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Capital Group

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy


SG 01. RI policy and coverage


01.1. 責任投資アプローチをカバーする投資ポリシーを策定しているかどうかを明示してください。

01.2. ポリシーの構成要素/種類と対象範囲を示してください。


01.3. 投資ポリシーが以下のどの項目をカバーしているか明示して下さい:

01.4. 組織の投資原則および全体の投資戦略、受託者義務(または同等のもの)の解釈、ならびに、ESGファクターおよび実体経済の影響をどのように考慮に入れているかについて説明してください。

The key element of our investment approach is always to act in the best long-term interests of our clients according to the fund objectives.

All of our investment activity, including how we integrate ESG issues into investment decisions and our engagement activities, is driven and directed by this principle. Intrinsic to our investment approach is the understanding that long-term sustainable and successful businesses incorporate and manage all relevant factors whether they be economic, financial, operational, environmental, social or governance related. Our bottom-up long-term investment approach therefore incorporates all these factors in a forward looking manner and reflecting the specific context of the issuer or sector.

Engagement with senior management and non-executive board members is also a core element of our investment approach. Engagement helps our investment professionals discern the risk appetites of management, their ability to manage risk, as well as their strengths and weaknesses. The management of risk is an important factor in building our investment thesis as is our conviction in the quality of the senior executive management team and non-executive board. This acknowledges the importance of having a strong team leading the business.

01.5. 責任投資アプローチをカバーする組織の投資ポリシーの重要な構成要素、バリエーション、例外事項を簡潔に説明してください。[任意]

The key elements of Capital's responsible investment policy are:

Research and resources - Capital has over 200 in-house equity and fixed income analysts who are responsible for evaluating all relevant factors, including ESG issues, as part of their company research into generating long-term value. Within Capital these individuals have the deepest knowledge, regular interaction with and understanding of companies and we believe they are best placed to generate investment convictions on behalf of our clients. Our intensive research and long-term holding period naturally lead to our analysts to develop productive relationships with companies, providing us with access and credibility.

Our global network of analysts and portfolio managers are the frontline resources in considering ESG issues as part of their overall company evaluation. We have a dedicated global ESG team who works with our investment professionals, supports the integration of ESG factors into our investment process, and drives the implementation of ESG initiatives across Capital. ESG team members have expertise in research, sustainable investing and issuer engagement.

In addition, we have a Governance and Proxy team who supports Capital’s stewardship and voting activities for our funds and segregated accounts. The team works with our portfolio managers and investment analysts to facilitate the voting decision-making process as well as enabling reporting of proxy voting decisions to clients. With global presence we are able to apply our governance principles consistently across all markets.

Screening/ Exclusions - Active stewardship is a key pillar of our responsible investment approach. We believe engagement creates value for investors and companies and that this is a far more impactful approach than excluding controversial companies — in equities and fixed income. In line with this approach, we do not apply screens or exclude stocks, unless it is part of the fund objectives or we are required to do so by our client’s guidelines or law.

A number of our clients with segregated accounts have ethical or other reasons why they may not want to invest in securities of companies with certain business interests. The criteria for the exclusion of securities or sectors are chosen in discussion with our clients. Our systems offer the flexibility for segregated accounts to avoid excluded securities or sectors.

Engagement with portfolio companies - Making thousands of company visits annually, and regularly meeting with the management of companies enables us to engage and generate dialogue on any issues that could affect the company’s long term prospects.

Our guiding principle as an organisation is always to seek to act in the best long–term interests of — and seek value for — our clients. In line with this overarching principle we decide, on a case-by-case basis, whether our clients’ interests are best served by engaging with companies or by the sale of the shares of underperforming companies.  Where appropriate, we will consider the views of other investors in deciding when and how to engage with companies.

Proxy Voting and Corporate Actions - All proxy voting decisions are made in-house by our proxy committees based on recommendations from our investment analysts. With their in-depth knowledge of companies, investment analysts factor in the circumstances which may apply to each vote rather than using a box-ticking approach or relying on external service providers. Voting decisions are overseen by regional proxy voting committees comprising portfolio managers, investment specialists, research analysts and legal counsel.

Our Governance and Proxy team provides in depth experience and enables a consistent set of policies and procedures to be applied globally. This approach facilitates consistency but allows us to be responsive to regional differences.

Our investment analysts also provide recommendations for voluntary corporate actions at the companies they cover. Decisions on corporate action events will be made by the portfolio managers and investment analysts responsible for shares held.

Industry Initiatives - Our companies participate in the following industry initiatives:

  • Sustainability Accounting Standards Board’s (SASB): Capital is an Alliance tier member of the SASB. Capital's Vice Chairman, Robert W. Lovelace is a member of the SASB Investor Advisory Group (IAG) that comprises leading asset owners and asset managers who recognize the need for consistent, comparable and reliable disclosure of material and decision-useful ESG information.
  • Asian Corporate Governance Association (ACGA): Steven Watson, Portfolio Manager at Capital, is Vice-Chairman of the ACGA Council.

