than unduly narrowing the universe of potential investments.

Specialist Socially Responsible Investment Solutions

We offer our clients a number of socially responsible investment funds (SRI Funds) which do exclude some investments based on ESG factors. Those funds integrate social values into the investment process by screening potential investments based on their ESG policies and practices or the industries in which they operate.  In 2016 RBC GAM made available a global equity fossil free fund in Canada and the U.S..  We also offer our institutional clients the ability to create a custom ESG screen for their segregated portfolios.


Engaging with management or directors of the companies in which we are invested is another tool we use to maximize our investment returns and lower our risk. Portfolio managers and analysts meet with the companies in which they invest on an ongoing basis and often discuss risks and opportunities relating to ESG factors. We engage more specifically with companies on ESG-related issues when those issues have been identified as particularly material for that company. Our ESG-focused engagements are chosen and prioritized using a risk-based approach, focusing on the materiality of the ESG risks and opportunities facing each company and the size of our investment in it. In general, the goal of our engagement program is to effectively communicate our views as an investor. Engagement also allows us to better understand our investee companies, their governance structures and their approach to ESG issues generally, which will better inform our voting and investment decisions. 

Proxy Voting

Proxy voting is a key part of our engagement process as it provides an important way for us to convey our views to boards and management. Voting responsibly is part of our fiduciary duty and we make our voting decisions independently, and in accordance with our custom Proxy Voting Guidelines. Those voting guidelines provide an overview of the corporate governance principles we support and how we will vote on ESG-related issues.


We believe that transparency and accountability is as important for institutional investors as it is for the companies in which we are invested. We provide our clients with regular reporting of our voting and stewardship activities and we publish semi-annual Corporate Governance & Responsible Investment reports to more fully describe our activities as a responsible and engaged shareholder.

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].

BlueBay has its own RI policies that are detailed in its PRI Transparency Report.

Please note that our screened funds referenced in the screening/exclusions policy are only available in Canada with the exception of the fossil free strategy which is available only in Canada and the U.S.. 

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.

RBC GAM has a fiduciary duty to act in the best interests of our clients and to have robust policies and procedures reasonably designed to prevent or manage conflicts of interest. Our conflict of interest policies establish the standards required to be followed by RBC GAM to ensure compliance with all applicable securities laws and regulations of the jurisdictions in which we operate.

Our conflict of interest policies cover all potential conflicts that may arise, including conflicts relating to the bank-owned structure of RBC GAM, personal trading, payments, gifts and entertainment, external directorships/outside activities, proxy voting and engagement. Our policies recognize that a conflict of interest arises when the interests of an individual or the firm are inconsistent with the interests of a client, including an investment fund unitholder, or when there is a conflict between the interests of our clients. We consider conflicts of interest to include actual conflicts, potential conflicts where there is a reasonable probability that an actual conflict will arise, and perceived conflicts where the perceived conflict could cause reputational damage to RBC GAM.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within portfolio companies.

04.2. Describe your process on managing incidents

          We receive notification from a number of sources regarding incidents at companies held in the portfolios we manage. For example, we have access to controversy indicators though our Sustainalytics and MSCI subscriptions which are incorporated into our monthly ESG snapshot reporting provided to portfolio managers. We also receive notices from ISS and Glass Lewis when there has been a significant governance-related event which is communicated to the portfolio managers who hold the relevant securities in their portfolios. In addition, controversies are part of the screening criteria for our SRI funds.