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ClearBridge Investments

PRI reporting framework 2019

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

          Internal ESG ratings process
        

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

Other description (1) The firm-wide commitment to integrate ESG across all assets (fundamental and ESG analysis, engagements, internal ESG ratings, etc.)

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

At ClearBridge, asset management is the Firm’s sole focus.  The Firm is aligned with the long-term interests of clients and strives to deliver alpha in every aspect of the business, from generating consistent investment performance, to promoting sustainable business practices (Environmental, Social and Governance), to delivering successful long-term outcomes.

ClearBridge’s business principles are focused on long term outcomes which is reflected in a history that dates back over 50 years supported by long tenured-employees at all levels of the Firm. The culture of the Firm is focused on attracting and retaining talent to deliver investment excellence and client service. Furthermore, ClearBridge’s compensation program is designed to align employees’ goals with the long-term interests of clients. ClearBridge’s longstanding belief is that its people, culture and legacy uniquely position the Firm for growth and success.

​Driven by the insight and expertise of Portfolio Managers and Research Analysts, ClearBridge’s time-tested investment process has guided the Firm throughout its history.  Key to long-term success is selecting high-quality companies through rigorous research and analysis. Strengthened by advanced trading and risk management systems, ClearBridge’s disciplined, methodical investment approach is designed to achieve consistent, top-tier performance over the long term.

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]

 

On an investment strategy level, Portfolio Managers have their own distinct investment processes and priorities when managing their portfolios. Thinking as long-term business owners they all share a fundamental approach to security selection and valuation analysis. A flexible approach to analysis is maintained across ClearBridge, with a common focus on real economic returns and cash flow. As long-term investors the Firm believes that business sustainability is crucial and Environmental, Social and Governance (“ESG”) investment principles are an important part of its long-term approach.

01.6. Additional information [Optional].

          
        
I confirm I have read and understood the Accountability tab for SG 01 I confirm I have read and understood the Accountability tab for SG 01

SG 01 CC. Climate risk (Not Applicable)


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.

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

Other, specify (1) description

          Internal ESG ratings process
        

URL/Attachment

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

URL/Attachment

02.3. Additional information [Optional].

The above documents appear in a variety of forms on our company website:

  • white papers
  • commentaries
  • published reports
  • bios
  • podcasts
  • presentations
  • fact cards
  • blogs

 


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.

ClearBridge’s Compliance Department addresses potential conflicts of interest that could arise from managing numerous accounts in the same strategy for different clients, especially if these accounts are subject to different fee structures.  First and foremost is monitoring to ensure equitable allocation of investment opportunities for similarly managed accounts.  The Compliance Department monitors all orders on a real-time basis to assure participation by all eligible accounts.  On T+1, Compliance reviews the trade blotter to ensure that all accounts that are eligible to participate in an investment opportunity did so. If an account was omitted inadvertently, it is treated as an error and the account is made whole.  Furthermore, Compliance reviews every Initial Public Offering allocation to ensure that such opportunities are appropriately allocated.  In addition, Compliance conducts a quarterly performance dispersion review for all accounts that are managed similarly.  Finally, no Portfolio Manager is permitted to short securities that are held long in any other portfolio they manage.  This restriction is monitored through automated systems.

 

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Not Completed)


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