  • International Corporate Governance Network (ICGN): Capital’s Corporate Governance Specialist Tom Elliott is on the ICGN’s Shareholder Rights Committee.

  • Council of Institutional Investors (CII): Capital’s Corporate Governance Specialist Tom Elliott sits on the CII Corporate Governance Advisory Council.

  • The Investor Forum (UK) (founding member): In her function as Senior Adviser to Capital, Ida Levine is on the Investor Forum Board of Directors.

  • Eumedion: Capital’s ESG Manager Rob Beale sits on Eumedion’s investment committee.

  • Assogestioni: Matteo Astolfi, managing director for financial intermediaries in Italy, is a named member of the association.

We are active participants in the above organizations and contribute by speaking at and attending events, working on collaborative engagement initiatives and participating in working groups such as the ICGN’s Cross Border Voting Working Group or the IASB and Financial Services Agency to improve accounting transparency. Finally, Capital's Chairman, Timothy D. Armour, was involved in the release of the Commonsense Principles of Corporate Governance available at

Capital has always invested for the long-term on behalf of our clients and as a matter of course has incorporated the impact of environmental, social and governance issues into the decision-making process where relevant. We continue to look for opportunities to encourage transparency from companies in which we invest on behalf of our clients. We remain committed to encouraging good governance practices through our own activities and those of other organisations promoting these concepts.

01.6. 補足情報 [任意]


SG 01 CC. Climate risk

01.6 CC. 投資期間において特定され、組織の投資戦略・商品に組み込まれている気候関連のリスクおよび機会について記述してください。

特定された気候関連の移行リスク・物理的リスクおよび機会、ならびに投資戦略・商品にそれらがどのように組み込まれているかを説明してください。(500 語以内で自由に記載)

As a global investor, we believe the impacts of climate change are broad and relevant, creating risks and opportunities across different sectors. With ESG integration, we embed our understanding of climate change into our investment decision making. This enables us to focus on the investment decisions where we see climate change and related issues as material financial factors.

The material climate related risks and opportunities we have identified include:


  • Climate regulation: Companies that do not anticipate regulatory developments may be at risk of a higher cost of capital and more expensive regulation which will affect their business models and, ultimately their valuations. We are mindful about the impacts of carbon emission regulations, which have already created winners and losers. According to our analysts, there is enough public concern and political action to affect industry and investment decisions.
  • Stranded assets: Some of our analysts have started to reallocate a portion of their portfolio according to their exposure to stranded assets, beyond the energy sector. They also engage with management to encourage them to be part of the solution and not part of the problem, especially in the mining sector, as it relates to unsustainable activities like thermal coal.
  • Divestment campaigns: Whether or not to divest from fossil fuel companies has been considered carefully, and we have taken into account the effectiveness of such an approach and the impact it would have. In the view of some of our analysts, divestment will not lower the global demand for fossil fuels, which is the key to reducing greenhouse gas emissions. The divestment movement will transfer the supply of fossil fuels to less environmentally conscious companies, which may even cause emissions to rise. Therefore, rather than divest, we have to date opted to engage with companies to encourage more climate-friendly action to accompany the transition to a low carbon economy.


  • Energy transition: The transition towards a low-carbon future will be a slow evolution rather than a revolution. However, this "slow evolution" will impact commodity prices, investments and ultimately, stock prices. We believe companies positioned to benefit from the transition to a low-carbon economy are attractive long-term investments. We invest in companies providing low-carbon solutions such as renewable energy, energy efficiency, water and waste management solutions. In fixed income we invest in green bonds issued by financial institutions, utility/energy companies and agencies that fund renewable energy projects.
  • Waste management: The waste management industry has significant growth potential because of its increasing importance. By providing collection and optical sorting systems to food and recycling businesses, waste management companies could benefit from major global trends: expanding environmental regulation, increasing recycling rates, greater automation, urbanisation and rising food consumption.
  • Electric vehicles: The move towards lower/zero emission vehicles will require significant R&D expenditures. This will ensure that some auto parts companies grow faster than the industry average. To identify opportunities in this field, we look at the proportion of spending on R&D, as a key indicator of which companies are prepared for increasingly restrictive emissions standards.


01.7 CC. 組織はそれら気候リスクの可能性および影響を評価しましたか?


In our view, the timescale for climate related opportunities is mostly short or medium term, while opportunities deriving from technological shift could be on a medium to long term timescale. We already invest in companies which we believe are benefiting or will benefit from these opportunities.

For climate related risks, the timescale could be further out. We believe the costs of climate change are limited in the short term but can be expected to rise over the next five to ten years. As long-term investors, our holistic and rigorous in-house research leads us to invest in companies which we think are effectively managing long-term risks, including climate risk.

01.8 CC. 組織はTCFDを公式に支持しますか?


While we have not yet publicly expressed our support for the TCFD, we are closely following its developments. Through our active participation in the Sustainability Accounting Standard’s Board (SASB) Investor Advisory Group, we support greater disclosure of ESG-related data, as such information can help us better assess the long-term value of a company. As it relates to climate-related disclosure across companies’ governance, strategy, risk management, metrics and targets, TCFD’s Implementation Guide extensively references the SASB Standards as a tool for implementing TCFD Recommendations.

