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Wellington Management Company LLP

PRI reporting framework 2020

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Organisational Overview
Basic information [OO 01 - 09] Asset class implementation gateway indicators [OO 10 - 12] Peering questions [OO LE 01 - HF 01]
Strategy and Governance
Investment policy [SG 01 - 04] Objectives and strategies [SG 05 - 06] Governance and human resources [SG 07 - 08] Promoting responsible investment [SG 09 - 11] Outsourcing to fiduciary managers and investment consultants [SG 12] ESG issues in asset allocation [SG 13 - 15] Asset class implementation not reported in other modules [SG 16 - 17] Innovation [SG 18] Communication [SG 19]
Direct - Listed Equity Incorporation
ESG incorporation in actively managed listed equities [LEI 01 - 10] Implementation processes [LEI 01 - 10] (A) Implementation: Screening [LEI 04 - 06] (B) Implementation: Thematic [LEI 07] (C) Implementation: Integration of ESG factors [LEI 08 - 10] Outputs and outcomes [LEI 12 - 13]
Direct - Listed Equity Active Ownership
Overview [LEA 01] Engagement [LEA 02 - 08] Outputs and outcomes [LEA 09 - 11] (Proxy) voting and shareholder resolutions [LEA 12 - 21]
Direct - Fixed Income
ESG incorporation in actively managed fixed income [FI 01 - 12] Implementation processes [FI 01 - 03] (A) Implementation: Screening [FI 04 - 06] (B) Implementation: Thematic [FI 07 - 09] (C) Implementation: Integration [FI 10 - 12] Fixed income - Engagement [FI 14 - 16] Outputs and outcomes [FI 17 - 18]
Confidence building measures
Confidence building measures [CM1 01 - 07]
Export Public Responses
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You are in Strategy and Governance » Promoting responsible investment

責任投資の促進

SG 09. Collaborative organisations / initiatives

09.1. 報告年度に組織がメンバーであったり、参加していた協働組織やイニシアチブ、ならびにそこで組織が果たした役割のレベルを選択してください。

当てはまるもの全てを選択してください

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

Wellington personnel regularly attend events hosted by PRI. In 2019, this included PRI in Person (Paris). In addition to attending sessions and collaborating with other asset managers and asset owners, Wendy Cromwell presented during the impact-focused panel discussion, “Identifying and measuring company impact – lessons from public markets.”

As discussed above in section SG 09.1, our Director of Sustainable Investment, Wendy Cromwell, joined the PRI Board of Directors in January 2019 as an asset manager representative. The nomination and voting process leading up to Wendy's appointment involved active communication with numerous asset manager signatories of PRI to understand which of their objectives and obstacles the PRI should focus its time and resources. By partnering with the PRI, asset owners, and other asset managers, we hope to raise the consciousness of ESG risks and opportunities, and build a more sustainable financial system.

Also in 2019, Marjorie Winfrey, Sustainable Investment Analyst, is member of the UN PRI’s EU Taxonomy Practitioners group, which will share tools and experiences to overcome barriers to implementation of the taxonomy.

Wellington has been an active user of the Data Portal to share our PRI reports with asset owners who may be potential clients and prospects.

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

One of Wellington’s macroeconomic research analysts attended the ACGA’s conference called “Rise of ESG in Asia: Implications for Listed Company Governance.” The analyst subsequently shared key takeaways from the dialogue with all investors, including those interested in China and emerging Asian markets.

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

As an investor member, Wellington supports climate risk disclosure and is included in the annual disclosure request.

One of our ESG analysts participated in an investor fireside chat at CDP's Global Supply Chain Summit to discuss the importance of environmental disclosure and how procurement decisions contribute significantly to a company's ESG impact.

We review CDP disclosure of individual companies through a dashboard created by our Investment Science team. We analyze CDP along with company filings, to assess the materiality of a company’s climate risk and current management of climate exposure. We’ve analyzed over 700 companies, providing a report with climate analysis and engagement priorities.

