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Momentum Metropolitan Life Ltd

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

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.

Responsible Investing is part of our core beliefs, and sustainable and responsible investment practices are a material factor underpinning our long-term success.  Outcome-based investing is the basis of the MML client-centric investment strategy, it redefines investment principles and returns from the perspective of the investor, as opposed to the investment managers' peer-based return goals.It can therefore be seen as a client-centric approach. The investment belief revolves around stress-free living by adopting a multi-asset-class, multi-strategy and multi-mandate approach.Responsible investment practices resonate with the outcome-based investing philosophy, the alignment of our client’s long-term goals to positively influence the world they will retire to. We consider the ESG risks of investments in which we invest to ensure their relevance in the performance of the overall objective.This applies across all asset classes, sectors and markets throughout the investment horizon of each respective investment.We have set goal posts to help us build on our responsible investment approach.Under each goal post is a list of actions that may be asset class specific to guide us where we need to implement and annually review to strengthen the responsible investment approach.Our goal posts are as follows: ESG integration, active owners, seek disclosure, advocacy, regulation and codes, report progress.

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]

MML Ltd’s purpose is to enable businesses and people from all walks of life to achieve their financial goals and life aspirations.  The MML Ltd's responsible investment policy is aligned and integrated with the company’s purpose and is approved and practically implemented and maintained by the MML Ltd's Exco.  MML Ltd acknowledges that we are in a privileged position to act as fiduciary to our clients and stakeholders. We strive to promote financial wellness for our clients and our values will always remain our foundation pillars.  These values are accountability, diversity, excellence, innovation, integrity and teamwork. Responsible investing is part of our core belief and sustainable and responsible investment practices are a material factor underpinning our long term success.  MML Ltd's considers the environmental, social and governance risk of assets in which we invest to be relevant to the performance of the overall objective – across all asset classes, sectors, markets and through time.  MML Ltd works to incorporate ESG factors into our investment considerations and ensuring that sustainability forms a cornerstone of our business principles and in our business dealings and undertakings. Through our responsible investment approach we aim as fiduciaries of client’s assets to invest in a manner that is fair and driven by the intention to generate long-term, sustainable investment returns while at the same time ensuring that the company remains true to its philosophy, portfolio construction and robust investment processes.  MML Ltd’s investment philosophy is an outcome-based investment approach, which is cognisant of managing the clients’ experience and journey to achieve a defined investment goal over the determined time period. We realise that ESG risk factors affect the sustainability of companies and therefore it is especially relevant to our investment decision-making process.  MML Ltd has set goal posts to help us build on our responsible investment approach. Under each goal post is a list of actions that we implement and annually review to strengthen the responsible investment approach. Our goal posts are: ESG integration, Active Owners, Seek Disclosure, Regulation and Codes, Advocacy and Report Progress.  We believe that our approach should preferably be pro-active and investigating directly or through our appointed service providers ESG risks, before these escalate to be material events that may affect our clients or stakeholders. Should they occur, an assertive process is adopted to manage the effect. It is our fiduciary duty to follow up on material ESG concerns and engage on the matter appropriately. MML Ltd encourages better transparency and disclosure of responsible investment practices across the investment industry. Therefore we promote integration of this information in investment decision-making to internal and external investment professionals, service providers and consultants.  Collaboration on responsible investment initiatives and encouragement of sharing ESG information within the investment industry is important to MML Ltd. We will support/participate in appropriate networks and platforms and seek to collectively address relevant emerging issues. 

We believe in active ownership as one of the important levers to successfully integrate responsible investment practices into its investment processes. Therefore, it uses its market presence, through shareholder activism, to contribute towards creating a well‐balanced economy for its investors. The proxy voting guidelines policy is also inherent to our risk management process.  Good corporate governance with its characteristics of transparency and accountability will force boards of directors to concentrate on their main function, which is to promote shareholder value and good corporate citizenship.

We use our market presence to influence and encourage companies to improve their management of environmental, social and governance (ESG) factors. This will lead to sustainable financial performance for the investor over the long term.  Examples of engagement opportunities are: Resolutions for upcoming board meetings that are contrary to our policies; Before shareholder meetings to discuss the relevant resolutions; Concerning news regarding a company in the media; To assist companies to improve their corporate governance; To engage regarding economic, social or environmental considerations of the invested company.

MML Ltd will review this policy annually or at such time as the board sees fit to revise its ESG policies and procedures

01.6. Additional information [Optional].


SG 01 CC. Climate risk (Private)

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.



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].

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.

The purpose of this policy is to provide a framework with regards to the avoidance and management of conflicts of interest in the Company in order to:

  • ensure compliance with the FAIS Act;
  • avoid legal liability, penalties, fines and reputational risk arising from any conflict of interest; and
  • avoid any situation in which the Company has an actual or potential interest that may, while rendering a financial service to a client –

a) influence the objective performance of its obligations to that client; or
b) prevent it from rendering an unbiased and fair financial service to that client, or from acting in the best interests of that client, including, but not limited to –

  • a financial interest,
  • an ownership interest, or
  • any relationship with a third party.

The Company will always attempt as far as possible to manage any identified conflict of interest by imposing actions designed to mitigate the risk of any of its clients receiving unfair treatment. These policies of mitigation will not only consider the treatment of client interests in relation to the interests of the Company and its employees, but also treatment between clients.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)