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Wellington Management Company LLP

PRI reporting framework 2018

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ESG incorporation in actively managed listed equities

Implementation processes

LEI 01. Percentage of each incorporation strategy

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate (1) which ESG incorporation strategy and/or combination of strategies you apply to your actively managed listed equities and (2) the breakdown of your actively managed listed equities by strategy or combination of strategies (+/- 5%)

ESG incorporation strategy (select all that apply)

Percentage of active listed equity to which the strategy is applied
87 %
Percentage of active listed equity to which the strategy is applied
12 %
Percentage of active listed equity to which the strategy is applied
1 %
Total actively managed listed equities 196%

01.2. Describe your organisation’s approach to incorporation and the reasons for choosing the particular ESG incorporation strategy/strategies.

At Wellington Management, we consider environmental, social, and corporate governance (ESG) criteria as one set of factors among many that should be weighed appropriately to inform investment decision making. We view ESG analysis and integration as both return enhancing and risk mitigating. To help our portfolio managers and investment teams better assess risks and opportunities in client portfolios, we have integrated the analysis of ESG factors into our investment and risk-management processes firmwide.

In addition to our ESG integration process, we serve as the investment manager of various screened investment portfolios, where we invest in, or exclude certain types of companies based on pre-agreed guidelines and criteria from the client. We also run a thematic strategy called Global Environmental Opportunities which is a global, diversified equity portfolio that invests in companies directly addressing environmental risks. In addition, we run a strategy called Global Impact which invests in a portfolio of rapidly growing companies whose innovations address some of the world’s most intractable social and environmental problems.

01.3. If assets are managed using a combination of ESG incorporation strategies, briefly describe how these combinations are used. [Optional]

Wellington Management sub-advises all three of Domini Impact Investment’s U.S. mutual fund offerings, two equity and one fixed income. The Domini Impact Bond Fund is a domestic, intermediate term fixed income fund, with a focus on community economic development. The objective is to create a fixed income vehicle aligned with the goals of seeking universal human dignity and environmental sustainability, while also achieving competitive financial returns. To that end, potential investments are screened by Domini for approval based on Domini’s own ESG criteria. While potential investments may be screened out due to negative factors, the approach also seeks to proactively invest in issuers that are having a positive impact on society.


LEI 02. Type of ESG information used in investment decision

02.1. Indicate what ESG information you use in your ESG incorporation strategies and who provides this information.

Type of ESG information

Indicate who provides this information  

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

Indicate who provides this information 

02.2. Provide a brief description of the ESG information used, highlighting any different sources of information across your ESG incorporation strategies.

Our ESG Research Team uses data from a number of different sources in order to evaluate companies’ level of disclosure and reporting on ESG indicators. As inputs to our approach, we use ESG research from Morgan Stanley, Credit Suisse, CLSA, Goldman Sachs Sustain, UBS, Bank of America Merrill Lynch, Société Générale, MSCI, Bloomberg, Oekom, ISS, Glass Lewis, Equilar, and FactSet amongst others. Data from select sources feeds a proprietary algorithm that we have developed in order to provide internal ESG ratings on about 7,000 companies. We are continually evaluating new data providers to improve the coverage and quality of inputs into our ESG analysis. These ratings and external research providers serve as a starting point for further research and engagement by the ESG Research team.

02.3. Indicate if you incentivise brokers to provide ESG research.

02.4. Describe how you incentivise brokers.

Wellington Management's investment personnel participate in a semi-annual research poll, which we use to help determine compensation of our brokers who provide ESG and other research.

02.5. Additional information.[Optional]


LEI 03. Information from engagement and/or voting used in investment decision-making

03.1. Indicate if your organisation has a process through which information derived from ESG engagement and/or (proxy) voting activities is made available for use in investment decision-making.

03.2. Additional information. [Optional]


(A) Implementation: Screening

LEI 04. Types of screening applied

04.1. Indicate and describe the type of screening you apply to your internally managed active listed equities.

Type of screening

Screened by

Description

In addition to our ESG integration process, we serve as the investment manager of various screened investment portfolios, where we invest in, or exclude certain types of companies based on pre-agreed guidelines and criteria from the client.

Screened by

Description

In addition to our ESG integration process, we serve as the investment manager of various screened investment portfolios, where we invest in, or exclude certain types of companies based on pre-agreed guidelines and criteria from the client.

04.2. Describe how the screening criteria are established, how often the criteria are reviewed and how you notify clients and/or beneficiaries when changes are made.