We developed guidance for companies specific to physical climate disclosures that complement other climate-related disclosure frameworks such as the TCFD and CDP, and we make explicit reference to CDP throughout the framework. Wellington Management and CalPERS launched a framework designed to help companies assess and disclose the potential effects of the physical risks of climate change (P-ROCC) on their business.

We continue to collaborate, sharing feedback to improve the breadth and depth of scalable climate datasets over time, including implementation challenges of consistent methodology for scope 3 downstream emissions and net/avoided emissions associated with low-carbon solutions.

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

ESG analysts attended both CII’s Spring and Fall conferences in 2018. One of our ESG analysts participated in a “master class” discussion at the Council of Institutional Investor (CII)’s 2018 Spring Conference, called Activist Investing, Shareholder Proxy Contest Decision-Making and Board Dynamics. The analyst discussed, alongside other panellists, how to evaluate an activist and its board nominees, as well as incumbent directors and company responses. This session also discussed what companies get right and wrong in dealing with activist investors, and how shareholder engagement can work to minimize threats and maximize longer-term performance and responsiveness.

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

GIIN invited members of Wellington’s Global Impact team to host a workshop for GIIN employees at their headquarters on impact investing and measurement in public equities. The workshop was interactive and conversational, with three impact case studies discussed. The workshop was well attended.

Wellington also attended and was among the sponsors of the 2018 GIIN Investor Forum in Paris.

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

One of the global industry analysts (GIAs) covering the real estate sector was invited to speak on a panel at the GRESB Real Estate Results conference. The analyst discussed his approach to using ESG data, including GRESB and other sources, in his investment process. He emphasized the use of data to ask more informed questions when engaging with management teams.

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意] 

          UK Stewardship Code, Japan Stewardship Code, Hong Kong Principles of Responsible Ownership, Australian Stewardship Code, Transition Pathway Initiative (TPI), Investor Forum (UK)

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意] 

          Investor Stewardship Group’s Framework for US Stewardship and Governance

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

In January 2017, we became a founding signatory of the Investor Stewardship Group’s (ISG’s) Framework for US Stewardship and Governance. The ISG is a collective of some of the largest US-based asset owners and asset managers, along with several of their international counterparts. Its purpose is to encourage best practice in corporate governance and investor stewardship in the US. This investor-led initiative promotes six corporate governance principles for US-listed companies and six stewardship principles for institutional investors.

 
          Task Force on Climate-related Financial Disclosures

イニシアチブにおける組織の報告年度の役割（定義を参照）

組織のイニシアチブへの関与の度合について、簡単に説明してください。[任意]

On the second anniversary of the 2015 Paris Climate Conference, Wellington Management joined over 230 organizations in signing the Statement of Support for the Financial Stability Board's (FSB's) Task Force on Climate-related Financial Disclosures (TCFD).

We believe the TCFD's recommendations are the emerging standards for comparable, reliable, efficient climate-risk disclosure that can help lenders, insurers, and investors make better decisions. The recommendations provide a non-prescriptive framework that corporations and asset managers can adopt in a manner that speaks to their overall climate-adaptation strategy by disclosing details about four key elements: governance, business impact assessment, risk management processes, and metrics selection.

In 2018, Wellington published its inaugural TCFD report, which can be found on our public website. As a fiduciary of client assets, we believe that it is important to consider all risks, including those stemming from climate change, which could be material to our clients’ portfolios. There is alignment between the framework and our approach. We intend to provide increasing levels of specificity over time.

