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Ellerston Capital 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

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

Other description (1) The Ellerston Capital Responsible Investment Policy also details our Modern Slavery Risk Policy.

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.

Ellerston Capital is a specialist investment manager providing a range of active, innovative equity and alternatives strategies. Our investment beliefs are as follows:

  1. Being majority owned by its principals and employees, our firm’s objectives are fully aligned with those of our client’s.
  2. Being a dedicated investment manager enables us to focus on doing one thing exceptionally well: grow and protect our clients’ wealth.
  3. We can create value for our clients by identifying outstanding investment opportunities and designing portfolios that use each of our investment teams’ strengths and capabilities to perform over the long term.
  4. Responsible Investment is key to our value creation proposition:
  • Environmental, social and governance (ESG) factors have the potential to impact both risk and return, and therefore should be factored into investment process, leading to more informed and holistic investment decision-making and better investment outcomes for our clients.
  • A key aspect of our fiduciary duty is that we have a responsibility to be active stewards of our clients capital - exercising positive influence through engaging with companies on relevant business and ESG issues; and, voting our clients proxy appropriately.
  • That a high level of transparency of our Responsible Investment process and related actions is important.

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]

Ellerston Capital's Resonsible Investment Policy is available on our website at the following link:

This Policy affirms Ellerston’s commitment to responsible investing and outlines our approach to practising responsible investing which comprises of four key components:

  1. Integration of ESG considerations in the investment process – research, analysis & investment decision making
  2. Portfolio screening – negative and positive as required by the client
  3. Stewardship – engagement with companies in our investible universe and those in cluded in our portfolios (and all relevant stakeholders), and undertaking proxy voting appropriately
  4. Transparency – full disclosure

These components are described in full detail in the Investment Policy.

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.

Other description (1) The Ellerston Capital Responsible Investment Policy also details our Modern Slavery Risk Policy.

02.3. Additional information [Optional].

Our Responsible Investment and Proxy Voting Policies are published on our website (per the links referred to in the above responses and the attached files) and covers all of the aforementioned policy components.

Please note that we have only attached the relevant files once rather than multiple times for each component.

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.

Ellerston Capital, as an Australian financial services licensee, is obligated under the law to have in place adequate arrangements for the management of conflicts of interest. All employees, officers and other representatives (including contractors) are required to be familiar with and comply with the policies. The main components of the policy include: 

  • Procedure for recognising, raising and disclosing a significant conflict of interest,
  • Identifying who is authorised to be a Conflict Manager, and setting out their duties,
  • Setting out specific procedures for evaluating, rating and acting on the conflict,
  • Definitions of extreme and significant consequences,
  • Policy on enforcement, whistleblowers and review/ audit and records. 

This policy is referred to in the Ellerston Responsible Investment Policy.


03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)