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Janus Capital Management LLC

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.

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.

02.4. Additional information [Optional].

Janus Capital Management LLC

ESG Policy



Janus Capital Management is a fundamental investment manager with an intensive, bottom-up investment process, focused on maximizing long-term returns while minimizing risk. We understand Environmental, Social and Governance (ESG) factors as critical externalities which impact the long-term viability and value of a business. Many of these factors elevate the importance of proper corporate governance and mark the difference between management teams who are willing to think long-term and those more interested in short-term profit optimization at the expense of the future viability of the business.


At Janus, we practice a bottom-up approach to research which seeks to deeply understand both the company and the ecosystem within which they operate. In addition to rigorous modeling and competitive analysis, we consider externalities such as ESG as a significant part of our research process. Often times, environmental, social or governance concerns uncovered by our research serves to remove a company from investment consideration.



We are long-term, fundamental investors and we actively seek out long-term oriented management teams. Our intensive research takes our analysts and PMs around the globe, where we conduct thousands of company visits / management interviews on an annual basis. Our investment team naturally develops long-term relationships with company management teams.  As we identify ESG concerns in companies, we leverage our constructive relationships with management teams to address these concerns.



While our bottom-up research process uncovers many ESG issues, Janus has established a Responsible Investment Officer to oversee and coordinate: the dissemination of ESG issues, ongoing ESG education, ESG documentation and ESG-related proxy voting. The primary responsibility for fundamental research (including ESG analysis) lies with the analysts; however, our Responsible Investment Officer helps to focus the conversation, and keep relevant/material issues front and center. In addition, we use outside services to monitor company-specific and general ESG issues and alert our analysts.


Proxy Voting

At Janus, our first priority is to act as a fiduciary in the best financial interests of our clients.  Strong ownership practices, such as proxy voting, can help protect and enhance long-term shareholder value.  Janus recognizes that environmental, social and governance issues present risks and opportunities that can have a material impact on the value of an investment.  We analyze and vote all ESG proposals in what we believe to be in the best, long-term economic interest of shareholders.

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 Conflicts of Interest (COI) policy document is fourteen pages; however, the most applicable portions are included below:

Broadly defined, a “conflict of interest” exists when two or more activities or relationships are incompatible to some extent. A conflict situation can arise when employees take actions or have interests that may make it difficult to perform their Janus work objectively or effectively. In general, Janus employees are advised to avoid any direct or indirect business connection with Janus’ customers, clients, suppliers and competitors, except on behalf of Janus.

Our COI policy addresses these, among other issues:

-  Control and Mitigation

-  Identification and Monitoring

-  Education and Training of Employees

-  Employee Guiding Principles - Conflicts of Interest


Potential conflicts of interest that require disclosure include, but are not limited, to the following:

-  Outside Employment or Material Business Relationships

-  Outside Directorship

-  Self-Dealing

-  Gifts and Entertainment

-  Personal Trading

-  Political Activity

-  Purchasing and Service Provider Selection

-  Family or other personal relationships, which might dissuade an employee from acting in the best interests of Janus and the Janus shareholders.

-  Any other arrangement or circumstance.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)