SG 09.2. Assets managed by PRI signatories (Not Applicable)

SG 10. Promoting RI independently

10.1. 組織が、協働的イニシアチブとは別に、独自に責任投資を推進しているかどうかについて記載して下さい。

10.2. 組織が協働的イニシアチブとは別に、独自に責任投資を推進するために行っているものを明示して下さい。選択した行動の目的に貢献するために組織が果たす役割と通常の行動頻度について説明して下さい。

説明 

          The ESG Research team and Sustainable Investment team broadly are regularly invited to participate in training programs by client request. In 2019, the Director of ESG Research explained the landscape of implementation options for sustainable investing solutions for the registered investment advisors of a subadvisory client. We participate in consultant education sessions, including participating in conferences and internal sessions. We discuss the ESG data provider landscape with clients and prospects seeking to select an ESG data provider that best suits their intended use case.
Given our collaboration with WHRC, our Director of Climate Research and the Director of WHRC increasingly providing several educational presentations to increase the understanding of our clients and consultants about physical climate change and potential impacts on capital markets. 
Members of Wellington's Global Impact team also present to the asset owner and advisory community to explain the similarities and differences between private and public impact investing, given that public impact strategies are newer to the market.
Our intention with these interactions is to increase awareness of the range of sustainable investment options, to answer questions about this range of strategies, and to reinforce our belief that incorporating ESG and impact factors can be achieved in tandem with investment performance. 
Please refer to SG 09 for additional details. 
The Sustainable Investment team met with clients and prospects on more than 430 occasions during 2019. All of our discussions have an educational component, with topics ranging from materiality to physical climate risks to the sustainable investing landscape.

行動の頻度

説明 

          Wellington Management Company LLP (Wellington), one of the world’s largest independent investment management firms, and Woods Hole Research Center (WHRC), the world’s leading independent climate research institute, have announced a multi-year collaborative initiative to integrate climate science and asset management. 
This new alliance will focus on creating quantitative models to help analyze and better understand how and where climate change may impact global capital markets. Wellington and WHRC will collaborate on a broad range of projects, including developing investor tools and innovative analytical methods seeking to improve climate risk assessment and investment outcomes. WHRC will also publish academic papers that draw from the climate modeling involved in the project.

行動の頻度

説明 

          The ESG analyst who covers the Energy sector participated in the request for feedback from the Environmental Defense Fund (EDF)'s report "Disclosure Divide" about methane. The ESG Research team also conducted a data provider landscape assessment of 60 ESG ratings providers and shared our conclusions with researchers at MIT.
As part of our ongoing collaboration with professors at Harvard Business School (HBS), Wellington Management became the subject of an HBS case study. The story is about innovation and it chronicles the challenges and excitement of being a true first-mover for impact public equities in an investment landscape dominated by venture capital/private equity. The portfolio managers of the Global Impact equity strategy, which is the subject of the case study, were Executive Guests at HBS to help teach the case for the first time.
As discussed in section SG 06.1, two of our global industry analysts (GIAs) are members of the Sustainability Accounting Standards Board (SASB) Standards Advisory Groups for the industries they cover, providing feedback to the SASB staff on the standards development process and the implementation and use of the standards Alan Hsu is a member of the Renewable Resources & Alternative Energy group, and Andre Desautels is a member of the Technology & Communications group.

行動の頻度

説明 

          As a founding member of the Investor Stewardship Group’s (ISG’s) Framework for US Stewardship and Governance, Wellington Management supports the six stewardship principles, which include provisions for regular disclosure of stewardship activities and policies to manage conflicts of interest.
Wellington is also participating in The ESGaction Council, which has partnered with eVestment to develop GOODquestions™, a common ESG questionnaire for plan sponsor and consultant institutional mandate RFPs, RFIs, and DDQs for 2019, which will result in more accurate and adaptable ESG reporting from asset managers, prevent the unhelpful proliferation of forms, and free up time and attention to focus on the substance of disclosures. 
As a member of FCLT Global, Wellington participated in Focusing Capital on the Long Term (‘FCLT Global’) Summit. FCLT Global’s mission is to develop practical tools and resources that encourage long-term behaviors in investment and business decision-making. One example of our participation during 2018 is that two of Wellington’s vice chairs led table discussions at the summit, discussing the merits of long-termism from multiple angles. In attendance were about 100 senior leaders from large global asset owners.

