This report shows public data only. Is this your organisation? If so, login here to view your full report.

Railways Pension Trustee Company Limited

PRI reporting framework 2020

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

          UK Stewardship Code

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.

The Trustee’s investment beliefs summarise our approach under the categories of governance, returns, risk and implementation. One of the investment beliefs specifically addresses the impact that environmental, social and governance factors have on long-term investment returns.


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]

Our Sustainable Ownership framework considers environmental, social and governance impacts through four lenses:

i)   Improves investment returns
ii)  Reduces investment risk
iii)  Impacts our reputation as a responsible investor
iv)  Impacts the world our beneficiaries retire into

Our 3 focus areas:

1. Integration in portfolio management
2. Active Ownership
3. Longer-term risks and opportunities

Our approach to Sustainable Ownership including our voting and engagement policies and adherence to stewardship codes is outlined on our website:

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].

We also provide an overview of our Sustainable Ownership framework in the annual report of the Trustee Company.

For more examples of our responsible investing activities, please see our 2019 Sustainable Ownership report:

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.

Potential conflicts of interest are addressed in three ways:

  1. The Trustee Company expects its external asset managers to have effective policies addressing potential conflicts of interest, when it comes to matters of stewardship and investment practice. We also consider conflicts of interest in our appointment and monitoring of service providers.
  2. Under the Code of Conduct, Railpen staff are required to disclose any interest in any company, or other entity, in which the Trustee Company has an ownership interest. The compliance function runs a corporate watch list and a personal securities and investments dealing policy to further limit conflicts of interest. 
  3. The Trustee Company’s voting policies are applicable to all listed companies, including without exception those that participate as employers in railway industry pension schemes

03.3. Additional information. [Optional]

If we vote against management at an AGM of a company which is a sponsoring employer within the Railways Pension Scheme, we will notify our MD, Investments and the Head of the Client Investment Team. In 2019 we sent 23 notifications of this type. 

We follow a similar process when we voting against management at the AGM of a company which is a tenant in our internally-managed Property portfolio. In this case, we notify our MD, Investments and the Head of Property. In 2019, we sent 9 notifications of this type.

SG 04. Identifying incidents occurring within portfolios (Private)