The Investment Policy Committee (IPC) members are portfolio managers of Fisher Investments (FI) and are ultimately responsible for all strategic investment decisions affecting the firm’s portfolios including individual security selection and oversight/accountability of ESG/SRI. The members include the founder of the firm, Ken Fisher (Founder and Executive Chairman, Co-Chief Investment Officer), and four others: Jeffery Silk (Vice Chairman, Co-Chief Investment Officer), William Glaser (Executive Vice President of Portfolio Management), Michael Hanson (Senior Vice President of Research) and Aaron Anderson (Senior Vice President of Research). The overall responsibility of implementation and fulfilment of the ESG policy rests with FI’s Investment Policy Committee (IPC). The IPC determines the materiality of the ESG considerations as they pertain to countries, industries or individual stocks with the assistance of FI’s Capital Markets and Securities Analysts. FI has designated one IPC member, Aaron Anderson, to oversee the continuing education on ESG investing and act as a Subject Matter Expert.
FI maintains a large Research Department dedicated to supporting the IPC in its decision-making process. The Capital Markets Research Team is responsible for gathering information used in the analysis of a wide range of economic, political, and sentiment drivers. The IPC uses this information to formulate forecasts and to develop portfolio themes. The Securities Research Team is responsible for the initial analysis and on-going monitoring of securities (including ESG analysis) held in the firm's portfolios. Each analyst covers assigned securities falling within specific sectors. They are then responsible for providing the IPC with security updates as market conditions dictate or at least once per quarter. The Capital Markets Innovation Research Team is tasked with furthering our efforts to develop and evaluate new “capital markets technology” through systematic idea generation and testing in collaboration with the IPC and other parts of the Research Department.
Dedicated ESG Subject Matter Analysts
FI has three ESG subject matter experts on the Capital Markets Research and Securities Research teams. These ESG subject matter experts impact the application of ESG considerations in several different areas of our process. The ESG Analysts are responsible for staying on top of current and developing ESG trends, and briefing the IPC when appropriate. Moreover, the ESG subject matter experts works with our ESG data providers to help ensure quality and comprehensive ESG data is available for decision-making and monitor the consistent application of ongoing ESG analysis for individual securities. Based on analysis conducted by FI’s Research Teams, FI’s IPC selects securities.
Implementation and Client Guidelines & Assurance
After the IPC determines the securities to be purchased or sold in our clients’ accounts, FI’s Implementation Team generates those orders into Eze Order Management System (Eze OMS). These guidelines are all monitored using our order management system, Eze OMS. The Client Guidelines and Assurance (CGA) team utilizes MSCI ESG Research to help ensure compliance with our ESG/SRI mandated portfolios. Any orders found to be in violation of any guideline or mandate would be rejected and sent back to the IPC for further review, restarting the process. If the orders prove to be compliant, they are sent to Trading for execution. The Trading Team then executes orders on the open market and the CGA team runs Post-Trade Compliance the following day. Eze OMS furnishes daily exception reports identifying any position potentially violating an account restriction or not falling within the guidelines of the IPC. FI has policies and procedures in place to document, communicate, and resolve these incidents. The client’s Relationship Manager would notify the client if the magnitude of the violation is considered material.
Additionally, FI’s ESG subject matter experts work with the CGA team to help ensure mechanical screens are applied appropriately and to help identify potential ESG issues with securities using MSCI ESG database tools. The ESG subject matter experts also work with Portfolio Engineering and Client Operations teams to accommodate client-mandated ESG/SRI restrictions.