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PRI reporting framework 2019

Export Public Responses

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LEI 12. How ESG incorporation has influenced portfolio composition

12.1. 組織のESG組み入れ戦略がポートフォリオや投資ユニバースの構成にどういう影響を与えているかを記載してください。


12.2. 補足情報 [任意]

We recognise that ESG factors can have a significant influence on the value placed on a company and its ability to drive shareholder returns on a long term basis.

ESG is relevant to a portfolio or investment decision if one or more of the following apply:

  • ESG is a predictor of future returns.
  • ESG analysis indicates longer term risks that investment analysis may not factor in.
  • ESG analysis indicates that there are moral or ethical issues which should be considered.

It is also important to consider ESG issues in light of the chosen method of implementation and investment time horizon. For example, ESG issues will have much more importance for directly or indirectly held securities where the holding period may be three years or more, than for a short term momentum based trade using futures.

Companies that undertake activities that are socially undesirable or environmentally damaging expose themselves to the longer term risk of regulatory change that adversely impacts their business. There is also the risk of fines or paying restitution if the conduct is illegal or negligent. This risk is particularly relevant in some sectors, such as energy.

We will not undertake a formal, permanent “divestment” approach, but rather consider whether the longer term ESG risks are sufficiently captured in the market price, and sufficiently diversified away within an index, or not. Unless the issue is such that it would result in the investment being worthless, then longer term risks are a matter of valuation, and whether the risks are adequately compensated for in the expected investment return. The expected holding period of the investment is also a very relevant consideration in this regard, as these types of risks are more important for assets with longer holding periods.


LEI 13. Examples of ESG issues that affected your investment view / performance

13.1. 組織の投資見解や報告年度のパフォーマンスに影響を与えたESG問題の例を挙げてください。


Misconduct at Board level: Evidence of Chair and CEO deliberately and systematically misleading the regulator as well as inappropriately amending an external independent report.

適用したESG組み入れ戦略 Screening|Integration


Reduce holdings before divesting company


Poor culture of risk & control: Multiple incidents in this financial services firm with the regulator conducting an external expert review. Resulted in significant turnover at board level and substantial fines and possible litigation.

適用したESG組み入れ戦略 Screening|Integration


Reduce holdings and significant engagement with company


Collapsed Dam: Key competitor faced domestic & international scrutiny following tailings dam collapse resulting in significant loss of life and environmental damage. Further scrutiny of other tailings dams and identified those firms that have geographical and structural advantages in terms of risk management of tailings dams.

適用したESG組み入れ戦略 Integration


Increased holdings in key Aust companies that are in advantageous position (e.g. better rated on operational resilience and governance oversight).


ESG issue: social conduct and disclosures related to responsible gaming practices

Food and beverage company, also has exposure to gaming through its ownership of a poker machine operator company. ESG concerns relate to poor disclosures on how it abides with its own responsible gaming policy and limited governance oversight as well as allegations of misleading and deceptive conduct. In the absence of public policy reform, activist groups are seeking to use existing consumer protection legislation to reduce the social licence and legitimacy of the gaming industry, with related reputation risks for the company, especially relative to revenue generation from its gaming exposure.

適用したESG組み入れ戦略 Screening


Did not invest


ESG issues: improved social metrics resulted in the company moving into the investable universe for the Sustainability (Best of Sector) Funds. 

An airline company's Social rating was upgraded due to the following key drivers: 

  • sustained peer outperformance on customer metrics from human capital-driven NPS initiatives (seen as key to business differentiation). 
  • evidence of positive cultural change, affirmed by improving performance in human capital assessment.
  • developing focus on diversity and solid disclosures on safety systems and processes


Increased position

13.2. 補足情報 [任意]