We serve as the investment manager of various screened investment portfolios, where we invest in, or exclude certain types of companies based on pre-agreed guidelines and criteria from the client.


LEI 05. Processes to ensure screening is based on robust analysis

05.1. Indicate which processes your organisation uses to ensure screening is based on robust analysis.

05.3. Indicate how frequently third party ESG ratings are updated for screening purposes.

05.5. Additional information. [Optional]


LEI 06. Processes to ensure fund criteria are not breached

06.1. Indicate which processes your organisation uses to ensure fund criteria are not breached

06.2. If breaches of fund screening criteria are identified - describe the process followed to correct those breaches.

Investment decisions, portfolio construction and related activities, including trading and trade reconciliation, are inherently complex processes. As a result, mistakes and imperfections occur, some of which cause losses in our clients’ portfolios. However, not all mistakes and imperfections are compensable errors. We generally consider something a compensable error when we determine that our actions did not meet the applicable standard of care for managing a client’s assets and that our client suffered a loss as a result. Our Error Resolution Council, a cross functional group of senior professionals, reviews the facts and circumstances underlying potential errors on a case-by-case basis in order to assess whether the events constitute a compensable error. In conducting the assessment, the Error Resolution Council often consults other relevant personnel, including the portfolio manager(s) for the client account and the client’s relationship manager.

If we determine that we have made an error in a client’s account, we will typically compensate the client for the direct monetary losses (if any) the error caused in the client’s account. Unless prohibited by applicable regulation or a specific agreement with the client, we net the client’s gains and losses from the error or a series of related errors with the same root cause and compensate the client for the net loss. We typically notify clients as soon as practical of any errors that violate client guidelines, or that result in a material loss in the client’s account. However, we generally do not notify clients about an event when we have determined that it does not constitute a compensable error.

06.3. Additional information.[Optional]

Our policies and procedures with respect to investment guidelines are defined in the firm’s Portfolio Guideline Monitoring Policy and Procedures. In its role as investment adviser or subadviser, the firm has responsibility for managing client portfolios in accordance with clients’ identified objectives, guidelines, and restrictions. We employ a variety of procedures and controls that are designed to assist investment professionals in complying with client guidelines. Primary responsibility for compliance with each client’s investment objectives and restrictions rests with the Portfolio Management Teams. We provide the Portfolio Management Teams with the appropriate professional support and infrastructure to ensure that they have the resources reasonably necessary to meet client guidelines.

Fidessa’s Sentinel contains the rules applied to each account that are tested by our compliance screening processes. Sentinel compliance screening can be performed on a pre-trade basis, in an overnight post-trade process, or both. Our proprietary investment and trading systems are linked to compliance screens, which enable most investment restrictions to be tested at the time an order is entered. Pre-trade overrides are reviewed throughout the day by Guideline Monitoring. Compliance tests are also applied to account holdings overnight, with results reviewed the next morning. Users throughout the firm have read-only access to the rules managed and maintained by Guideline Monitoring.

 


(B) Implementation: Thematic

LEI 07. Types of sustainability thematic funds/mandates

07.1. Indicate the type of sustainability thematic funds or mandates your organisation manages.

07.2. Describe your organisation’s processes relating to sustainability themed funds. [Optional]

While the mandate of our central ESG research team is to facilitate the integration of ESG factors across all portfolio management teams, there are more targeted ESG/impact portfolios as well, including the following examples:

  • Global Impact, a global equity portfolio that invests in innovative companies whose core business addresses the world’s major social and environmental challenges with a measurable impact. This is determined by Wellington’s proprietary bottom-up global fundamental research This strategy is focused on 10 impact themes, which can be summarized into three categories: life essentials, human empowerment, and environment.
  • Global Environment Opportunities: a global equity portfolio designed to help address carbon and sustainability under-investment in a targeted approach that delivers both environmental and financial returns on capital. This strategy is focused on four broad sustainability categories: low carbon electricity, energy efficiency, water and resource management, and low carbon transport.
  • Advancement of Women: a global equity portfolio designed to invest in high-quality companies that value the inclusion and promotion of women. As part of the fundamental research process, the investment team focuses on female representation at the board and senior management levels as a proxy for companies’ commitment to diversity.

The firm also serves as the investment manager of various screened investment equity and fixed income portfolios, where we invest in, or exclude, certain types of companies based on pre-agreed ESG guidelines and criteria from the client.

