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Universities Superannuation Scheme - USS

PRI reporting framework 2018

Export Public Responses

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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


other (2) description

          SIP, Stewardship Code & Global Principles

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.

Note on SG01.2 - Application of policies:

Please note the application of the policies in SG01.2 varies dependent on the policy. E.g. The Screening and Exclusions Policy (USS's Ethical Policy) only applies to USS's Investment Builder ethical fund and ethical lifestyle options; and we do not have standalone environmental, social and governance guidelines for every individual asset class. However, USS's Statement of Investment Principles, and Investment Beliefs apply to the whole scheme.

With regards to the transition to a lower-carbon economy:

USS was among the first pension funds globally to recognise the potential implications of climate change for long-term investors.

In 2001 we published an industry leading discussion paper: Climate Change: a Risk Management Challenge for Institutional Investors. Later that year we co-founded the Institutional Investors Group on Climate Change (IIGCC), which provides a forum for European institutional investors to collectively engage with policymakers on the long-term risks and opportunities of climate change. The scheme made its first investment dedicated to renewables and clean tech in 2000.

In the years since, we have demonstrated our leadership on the issue of climate change by constantly advocating for it to be squarely on the agenda of institutional investors.

  • IIGCC: USS provided the first ever Chairman for the IIGC and continues to hold a position as advisor to the Board. The organisation has developed Global Climate Change Disclosure Frameworks setting out investor expectations of disclosure from companies in industry sectors (including automotive, oil and gas, and electricity).
  • CDP: We have been a signatory to CDP (formerly the Carbon Disclosure Project) since its first iteration in 2002. CDP offers a framework for companies to follow when providing key climate change data to their investors.

Climate change represents potentially significant risks for the assets in which we invest. The way in which our investee companies and assets manage these risks is therefore a key concern, in line with our responsibility to safeguard the fund for the long-term benefit of our members. We expect companies in which we invest to analyse climate change risks, both in terms of their carbon emissions and how they are adapting to a changing climate, and to develop mitigation plans.

There are three key areas in which we undertake activity on climate change:

  • Encouraging disclosure of carbon emissions and information on how companies/assets are managing climate risks.
  • Engaging with companies to encourage better management of climate risk. We regularly discuss climate change at meetings with companies, as part of our ongoing engagement.
  • Engaging with policy makers to ensure appropriate climate change policies are established to encourage the transition to a low carbon economy. Most of our engagement with policy makers on climate change is conducted through the Institutional Investors Group on Climate Change (IIGCC). Over the years, USS has met with policy makers from governments from across the EU, the European Commission itself, the UK government and also representatives from the Australian government and the Province of Alberta (the home of oil sands).

Further information on USS's activities and approach to climate change risk management is available at

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

Climate change represents potentially significant risks for the assets in which we invest.  These risks can be:

  • Physical – a changing climate may directly impact the viability of some assets or business models (for example, flood risk for real estate, or drought / fire risk for timberland assets);
  • Regulatory – where governments set in place polices to reduce emissions or encourage changes in technology in the shift to a lower carbon future.  This could lead to, for example, the stranding of coal assets; 
  • Reputationally – where members and beneficiaries express concerns regarding investments in certain sectors associated with fossil fuels.  

Such risks are addressed by fund managers in their analysis of potential  investments, and in their stewardship of assets.   


The scheme’s Investment Beliefs highlight a commitment to collaboration. They state "the fund's interests are further protected from adverse impacts by collaboration with like-minded investors and engagement with government, industry and regulators".

This belief and commitment to collaboration is reflected in the market-wide transformation work and collaborative initiatives outlined in USS's RI Strategy. It is exemplified in the activities undertaken by the Scheme each year, supported by the disclosures in our published PRI Transparency Reports, which include reporting on all voluntary and mandatory indicators, as well as our website which publicly shares USS's policies and approaches on RI.

See and 


Investment Beliefs 

The investment beliefs also discuss active management, internal resources, an illiquidity premium and "that investing responsibly and engaging as long term owners reduces risk over time and may positively impact fund returns".  All these factors have influenced the scheme's approach to responsible investment.

