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Nuveen, a TIAA Company

PRI reporting framework 2020

Export Public Responses

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

          Corporate Governance Social Responsibility Charters
          ESG Fund Guidelines

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

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.

We believe that incorporating ESG factors into investment research, due diligence, portfolio construction and ongoing monitoring allows us to improve financial performance, mitigate risk, and create new investment opportunities. We are proud of the leadership role we have played for over five decades in RI and of our track record of achieving positive financial and non-financial client outcomes related to ESG practices. We believe that by driving transparency, innovation and global adoption of RI best practices across all asset classes, we have the opportunity to provide enduring benefits for portfolio companies, investors, society and our local and global communities.

Our clients expect us to be good stewards of their investments as we help them achieve financial well-being at all stages of life.  In order to fulfil our commitment to preserve financial, social and environmental value and support a sustainable macroeconomic system, we organize our practice around three key RI principles: (1) ESG integration, (2) engagement and (3) impact.

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]

Nuveen’s RI program is built around a centralized structure. We implement our unified policy and processes via a “central strategy, local ownership” model which strengthens accountability, ownership, effectiveness, ability to scale and credibility across the organization.

Nuveen’s Policy Statement on Responsible Investing applies to 100% of Nuveen’s AUM, $1.06T, across asset class and investment specialists (as of 12/31/19).

TIAA’s Policy Statement on Responsible Investing applies to all TIAA and TIAA-CREF Fund Complex assets, which accounts for ~$387B of Nuveen’s total AUM (as of 12/31/19).

Nuveen’s Responsible Property Policy applies to all Nuveen Real Estate assets, which accounts for ~$125.7B on Nuveen’s total AUM (as of 12/31/19).

For the purposes of this report, responses within each reported module reflect activities for a majority of assets held within each respective asset class. In certain cases and where it exists, investment specialist-specific activities may be additionally described in the descriptive sections.


Investment specialists: Nuveen’s investment affiliates take a unique investment approach to pursuing competitive risk-adjusted returns on behalf of their clients and may differ depending on company type, underlying asset or applicable regulation, including fiduciary duties and obligations.

RI team: Nuveen’s centralized RI professionals specializing in both public and private markets who drive knowledge sharing, new insights, and synergies at the security, portfolio, asset class and thematic levels, and effective and scaled portfolio company engagement.

Investment teams: Investment professionals across asset classes (i.e. research analysts and portfolio managers).

01.6. Additional information [Optional].

          Nuveen’s Responsible Investing Principles:

(1) ESG Integration
We believe that the consideration of ESG factors in investment research and portfolio management enhances long-term performance and allows us to better manage downside risk. We created and utilize a proprietary, technology-enabled platform to share ESG data, research and tools to augment traditional investment analysis, providing visibility into the financial risks and opportunities inherent in ESG.

(2) Engagement
We believe that effective engagement allows us to drive change at our portfolio companies and in the broader market to mitigate corporate risks and bolster company value.

Our key engagement activities include:

Proxy voting: We execute thoughtful, case-by-case voting on management and shareholder proposals for publicly traded companies.
Dialogue: We engage in direct and constructive dialogue with CEOs, senior management, boards of directors, tenants and operators as well as other appropriate stakeholders to promote value-enhancing outcomes through encouraging relevant ESG disclosure and adoption of best practices.
Targeted initiatives: We aim to drive measurable outcomes with company, industry, thematic and country-specific initiatives.
Market initiatives: We collaborate with peers, interdisciplinary experts and industry stakeholders to create best practices and drive more effective outcomes.
Policy influence: We actively help to shape legislation, public policy and global standards related to RI best practices.

(3) Impact
We believe that all investments have an impact on society and the environment. There are a growing number of opportunities across asset classes to pursue specific, positive and measurable social and environmental results while delivering robust long-term financial returns. By measuring and managing impact we seek to surface new insights, reveal future opportunities and help our clients invest in portfolios that meet their financial and impact goals.

While each of our investment specialists takes a unique investment approach to pursuing competitive risk-adjusted returns on behalf of its clients, we believe that these principles are applicable across all asset classes. Further, the underlying activities in each principle continue to expand and develop over time to meet evolving business needs and to ensure that we are realizing the full investment benefits of an RI approach.

SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe the identified transition and physical climate-related risks and opportunities and how they have been factored into the investment strategies/products.

Impacts from climate change may include significant risks to global financial assets and economic growth. As investors, our primary objective is to mitigate investment risks stemming from climate change. We recognize that long-term investment performance depends on other well-functioning systems, including natural systems that provide clean water, abundant food, and many other resources to the global economy. These systems are threatened by global climate change, which in turn threatens economic growth and investment performance. Therefore, our focus on mitigating climate risk is grounded in this orientation.

Nuveen’s climate change strategy seeks to align our practices with the recommendations of the Task Force on Climate-Related Financial Disclosure, while recognizing our unique multi-asset class structure. Specific facets of the strategy include the development of an overarching risk classification framework, constructing internal climate metrics, and addressing data gaps through building upon industry vendors’ specific asset class strengths. 

Physical risks & Nuveen’s exposure:

Physical risks of climate change are observed in all geographical regions: the atmosphere and oceans are warming, sea levels are rising and weather patterns are changing (linked to the increasing intensity and frequency of storm surges and hurricanes).  These changes can have a strong adverse impact on infrastructure, agricultural yields, quality of life, public health and economic growth. Emerging markets are likely to be more vulnerable to these impacts than developed markets.

Physical risks may affect Nuveen clients’ public & private investments, with exposure concentrated in two areas: 1) private investments in agriculture, timber, real estate, energy and infrastructure, and to a lesser extent, 2) public equity and debt investments in the utilities, energy, food and beverage, apparel, metals/mining, industrials and basic materials industries. 

