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West Midlands Pension Fund

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

01.3. Indicate if the investment policy covers any of the following

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

01.5. Describe your organisation’s investment principles, and overall investment strategy, and how they consider ESG factors and real economy impact.

The Responsible Investment Framework defines the commitment of West Midlands Pension Fund  to responsible investment (RI). Its purpose is to detail the approach that Fund aims to follow in integrating environmental, social and governance (ESG) issues in its investments. It is considered supplementary to the Fund’s Statement of Investment Principles and thus in alignment with its fiduciary duty.

The Pensions Committee is at all times responsible for the Fund’s investments, including oversight of the RI strategy.  Responsibility for oversight of the Fund’s RI framework sits with the Strategic Director of Pensions and Assistant Director (Investments). Responsibility for the implementation of this framework sits with the RI Officer.  This policy applies to all members of the Pensions Committee and the Fund officers.  The Pensions Committee will review this policy at a minimum annually (in June of each year), or at such time as the Fund sees fit to revise its RI policies and procedures.

The RI Framework consists of the following sections:  the Fund's RI beliefs and guiding principles which drive its approach, what the Fund expects of itself, fund managers and companies with respect to ESG issues, and finally how RI is implemented in practical terms.

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]


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.

URL/Attachment

URL/Attachment

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

02.3. Indicate if your organisation’s investment principles, and overall investment strategy is publicly available

02.4. Additional information [Optional].

The Fund uses the Local Authority Pension Fund Forum (LAPFF) as its primary engagement partner and by extension endorses its engagement policies. The Fund's engagement policies are also set out in its Stewardship Code Compliance Statement. The Fund also engages through other partners including the PRI and the UK Pension Fund Roundtable. The Fund will engage directly where partnership-based engagement is inappropriate or is not available.

Please note that the Fund's primary investment strategy document - containing a summary version of the RI framework was, until 31/03/2017, the Statement of Investment Principles. From 01/04/2017, this will be replaced with an Investment Strategy Statement (also containing a summary version of the RI framework).


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.

The Fund maintains the following procedures for managing conflicts:-

  • Identification - Staff are provided with the Compliance Manual which sets out the types of conflicts that arise or may arise in their roles in addition to support from Compliance where there is any doubt whether there is a potential or actual conflict.
  • Recording – A Conflicts Register of all potential and actual conflicts is maintained by the Fund's compliance department ("Compliance").
  • Personal account dealing (PAD) – to prevent conflicts arising from information obtained by virtue of your employment, all staff are required to adhere to the rules on PAD.   More details are provided in OA 04.3 below.
  • Outside business interest - All staff are required to notify Compliance of, and seek approval for any outside business interest.
  • Gifts and entertainment – The Authority has implemented procedures to ensure that staff do not offer or provide gifts or entertainment to employees of any other company or person in an existing or potential business relationship, without the specific authorisation of the Strategic Director of Pensions.
  • Training

03.3. Additional information. [Optional]

Personal account dealing - excerpt of Compliance policy

Employees and connected persons are required to forward a copy of all contract notes of transactions in which they have been involved to the Compliance & Risk Manager immediately they are in receipt of such note. Employees have the option of requesting that their broker automatically sends the Compliance and Risk Team contract notes of transactions in which they have been involved.

In addition, neither the employee nor connected persons may deal on their own behalf ahead of a transaction in the same stock to be undertaken on behalf of the Fund (in other words, no "front running").

To support this, there should be no share dealing by individuals seven days before or after the Fund trades in the active global mandate, subject to exceptions (i.e. when the Fund trades quickly in response to a significant piece of news; in which case staff may legitimately have dealt in the same stocks within the previous seven days). Staff wishing to deal should check with the Active Global Equities Portfolio Manager, whether or not they can trade prior to doing so and if allowed, notify the Compliance and Risk Team.

The Compliance and Risk Team will check within the fourteen day window, all personal share dealings by staff against those of the Fund (taking into account those stocks which the Fund has traded on an exceptions basis). Additionally, the Fund will reconcile the contract notes of transactions against employees brought forward balance (i.e. statement of holdings) and their end of period position statement.

Generally, employees and connected persons must not deal in a security where they are in possession of non-public price sensitive information as defined by the Criminal Justice Act 1993. Employees should fully appraise themselves with the provisions of this Act.

When requested by the Compliance and Risk Team, the Fund requires employees to disclose their PAD and that of their connected persons.

 


SG 04. Identifying incidents occurring within portfolios (Private)


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