DC and Members' views

USS also has a "USS Default lifestyle option statement of investment principles" which acknowledges a large group of the USS membership has specific objectives around ethical investing. The scheme has developed ethical guidelines and offers Ethical Fund and Sharia Fund options for members investing in the USS Investment Builder defined contribution (DC) section of the scheme.


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

USS's Statement of Investment Principles and Investment Beliefs, which are available on the scheme's website, outline the framework for the consideration of ESG factors for the scheme:



The link to the real economy is discussed on our website under the 'Approach' page for Responsible Investment. The section highlights how the scheme encourages good corporate management of ESG issues, and seeks to ensure our assets contribute positively to our members' future. The section also highlights the concept of the "universal investor" explaining how scheme returns are ultimately tied to the real economy. See for more detail.

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]

In addition to the Statement of Investment Principles and Investment Beliefs (see , the following key documents govern responsible investment at USS:

  • USS Responsible Investment Strategy 
  • USS RI Approach
  • USS UK Voting Policy
  • USS UK Stewardship Code Statement  
  • USS Global Stewardship Principles
  • USS Governance Expectations for Hedge Funds
  • USS Responsible Property Investment Policy 
  • USS Responsible Property Investment Targets
  • USS Private Markets Enhanced Due Diligence

Additionally, the Scheme also developed Ethical Guidelines for use in the ethical fund options offered under the USS Investment Builder - the DC section of the scheme. USS Investment Builder also includes a USS Sharia Fund. For more details see: 

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.




Other, specify (1) description

          Statement of Investment Principles

Other, specify (2) description

          USS Private Markets Enhanced Due Diligence Process

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].

As well as the above documents and web pages, there are additional operational and implementation guidelines relating to RI that are applicable to different processes or mandates. Some documents are available on the web pages referred to in the questions e.g. the processes for fixed income and environmental performance targets for real estate. Other guidelines have not been published but may be referred to within the overarching approaches referenced in key governing documents for investment processes e.g. for stock lending recalls for voting.

RI considerations are also included within the public equity decision process documentation used by the in-house equities team. The bespoke template documents developed by USS Investment Management for internal record keeping for equity decisions include RI performance indicators and the scheme's investment "Tear Sheets" include the latest RI team perspectives, RI engagement meeting conclusions and voting records. Completed records are posted to a shared internal research hub (IRH) on Bloomberg for ready access by the equity and credit investment teams and RI team.

Policies and processes are also being enhanced to help deal with the increased appointment and monitoring requirements associated with a larger number of external public markets managers resulting from USS’s introduction of DC fund options. Prior to the launch of USS Investment Builder at the end of 2016, the scheme had few external public markets managers. The RI elements of the diligence and monitoring processes for such mandates are outlined in detail under the SAM section.

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.

As a beneficial owner with in-house fund management and RI capabilities serving only one client, USS does not face the range of potential conflicts of interest that commercial fund managers may need to address. This is publicly outlined in our Stewardship Code Statement - .

Further, USS has put in place policies and procedures to take all reasonable steps to identify, record, manage and disclose and conflicts of interest which do arise. All staff are required to act in accordance with the Conflicts of Interest and Confidentiality Policy, a copy of which is maintained by the Compliance Department.  USS Investment Management has a strong internal compliance function and is authorised and regulated by the FCA. All fund managers are expected to act in the best interest of the scheme, not their individual portfolios: this behaviour is reinforced by the fund's appraisal process and the bonus structure for USS Investment Management.


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

          For private markets and property assets, where we have control or sit on the Board, we will monitor incidents through board papers, discussions with management and/or appointed managers.

For listed equity portfolio companies, we have access to market information through broker reports, newswires and data providers. This includes a service provider which specifically highlights ESG incidents. Portfolio managers, the RI team and other executives from USS Investment Management will attend industry events and meetings with service providers or peer investors which may highlight concerns. We also meet directly with the company at both board and management levels, and with different executives within the c-suite. In addition, we have a separate process for monitoring our public equity holdings for human rights related issues.

We also meet with our external fund managers and GPs and are able to leverage information flows from these sources for our direct holdings.