Transition risks & Nuveen’s exposure:

Transition risks of climate change stem from the transition to a low carbon economy via technological innovation (increasing viability of renewable energy, energy efficiency, energy storage, and alternative and lower-carbon fuels), environmental regulation (cap and trade/carbon tax, fuel efficiency standards, etc.), and market forces (changes in fossil fuel commodity prices and consumer preferences).

Transition risk may affect Nuveen clients’ public & private investments, with exposure concentrated in fossil fuel and energy-intensive sectors. An abrupt or disorderly low carbon transition is expected to increase the transition risk facing these sectors.

Factoring climate risks into investment strategies:

Nuveen factors physical and transition risks of climate change into investment strategies in a variety of ways.  Individual investment teams identify and manage risks that apply to the specific assets that they oversee.  Nuveen’s Responsible Investing professionals work closely with investment teams in each asset class to integrate ESG considerations, including climate risk, into the fundamental investment process. For example, investment teams receive specialized training and have widespread access to carbon and climate data for their asset class.

In real assets, Nuveen emphasizes direct investments in climate change adaptation/mitigation projects like renewable energy and desalination and screens. In public markets, Nuveen is among the largest global investors in green bonds, and has launched over 10 low carbon mutual funds and ETFs.

01.7 CC. Indicate whether the organisation has assessed the likelihood and impact of these climate risks?

Describe the associated timescales linked to these risks and opportunities.

Nuveen participates in TIAA’s Emerging Risk’s Working Group, under which climate risk was initially identified and tracked.  The Emerging Risk Working Group developed the following timescale rubric:

  • Short-term: 1-4 years
  • Intermediate: 3-6 years
  • Mid-term 6-10 years
  • Long-term: >10 years

We evaluated the timescale, level of importance, impact, and likelihood of several aspects of climate risk, including carbon-intensive assets and the physical, macroeconomic, and water impacts from climate change. While timescales can vary significantly based on a number of factors, we believe that carbon-intensive assets may face more short- and intermediate-term risks than other assets. However, the likelihood and impact of these risks is uncertain depending on the speed and nature of the low carbon transition.  Meanwhile, we expect physical risks to materialize more so in the long term, with higher likelihood due to the physical effects of climate change already projected to occur.

In addition to these initial views developed through the emerging risks process, we plan to conduct additional analysis on the timescale, likelihood, and impact of these risks as part of formally embedding climate risk into our enterprise risk management process. For certain asset classes with less liquidity and longer hold periods (such as real estate), Nuveen already conducts more detailed analysis over a 30 year time horizon.

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.


The Climate Risk Task Force (the “CRTF”) is an internal working group established to develop an organization-wide strategy and oversee the management of risks associated with climate change that may arise across the Enterprise and its investment specialists. The task force’s responsibilities include but are not limited to:

  • Coordinate board-level communication on climate change risk topics
  • Recommend new climate risk management processes to monitor the exposure of Nuveen investment portfolios
  • Review and recommend potential climate risk controls

Environmental issues have always figured prominently in TIAA’s Policy Statement on Responsible Investing.  Prior to the establishment of the CRTF, in early 2017, TIAA’s Executive Committee approved a new Climate Change Statement of Principles, which provided further clarity and guidance across the company on this important cross-cutting issue. Language from the statement was later integrated into the Climate Change section of the 7th edition of the TIAA Policy Statement on Responsible Investing published in March 2019.  The full Policy Statement can found online at: 


1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.


          - The National Association of Insurance Commissioners survey assessing our climate risk strategy. 
- Nuveen Real Estate publishes a sustainability report and participates in the GRESB benchmark.

SG 02. Publicly available RI policy or guidance documents


02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

Other, specify (1) description

          Corporate Governance Social Responsibility Charters


Other, specify (2) description

          ESG Fund Guidelines


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

02.3. Additional information [Optional].

As signatories to the PRI, Nuveen has made a firm-wide commitment to broaden the scope of strategies and investment areas that include the integration of ESG information. Approaches for integrating ESG varies across asset classes and strategies, as do the specific policies and levels of disclosure.

Additional Nuveen Policies and Guidelines:

  • Sustainable Investment for Properties: 
  • Farmland Guidelines:

In addition to our publicly available policies listed above, TIAA/Nuveen has a number of internal policy documents and guidelines related to the incorporation and oversight of ESG in investment decisions. Policies integral to proprietary strategies have not been publicly disclosed.

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.

We seek to avoid or mitigate conflicts of interest that may arise in the normal course of our activities. We do this in several ways:

(1) Through the issuance of policies;

(2) Through the training of our employees;

(3) Through the implementation of controls; and

(4) Through the monitoring of activity that may present conflict such as employee personal trading and conduct, employee/firm and/or client and portfolio company relationships.

Information relating to our policies on conflicts of interest, voting client securities and other practices are outlined in our affiliates’ respective Form ADV, Part 2A which is made available to the public.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios

04.1. Indicate if your organisation has a process for identifying and managing incidents that occur within investee entities.

04.2. Describe your process on managing incidents

This response applies to Nuveen Real Estate, Real Assets, and Private Markets.

Within the Nuveen organization, Nuveen Real Estate has a defined process to Property Managers. They are required to report all material incidents to the respective Asset Managers, who will then escalate to the Head of Asset Management if required. Nuveen Real Estate utilises a Programme Governance audit tool to ensure that Property Managers have the relevant policy and process in place in order to notify Nuveen Real Estate of material issues. This is reviewed on an annual basis by asset managers. Additionally, Nuveen Real Assets and Private Markets investment teams are required to monitor and report all material ESG incidents, address them as appropriate through direct engagement or via a partner or sponsor, and review them at quarterly portfolio reviews or more frequently as necessary.