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Ashmore Group plc

PRI reporting framework 2020

Export Public Responses

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INF 11. ESG issues in post-investment activities

11.1. Indicate whether your organisation and/or operators consider ESG issues in post-investment activities relating to your infrastructure assets.

11.2. Indicate how your organisation, and/or operators, considers ESG issues in the following post-investment activities relating to your infrastructure assets.

11.3. Describe how your organisation, and/or operators, considers ESG issues in post-investment activities related to your infrastructure investments. [Optional]

E&S Portfolio Management:

1. Disclosure / Stakeholder engagement: For Category A, B+, B and C Projects, to the extent required by the environmental and social requirements, the investment must provide information (disclosure) regarding environmental and social impacts and risks and mitigation measures to affected groups, in order to establish an appropriate dialogue and consider possible adjustments.

2. E&S Monitoring: For the duration of the investment, the Ashmore E&S Officer must periodically monitor performance in order to verify compliance with the environmental and social requirements, covenants and reporting requirements included in the financing or investment documents with the Investment, as applicable. The Ashmore E&S Officer will monitor against the KPIs developed for the respective project. The E&S Officer will monitor any developments related to environmental, social, health, safety, labour and security issues arising from the routine investment supervision activities. In case of non-compliance with the Environmental and Social Requirements, corrective measures must be established, including when required an ESAP and the performance of audits to ensure proper implementation.

3. Regular monitoring of the environmental and social performance of all investments: For Category A projects four (4) assessments per year, including two (2) on-site visits by the Ashmore E&S Officer and two (2) document reviews. For Category B+, B and C projects minimum one document review and one site visit by the Ashmore E&S Officer.

4. E&S Reports:

Quaterly/Biannual/Annual Environmental and Social Compliance Report for Category A, B+, B and C. Projects need to provide the necessary information required to: (a) verify the satisfactory implementation and operation of the ESMS, relevant managers responsible as well as training activities carried out;  (b) assess the environmental and social performance of the investments with respect to compliance with the environmental and social requirements; and (c) propose any corrective actions, if and to the extent necessary.
Reporting in case of E&S serious incidents: Notify of any social, labour, health and safety, security or environmental incident, accident or circumstance with respect to any investment that (a) has, or could reasonably be expected to have, a material adverse effect or impact on the Ashmore Funds or the investments, or (b) involves or causes, or is reasonably likely to involve or cause, any material breach of the environmental and social requirements, specifying the nature of the incident, accident, or circumstance and a corrective action plan.

In summary:

I. E&S activities immediately post-deal:

  • Identify high priority actions that merit inclusion in the 100-day plan, particularly non-compliance with national regulations.
  • Collate any additional data that was not available during the E&S Due Diligence phase to close out any significant outstanding issues.
  • Revisit findings of E&S Due Diligence and E&S Action Plan. Develop E&S strategy with the investee company to guide implementation and support future E&S initiatives. Agree core E&S KPIs.
  • Identify key personnel within the investee company who will manage implementation of E&S strategy and actions.

II. E&S activities during the investment holding period:

  • Oversee the management of E&S issues and implementation of E&S Action Plan.
  • Engage investee company and pursue continuous improvement and potential opportunities.
  • Monitor progress. Undertake periodic reporting and consultations with investee company management on E&S matters. Track core E&S KPIs.
  • Compile periodic performance reports for: i) Internal use for monitoring company performance; ii) Investors to demonstrate that money is being invested responsibly and in line with their investment policies; and iii) Any other stakeholders for which disclosure of information was identified during the due diligence assessments.
  • Collect E&S performance data that could add value to exit process.