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Garcia Hamilton & Associates, L.P.

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

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.

Since the Firm’s inception, we have followed a consistent fixed income investment philosophy that focuses on the preservation of principal while maintaining high current income. Our goal is to outperform the benchmark index net of fees with higher credit quality, lower risk, and less volatility. We understand that the role of fixed income is to anchor the portfolio so the client can take risks elsewhere. Our approach is simple, but its simplicity is what gives it its power.

Our high-quality philosophy prevents the Firm from taking unnecessary or unquantifiable risk. This is particularly beneficial in today’s current volatile environment.

GH&A has included environmental, social and governance (ESG) considerations in our investment philosophy since our founding (1988).  Our philosophy is nuanced and proactive and has evolved beyond negative screening processes. These factors are incorporated considerations in our portfolio construction, investment decision-making, investment analysis and due diligence.

GH&A’s investing policy seeks to incorporate ESG and responsible investing (RI) trends and metrics across our high-quality universe within our top-down macro framework. We continually evaluate corporate securities on their current ESG/RI initiatives and policies and evaluate their measurable improvement and implementation of these initiatives.

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]

We utilize traditional financial and quantitative metrics analysis as well as qualitative assessments to identify ESG risks and opportunities and inform buy/sell/hold decisions. The Firm uses both internal and external resources to acquire data, information and analyses on sustainability factors facing our corporate universe.  GH&A collects historic and peer level data on our corporate securities including RobecoSAM, Sustainalytics Rank, ISS Quality Score, CDP Climate Score as well as Bloomberg ESG disclosure metrics.  The reports from these third-party providers assist the investment team in its overall evaluation process and provides a base to further study/research these securities for continued inclusion in our portfolio. Corporate securities are evaluated based on improving or declining adherence to PRI guidelines. If a security within our investment universe fails to maintain a positive ESG trajectory, it will receive diminished consideration for future investments.

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.


File Attachment

02.3. Additional information [Optional].

Though we do not publicly disclose our definition of ESG, investment objectives that take ESG factors into account, ESG incorporation approaches, and reporting, we make this information available to clients on quarterly and annual due diligence, compliance, and ESG questionnaires and disclosures.

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.

Excerpt from GH&A Code of Ethics: Section I. General Principals, D. Conflicts of Interest

The Firm has a duty to disclose potential and actual conflicts of interest to their clients. All employees have a duty to report potential and actual conflicts of interest to the Firm. Therefore, all employees are required to disclose annually any board position they or their spouse hold for a foundation, endowment, charity or similar organization, private company, publicly traded company, or government entity. In addition, prior to acceptance of any position in an outside enterprise, i.e., a publicly-held company or government entity, or serving as a member of an investment committee of any Board, an employee must submit a Notice of Intent to Accept Position which can be found attached to [the Code of Ethics] as Exhibit A.

03.3. Additional information. [Optional]

As an Investment Advisor registered with the Securities and Exchange Commission, GH&A fiduciary obligations include: prudence in managing clients’ assets, acting in the clients’ interests above the Firm’s interests, disclosing potential or actual conflicts of interests and maintaining confidentiality of client records and information.

SG 04. Identifying incidents occurring within portfolios (Private)