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Wells Fargo Asset Management

PRI reporting framework 2018

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

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

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

Wells Capital Management (WellsCap) brings together a strategic balance of investment capabilities to serve the investment needs of our clients worldwide. WellsCapunderstands ESG issues are important considerations among many that should be incorporated by our investment teams within their evaluation and decision-making processes. We believe that ESG issues can have an impact on financial performance and that a better understanding of ESG factors can help protect against downside risk and contribute to long term risk-adjusted returns. As such, WellsCap integrates material ESG considerations into our research, which is foundational to all of our actively managed investment strategies.

We believe understanding the potential impact arising from ESG issues is an essential step to better understanding investment outcomes in a rapidly changing world. Changing consumer preferences, increasing costs from externalities (such as resource use or climate change), and the emerging regulations addressing these issues are increasingly changing behavior of the markets we operate in. By considering ESG as an important element of investment performance, we are able to consider a broad range of relevant risk factors and generate returns as the market increasingly reacts, while aligning our investment outlook and strategies to the new norms of a changing world.

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

WellsCap is committed to the following principles that underlie our investment beliefs regarding ESG:

  1. Strategic client relationships: Through a client-centric approach, we initiate conversations with our clients to better understand their needs and then seek to achieve alignment with their ESG objectives through the development of appropriate investment strategies.
  2. Independent investment teams: We believe that an organization of independent and specialized investment teams is the optimal structure to achieve consistent outperformance and risk-adjusted returns. Our portfolio management and research teams integrate ESG considerations into their analyses and decision-making processes where they believe these issues may affect the success of an investment.
  3. Independent risk management: As active managers, we believe that companies that perform poorly on ESG demonstrate higher downside risk that is unrewarded in achieving long-term risk adjusted returns. To empower our investment teams, we incorporate ESG research and analysis into our independent risk management functions, providing proprietary tools and services that help investment managers better understand the ESG risk profiles of investments.
  4. Active ownership: As signatories to the Principles for Responsible Investment and the Japan Stewardship Code, we take our role as active owners seriously.  The relationship we have with our investments doesn't end once we invest; to ensure the sustainable growth of our investments, we vote our proxies and engage in dialogue on ESG issues, encouraging best practices across our portfolios – and helping us deliver superior long-term risk adjusted returns. 

Ultimately, considering ESG in our investment strategies contributes to our number one priority: generating positive investment outcomes for our clients.

How WellsCap approaches ESG

We believe ESG investing is investing in a better future.

Our primary focus is on generating positive outcomes for our clients. For us, strong ESG practices can be seen as good business practices; we believe that by integrating ESG approaches with clients’ unique values we can improve investment outcomes for a better future, together.

In terms of different ESG investment approaches, we identity investor motivations and align our approach to address them. Underpinning our ESG investment approaches are two foundational commitments:  Stewardship and ESG Risk Management.

  • Stewardship refers to our commitment to impel investee companies through activities such as engagement and proxy voting in making positive changes on ESG issues to promote long-term value creation.
  • ESG Risk Management is part of our firm-wide risk platform, Portfolio Risk Management and Analytics (PRMA) overseen by the Office of the CIO. This dedicated team and function provides proprietary tools to identify the most significant risks relate to ESG issues across all strategies and at the firm aggregate level.


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.


02.2. 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].

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.

WellsCap has developed policies and procedures designed to manage and mitigate the risks of potential or perceived conflicts of interests that may arise. As a registered investment adviser, WellsCap has fiduciary responsibilities to act in the best interests of its clients. Such duties include: reasonable and independent basis for its investment advice, seeking best execution for clients’ securities transactions, ensuring that the investment advice is suitable to the client’s objectives and refraining from engaging in personal securities transactions inconsistent with client interests. To minimize any potential conflicts, WellsCap manages its advisory services, fee structure, and investment selection process in accordance with pre-established client investment guidelines, the client advisory contract, and all applicable policies and procedures pursuant to Rule 206(4)-7 of the Advisers Act. WellsCap has a fiduciary responsibility to manage all client accounts in a fair and equitable manner. It seeks to provide best execution of all securities transactions and aggregate and allocate securities to client accounts in a fair and timely manner. In addition, WellsCap has adopted policies limiting the circumstances under which cross-trades may be affected between the portfolio and another client account. Further, WellsCap discloses all identified potential conflicts of interest within its ADV Part 2A.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)