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Dana Investment Advisors

PRI reporting framework 2018

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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

01.3a CC. Describe how your products or investment strategy might be affected by the transition to a lower-carbon economy.

Dana's investment process includes quantitative metrics on carbon intensity and footprint for equities and corporate bond strategies. Our strategies have significantly less carbon intensive positioning versus their benchmarks. Fundamental analysis deepens our understanding of individual company carbon paths. Our research efforts are across sectors. In other words, we are not simply focused on one sector (i.e. energy or fossil fuels), but believe this is relevant across all sectors and supply chains. In addition, we use quantitative information as a starting point and follow up with fundamental research to derive a greater understanding of the materiality of the issues, approach to target setting, reliance on other factors to achieve targets and more.  We believe an underweighted exposure over time positions our clients well as we transition to a low-carbon economy. 

01.3b CC. Describe how climate-related risks and opportunities are factored into your investment strategies or products.

As noted above, we factor climate-related risks such as carbon emissions via quantitative metrics and fundamental analysis. This includes exposure and resilience with respect to natural disasters and natural resource constraints such as water.

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

We believe that Environmental, Social and Governance factors contribute to alpha generation and risk reduction. Thus researching, evaluating and advocating for transparent and sustainable practices simply make good business sense. While good policies at a senior management and Board level are clearly desirable, we favor quantitative metrics and targets wherever possible. We value and support the focus on "materiality" when discussing any particular company's ESG ranking and peer comparisons.

In the wake of ever-evolving technological advancements, shifting cost curves and changing demographics, our fundamental analysis focuses on identifying disruptive innovations, repercussions on incumbents and changes in relative valuations. We believe that there are critical systemic risks that warrant our focused attention. Water scarcity, quality and resilience are examples. We support efforts and product designs that move toward a more circular economy. Social issues include gender diversity, including Board representation and managerial roles, and labor relations, particularly related to health and safety. Governance issues include policies, disclosures, incentive structures, political spending, and more. 

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]

ESG analysis has garnered greater acceptance and more "mainstreaming" as academic and practitioner studies have demonstrated added value on a variety of metrics. Our firm has seen this growth internally as well. After doubling our ESG integrated AUM in the prior two years, this year we signficantly expanded our ESG integration across Equity and Fixed Income Strategies. For example, our Large Cap Equity Strategy incorporates the ESG factor analysis and the majority of holdings overlap with our advocacy efforts for our designated Social ESG Strategies. Our Limited Volatility Fixed Income Strategy (a high credit, U.S. government and agency product) allocates to government-backed, AAA-rated securities which include Small Business Loans (SBAs) that often assist low income or minority owned businesses. These Strategies combined with our Social ESG Strategies represent the majority of our AUM. All Strategies incorporate Governance and we see an increase in the materiality and use of E & S factors as well.

We utilize proprietary quantitative financial and ESG models coupled with rigorous fundamental analysis to determine relative valuations for companies in our universe. Our ESG modeling is used as the basis for our Equity and Corporate Bond ESG integrated Strategies. 

Our Responsible Investment policy includes details on our positive factors, negative screening (where applicable), processes for integrating ESG analysis and active ownership efforts. Our firm's Responsible Investment Policy is on our website and includes our overall approach to investing that incorporates a quantitative and fundamental analysis of ESG issues and our view that this is becoming more material and more mainstream. Our proxy guidelines that encompass the majority of equity AUM are on our website as is our engagement policy.

One variation of note is our Catholic Equity and Fixed Income ESG Strategies. These Strategies integrate ESG factors as described above and also adhere to the United State Conference of Catholic Bishops (USCCB) guidelines.

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].

Note: Please see Dana website:, "Our Services" for access to Equity and Bond Strategy books; only one book is linked above, as an example. More information is public this year, including engagement policy, more detailed proxy guidelines and advocacy examples.

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.

Dana takes seriously its responsibilities in identifying and disclosing potential conflicts of interest regarding the investment management of client accounts. Each stage of the investment management process may potentially involve a conflict. Dana seeks to proactively eliminate those conflicts that are associated with managing client accounts. For any conflicts that cannot be effectively eliminated, Dana provides adequate disclosure in several documents that are either delivered to clients or made available upon request. On an annual basis, all Dana employees complete and sign a Conflicts of Interest disclosure statement which identifies any new or changed conflict that might exist. Disclosure is made in four key documents: Form ADV Part II (or ADV Brochure alternative), Proxy Voting Policies and Procedures, Privacy Statement(s), and Dana’s Code of Ethics. Dana holds a mandatory Annual Compliance Training meeting and requires employee certification with Dana’s Code of Ethics. The Code of Ethics includes a personal trading policy. Client account trading follows a 2-level trade rotation that ensures trades are executed in an equitable manner.

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

          Incidents may be identified by our data vendors (i.e. MSCI, Trucost, Bloomberg, Sustainalytics) whose metrics are incorporated in a quantitative model which Portfolio Managers and Analysts routinely review. In addition, our Portfolio Management team communicates daily about events and news impacting portfolio holdings and share research related to incidents. Clients occasionally identify issues as well. If a consequential issue arises with an existing portfolio company, we typically sell the position and purchase a more suitable position.