01.9 CC. 重大な気候関連リスクおよび機会を特定・管理する組織全体の戦略がありますか?


The integration of climate related risks is an important part of our research-driven investment process. Capital Group has always invested for the long term on behalf of our clients and incorporated the impact of environmental issues into the decision-making process. As an asset manager, we recognise that clients trust us to invest in a way that helps them to meet their long-term investment objectives. Responsible investing forms an integral part of our bottom-up investment process, reflecting our belief that successful companies are likely to be those that take environmental, social and governance (ESG) issues seriously.

Consistent with our responsible approach to investing, it makes sense for us to be attuned to major sustainability issues, especially as they relate to the environment. With regard to those companies operating in industries about which some analysts might have concerns, we generally favour engagement rather than categorically restricting investment in them. We conduct bi-monthly dedicated ESG calls with analysts and portfolio managers to discuss specific sectors and themes including climate change, and capture examples of ESG integration. Internal and external ESG data forms the basis for the preparation for these calls and referencing our engagement with companies to enrich the discussion.

ESG factors can also be part of a positive investment decision. Our analysts are sometimes able to recommend investing in companies that they believe can deliver superior returns over the long term while providing sustainable environmental benefits. Successful investments have been made in companies that provide renewable energy and irrigation solutions in emerging markets, and in those that deliver energy efficiency benefits. We also follow developments in new technology, such as batteries for energy storage, which could accelerate the transition to a lower carbon economy.

1.10 CC. TCFD開示を発表するために組織が使用する文書/通信を示してください。

SG 02. Publicly available RI policy or guidance documents


02.1. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。






02.2. 一般に入手できる組織の投資ポリシー文書を記載してください。その文書のURLを記入し、該当文書を添付してください。








02.3. 補足情報 [任意]

As long-term active investors, we regard stewardship as an integral part of our investment process and are committed to contributing to the enhancement of corporate value and sustainable growth of investee companies through constructive dialogue and purposeful engagement.

Capital Group is a signatory to the following stewardship codes (including date we signed up), which aim to enhance the quality and documentation of engagement with companies. Our responses to each code are available on our website.

UK Stewardship Code (2010):

Japan Stewardship Code (2014):

Hong Kong Stewardship Code (2019):


SG 03. Conflicts of interest

03.1. 組織として、投資プロセスにおける潜在的な利益相反を管理するポリシーを策定しているかどうかについて明示して下さい。

03.2. 投資プロセスにおける潜在的な利益相反を管理するポリシーについて説明してください。

Our parent company, Capital Group, is privately owned and engaged solely in the business of investment management. As a result, we believe we’re less likely to encounter situations where our interests conflict with those of a client. However should a conflict of interest arise, our policy is to resolve it fairly in the best interests of the client. 

Capital associates adhere to our Code of Ethics, maintain the highest ethical standards and must put client interests ahead of the firm's and their own. Key policies support these principles, including rules prohibiting insider dealing, restricting personal trading, political contributions and business-related gifts and entertainment. Rules requiring disclosure of personal or other interests may lead to associates being excluded from the voting decision. The Code of Ethics disclosure is reviewed and signed quarterly by all associates globally.

To prevent undue influence by clients on voting decisions, our process is to scrutinise voting decisions in which Capital’s clients with significant assets under management have an interest. A client may have an interest in a vote by reason of being the portfolio company concerned or by having tabled a shareholder resolution, made public statements or directly attempting to influence our decision.

03.3. 補足情報 [任意]

SG 04. Identifying incidents occurring within portfolios

04.1. 組織では、投資先企業において発生するインシデントの特定と管理を行うプロセスを設定しているかどうか明示して下さい。

04.2. インシデントを管理するプロセスを説明して下さい

Our long-term active investment approach, means that we regularly engage in a dialogue with senior management and other stakeholders. We will discuss with management a wide range of topics which can include strategy, operational performance, governance, board composition, remuneration and environmental, social and governance (ESG) concerns. We are most concerned with issues that have a material impact on shareholder value. We will generally engage in a quiet, behind-the-scenes dialogue with the company as this usually is a more effective and constructive approach to solving problems and avoids the risk of damage to shareholder value caused by polarised public positions. Where our investment professionals identify ESG risks we may consider intervening where we think it is likely to achieve a materially better financial outcome for our clients.

Engagement with company management is part and parcel of our investment process and intervention would be a natural extension of this approach where there are issues of material concern. If behind-the-scenes dialogue with management has failed to achieve the desired outcome and we wish to retain the investment in the company concerned, we consider carefully whether taking further action could improve shareholder value. This action can take many forms, including holding additional meetings with management specifically to discuss concerns, or raising the matter with non-executive directors (including its senior independent director or chairman), or the company’s advisers. Occasionally we may also work with other investors where we believe this is the appropriate course and will benefit our clients, and consistent with applicable legal constraints. Engagement is our primary focus, alternatively if we believe it is in the best financial interests of our clients, we may sell the shares in a company rather than continue the discussions.