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Wellington Management Company LLP

PRI reporting framework 2020

Export Public Responses

You are in Strategy and Governance » Investment policy


SG 01. RI policy and coverage


01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類と対象範囲を示してください。


01.3. 投資ポリシーが以下のどの項目をカバーしているか明示して下さい:

01.4. 組織の投資原則および全体の投資戦略、受託者義務(または同等のもの)の解釈、ならびに、ESGファクターおよび実体経済の影響をどのように考慮に入れているかについて説明してください。

At Wellington Management, we believe that understanding securities holistically, including their ESG characteristics, helps 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. We do this by producing ESG research and ratings, conducting ESG portfolio reviews with investment teams, and engaging with company executives and board members on ESG issues for the benefit of our clients. ESG analysts specialize by sector, which helps investors to consider common material ESG risks and opportunities across the sector as well as the relative performance of potential investments against a relevant peer set.

We believe it is important for each portfolio manager and investment team to have a genuine and credible articulation of how ESG considerations are integrated into their investment philosophy and process.  This means the integration is intrinsic to the process and not externally imposed. 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.

01.5. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。[任意]

ESG criteria have the same relevance to investment analysis as traditional financial criteria, and are incorporated into the investment decision to the extent that an investor believes that they will have an impact on financial returns.

Given the impact that issues like these can have on financial performance, we believe it is our fiduciary duty to integrate ESG analysis into our investment process to help pursue better investment results for our clients.

Due to the way the firm has organized its research and portfolio management functions, we don't have a chief investment officer. Instead, our investment capabilities are organized as a community of teams — each functioning as an entrepreneurial entity within an established organization. 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.

In recent years, we have further developed our specialized, in-house ESG Research team to help our portfolio managers and analysts gather deeper intelligence on ESG topics and integrate these considerations into the investment process. Core to our ESG integration philosophy is the belief that material ESG issues are strategic business issues, so we focus on understanding these material issues so that we can make more informed investment decisions for our clients.

We provide central ESG integration resources to portfolio teams firm-wide, and approach ESG integration as a tailored process, applied to all asset classes. We analyze ESG risks and opportunities in client portfolios, engage with companies in which we invest to discuss material ESG issues, and vote proxies on clients’ behalf to support decisions we believe will maximize the long-term value of securities. Our culture is built to support collaboration and our open-architecture “community of investors” naturally lends itself to the integration of ESG considerations.

Our ESG Research team, part of the central Investment Research function, 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 the ESG factors most relevant to the sectors within their coverage area. They are also responsible 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.

01.6. 補足情報 [任意]


SG 01 CC. Climate risk (Private)

SG 02. Publicly available RI policy or guidance documents


02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。





02.2. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。








02.3. 補足情報 [任意]

SG 03. Conflicts of interest

03.1. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

Wellington Management does not engage in retail brokerage, lending, securities underwriting, or proprietary trading and is not affiliated with any firms that engage in these businesses. In addition, the firm’s business model, ownership structure, and culture seek to align the interests of clients with those of the firm. Our broadly diversified client base and functional lines of responsibility help to minimise the number of potential conflicts of interest in relation to stewardship though they cannot prevent such conflicts entirely. Together, these structural elements may help the firm avoid some of the typical conflicts of interest in the investment management business that may arise in connection with stewardship responsibilities, though they cannot prevent such conflicts entirely.  As a fiduciary, we seek to place the interests of our clients first and to avoid conflicts of interest, including those that arise from voting or engagement issues. Our policies and procedures for managing conflicts of interest in relation to corporate governance issues are contained in the Global Proxy Policy and Procedures. In addition, on an annual basis, our Investment Stewardship Committee sets standards for identifying material conflicts with respect to proxy voting and corporate engagement.

03.3. 補足情報 [任意]

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、投資先企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

Wellington Management is a firm with a long history of conducting independent fundamental research. Monitoring our investee companies and engaging directly with company managements on a range of issues, including ESG matters, has always been a core part of our investment process. The majority of our company research is the result of direct contact with company management, both in our offices and on site, including contacts with company suppliers, customers, and competitors. Each year, Wellington participates in more than 10,000 meetings with company management teams from around the world. Portfolio managers, industry analysts, and ESG analysts all take part in our ongoing dialogue with companies, and we share information from these engagements with one another using a common research platform. This internal platform allows us to share specific company ratings from our fundamental, credit, quantitative and ESG research teams, along with engagement notes from meetings with company managements. Providing this level of transparency and information sharing across the firm facilitates our ongoing monitoring and dialogue with investee companies and helps us prioritize and focus our monitoring and engagement activity. Our firm's engagement with company management teams depends on the materiality of the issue, the responsiveness exhibited by the company to past communications and our assessment of whether such engagement is in the best interests of our clients. Our stewardship activities can include meeting with company boards, speaking to non-executive directors, carrying out proxy voting or participating in stakeholder dialogues. In the event that a company is not responsive to our initial engagement efforts, we will consider additional meetings with management, meetings with the Chair and other board members, writing a letter to the board, and potentially voting against members of the board in order to escalate our concerns.

We also use our proprietary ESG rating system to help monitor incidents from our investee companies. Our ratings are calculated using a systematic process and provide a relative assessment of an issuer’s ESG profile versus others in their peer universe. Each peer universe is defined using three criteria: industry group, home market and company size. Importantly, the rating is not a buy or sell signal, but rather helps flag potential material issues and provides a starting point for deeper qualitative analysis. In addition, some ESG issues lend themselves more objectively to quantitative analysis because we can measure them, such as the emissions contained in the carbon footprint, compared to the role a company’s culture plays in talent retention. An input to these ratings is a controversy monitor which weighs incidents by severity and materiality for each company.