Pengana engages an independent ESG researcher to conduct an annual review of companies newly introduced to the Fund portfolio since the last review. The basis for the evaluation is the ethical policy as summarised.
The outcome of the review is a report highlighting investments which may not be compliant with the ethical investment policy. The report is considered by the Investment Team and follow-up analysis of possible non-compliant investments may be undertaken.
Pengana has final discretion on whether or not to divest non-compliant investments. Where it is decided to divest, the asset is disposed as soon as practicable, as determined on a case-by-case basis, whilst endeavouring to realise the best price it reasonably can, taking into account liquidity and other market forces.
On occasion Pengana may choose to engage with an investee company rather than divest as a better way to effect change.