行動の頻度

説明 

          One of our Utilities industry analysts presented to a group of asset owners at the PRI in Person conference to share his perspectives on climate risk, the alternative energy market, and other environmental investment opportunities. 
One of our ESG analysts participated in an investor fireside chat at CDP’s Global Supply Chain Summit to discuss the importance of environmental disclosure and how procurement decisions contribute significantly to a company’s ESG impact. This conference was attended by CDP Supply Chain members, including public companies that respond to the annual disclosure request.
One of our ESG analysts participated in a “master class” discussion at the Council of Institutional Investor (CII)’s 2018 Spring Conference, called Activist Investing, Shareholder Proxy Contest Decision-Making and Board Dynamics. The analyst discussed, alongside other panellists, how to evaluate an activist and its board nominees, as well as incumbent directors and company responses. This session also discussed what companies get right and wrong in dealing with activist investors, and how shareholder engagement can work to minimize threats and maximize longer-term performance and responsiveness.

行動の頻度

説明 

          All of our in-house research developed can be found on the Insights section of our web site. In 2018, this included a white paper written by the ESG Research team about the treatment of dual-class shares by index providers and its impact on investors. We also published two pieces discussing the opportunity for impact investing in public markets, focused on equity and fixed income, respectively.

行動の頻度

説明 

          We regularly meet with institutional clients who are seeking to learn more about our engagement with the PRI and understand requirements where we share our experiences and encourage participation. We also regularly discuss the collaboration opportunities and responsibilities as a PRI signatory as part of client inquiries.

行動の頻度

10.3. 組織が責任投資の推進のために、報告年度中に参加した追加の活動およびイニシアチブがあれば、それらを記載して下さい。[任意]

SG 11. Dialogue with public policy makers or standard setters

11.1. 報告年度において、責任投資を支援するために、組織が単独で、あるいは他組織との協働により、政策立案者や規制当局との対話を行ったかどうかを記載してください。

はいの場合

11.2. 使用した方法を選択してください。

具体的に記入してください 

          Wellington participates in industry groups/trade associations that provide feedback to regulators on responsible investment issues. We meet informally with FRC, Bank of England representatives.

11.3. （単独でまたは協働により）政府または規制当局に書面を提出した場合、その書面が一般に入手できるかどうかを記載してください。

URL https://www.unpri.org/sustainable-markets/sec-sign-on-letter?adredir=1
URL https://theinvestoragenda.org/wp-content/uploads/2019/12/191201-GISGCC-FINAL-for-COP25.pdf
URL https://www.cftc.gov/PressRoom/PressReleases/8079-19

11.4. 組織が公共政策立案者または規制当局と話し合いを行った主なテーマの概略を記載して下さい。

Wellington selectively participates in industry groups and trade associations that occasionally provide collective feedback to regulators on issues that directly impact responsible investment or the asset management industry at large. For example, members of our Legal and Compliance team have participated in discussions with the Investment Company Institute (ICI) to listen to and provide feedback to inform the collective view on shareholder rights issues, including shareholder proposals and the role of proxy advisory firms, so that these views may be relayed to the U.S. Securities and Exchange Commission (SEC) in the form of comment letters. Wellington is largely in agreement with the balanced view presented by ICI on this issue. In addition, Wendy Cromwell, Vice Chair, Director, Sustainable Investment, and PRI board director, signed PRI's sign-on letter to the SEC, opposing these changes, on behalf of Wellington. The letter has been posted in the SEC's comment files.

In addition, members of our Compliance team are participating in the Investment Association's collaboration to provide guidance to the UK investment management industry implements the new requirements of the EU Shareholder Rights Directive implementation by the Financial Conduct Authority (FCA).

Wellington signed the Global Investor Statement to Governments on Climate Change, reiterating support for coordinated policy development to accelerate investment in the low-carbon transition and to enhance climate-related financial reporting. Chris Goolgasian, Director of Climate Research, was asked to be a member of the Commodity Futures Trading Commission (CFTC) Market Risk Advisory Climate Risk Subcommittee and is an active member. This subcommittee aims to identify challenges to managing climate risks and ways to bolster scenario analysis, reporting, and governance efforts, and to explore potential policy initiatives and best practice for risk disclosure.
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