Wellington Management sub-advises all three of Domini Impact Investment’s U.S. mutual fund offerings, two equity and one fixed income. The Domini Impact Bond Fund is a domestic, intermediate term fixed income fund, with a focus on community economic development. The objective is to create a fixed income vehicle aligned with the goals of seeking universal human dignity and environmental sustainability, while also achieving competitive financial returns. To that end, potential investments are screened by Domini for approval based on Domini’s own ESG criteria. While potential investments may be screened out due to negative factors, the approach also seeks to proactively invest in issuers that are having a positive impact on society.


(C) Implementation: Integration of ESG issues

LEI 08. Review ESG issues while researching companies/sectors

08.1. Indicate which ESG factors you systematically research as part of your investment analysis and the proportion of actively managed listed equity portfolios that is impacted by this analysis.

ESG issues

Proportion impacted by analysis
Environmental

Environmental

Social

Social

Corporate Governance

Corporate Governance

08.2. Additional information. [Optional]


LEI 09. Processes to ensure integration is based on robust analysis

09.1. Indicate which processes your organisation uses to ensure ESG integration is based on a robust analysis.

09.2. Indicate the proportion of your actively managed listed equity portfolio that is subject to comprehensive ESG research as part your integration strategy.

09.3. Indicate how frequently third party ESG ratings that inform your ESG integration strategy are updated.

09.4. Indicate how frequently you review internal research that builds your ESG integration strategy.

09.5. Describe how ESG information is held and used by your portfolio managers.

09.6. Additional information.[Optional]


LEI 10. Aspects of analysis ESG information is integrated into

New selection options have been added to this indicator. Please review your prefilled responses carefully.

10.1. Indicate which aspects of investment analysis you integrate material ESG information into.

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

Proportion of actively managed listed equity exposed to investment analysis

10.2a. Indicate which methods are part of your process to integrate ESG information into fair value/fundamental analysis and/or portfolio construction.

10.3. Describe how you integrate ESG information into portfolio weighting.

Our ESG Research Team, part of central Investment Research, helps portfolio managers and analysts gather deeper intelligence on ESG topics and integrate these considerations into the investment process. We believe a holistic understanding of how companies deploy capital — financial, physical, and human — is helpful in framing an investment thesis, and examining ESG issues gives us a more complete picture. ESG analysts are responsible for conducting in-depth analysis of ESG factors most relevant to sectors within their coverage area, and for coordinating the proxy voting and ESG engagement strategies for the companies in their sectors with equity and fixed income analysts and portfolio managers. Our ESG team works closely with investment teams to incorporate our research into the investment process — regularly conducting in-depth portfolio reviews with investment teams to discuss holdings with the greatest ESG risks and strengths.

Portfolio Managers develop their own investment approaches, whereby ESG considerations are integrated into their research and decision-making processes to the extent that they believe these issues may affect the long-term success of a company and investment returns. This can manifest within the investment thesis or portfolio weighting for a security, as well as within proxy voting and company engagement efforts.

10.4a. Describe the methods you have used to adjust the income forecast / valuation tool

We consider environmental, social, and corporate governance (ESG) criteria as one set of factors among many that should be weighed appropriately to inform investment decision making. We view ESG analysis and integration as both return enhancing and risk mitigating. To help portfolio managers and investment teams better assess risks and opportunities in client portfolios, we have integrated the analysis of ESG factors into our investment and risk-management processes firmwide.

Each of our portfolio managers develops their own investment approach whereby ESG considerations are integrated into their research and decision-making processes to the extent that they believe these issues may affect the long-term success of a company and investment returns. This can manifest itself within the investment thesis or portfolio weighting for a particular security, as well as within our proxy voting and company engagement efforts.

Proportion of actively managed listed equity exposed to investment analysis

10.2b. Indicate which methods are part of your process to integrate ESG information into fair value/fundamental analysis and/or portfolio construction.

10.4b. Describe the methods you have used to adjust the income forecast / valuation tool

We consider environmental, social, and corporate governance (ESG) criteria as one set of factors among many that should be weighed appropriately to inform investment decision making. We view ESG analysis and integration as both return enhancing and risk mitigating. To help portfolio managers and investment teams better assess risks and opportunities in client portfolios, we have integrated the analysis of ESG factors into our investment and risk-management processes firmwide.

Each of our portfolio managers develops their own investment approach whereby ESG considerations are integrated into their research and decision-making processes to the extent that they believe these issues may affect the long-term success of a company and investment returns. This can manifest itself within the investment thesis or portfolio weighting for a particular security, as well as within our proxy voting and company engagement efforts.

10.5. Additional information.


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