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Fort Washington Investment Advisors, Inc

PRI reporting framework 2020

You are in Strategy and Governance » Investment policy

投資ポリシー

SG 01. RI policy and coverage

この指標には新しい設問が追加されています。事前に入力されている回答を精査してください。

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。

当てはまるものをすべて選択してください。
ポリシーの構成要素/種類
AUMの対象範囲

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。

Fort Washington Responsible Investment Policy

Purpose

As a fiduciary asset manager, Fort Washington’s clients are at the forefront of all we do.  We believe in repeatable practices that balance risk and return while adhering to the policies and framework set forth by each individual client.  In doing so, we support a broad spectrum of Responsible Investing.  We encourage, support, and practice an investment philosophy that considers environmental, social, and governance factors in assessing risk and the sustainability of future returns. 

Fort Washington’s Approach to Responsible Investment

Fort Washington operates three business segments – Institutional Asset Management, Private Client Wealth Management, and Private Equity Investment Management. Investment teams in each area have tailored approaches to integrate responsible investing for various asset classes and investment types. The items below describe how select investment teams throughout the firm apply responsible investing principles.  

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]

Fort Washington Responsible Investment Policy, continued

Integration of Responsible Investing into the Investment Process

Every investment decision at Fort Washington is based on an assessment of risk-adjusted return. A comprehensive risk management program includes a thorough assessment of environmental, social, and governance (ESG) factors. To varying degrees, our investment teams use MSCI ESG research and Morningstar Sustainability Ratings at the company, portfolio, and manager level to integrate ESG factors in the investment process. We also conduct proprietary ESG research when our investment teams are assessing the downside case for buy candidates and existing holdings.  The following tactics are deployed as Fort Washington incorporates responsible investing principles within its investment processes in support of achieving our clients’ objectives:

Positive/Best-In-Class Screening

Fort Washington employs positive ESG screening on behalf of investors who seek to construct a socially conscience portfolio. Our Private Client Group investment professionals construct comprehensive multi-strategy portfolios, leveraging ESG managers ranked highly by Morningstar and other third party data providers. Based on the desired asset allocation, each asset class is screened to seek best-in-class external strategies that adhere to an ESG mandate. The robust due diligence selection process is both quantitative and qualitative. The process concludes with Fort Washington’s Due Diligence Committee, comprised of senior leadership and asset class specialists, interviewing the fund manager. These interviews include wide ranging discussions on how the strategy measures and incorporates responsible investing into their investment approach.

Negative / Exclusionary Screening

Fort Washington has managed exclusionary or negative screen client portfolios since the firm’s inception. Our process seamlessly incorporates exclusionary screens along with ESG and other client specific investment guidelines, ensuring we uphold any ethical standards important to our clients along with sustainable investment practices.

Negative screens can vary from client to client and reflect what is important to investors by eliminating companies that participate in specific business activities. The most common are exclusions for companies that supply, manufacture, and/or distribute alcohol, tobacco, and weapons. Impact investors may screen out companies that derive a certain amount of revenue from fossil fuels. Clients with social objectives often screen out companies that engage in for-profit activity in countries with a history of human rights violations while faith-based clients may seek to exclude companies that participate in stem-cell research. Understanding the screening process is particularly important as it dictates portfolio construction and can often be a significant factor in investment performance.

Corporate Engagement & Shareholder Action

Fort Washington views corporate engagement and shareholder action as effective means to manage investment risk and support activities that drive positive shareholder value. Our Institutional equity and fixed income investment teams seek to engage with companies, where appropriate, primarily through dialogue and voting. These actions allow us to evaluate and understand companies’ corporate governance policies, environmental impact, and social issues. Additionally, active ownership philosophy is a key criteria when our multi-strategy teams conduct due diligence on external managers. We question managers to get a deep understanding of their engagement methods.

RI Governance  

Comprised of senior leaders in the organization and members from all areas of the company, the Responsible Investment (RI) Committee governs the firm’s RI efforts.  This group establishes responsible investing policies and procedures, ensures these policies and procedures are documented and followed, enhances RI awareness across the firm and allocates resources toward RI program development.

Implementation of the RI Policy is the responsibility of each investment team with support of the RI Committee.  Each team has a representative that is a member of the RI Committee. These individuals are accountable for upholding and communicating RI policy within their respective disciplines.

 

 

01.6. 補足情報 [任意]

          Our corporate culture is a key influencer of our investment policy. We adopt a long-term perspective and embrace results-driven actions while helping create value for our clients. Fort Washington supports a collaborative, team oriented approach that facilitates best thinking while operating with the highest standards of integrity and ethics.


We consider our culture as our own unique way of operating based on our values and guiding principles as well as helping define how we work with our business partners. This same culture has been critical to our financial success, enabling us to work in the best interest of our clients, our associates and our community.


Ten Guiding Principles
•We create value for our stakeholders.
•We favor the long term vs. the short-term outlook.
•We drive to achieve top-notch performance.
•We execute with urgency, proficiency and passion as disciplined execution is critical to our success.
•We are results-driven and have an incredibly strong work ethic.
•We make sensible decisions based on data and fact rather than on opinion, fad or partial knowledge.
•We operate with the highest standards of integrity and ethics.
•We value Level 5 Leadership and keep our egos in check.
•We collaborate effectively across the Enterprise, always operating in the spirit of teamwork and collegiality.
•We provide the ideal place for a long-term career. We enjoy working with each other.

Fort Washington Firm-wide Policies and Procedures for RI

Charter/Goal: To establish, implement and monitor policies and procedures to ensure proper oversight of ESG considerations.

Committee Meetings:   The Committee will meet on a semi-annual basis and any time an issue arises that needs discussion.  ESG Committee reviews its Policies and Procedures annually to determine if changes are warranted, if any.

Reporting Requirements:  Strategy composite snapshot reports will be run on a monthly basis and distributed to the asset or investment strategy Sub-Committees.  Sub-Committees will provide the ESG Committee with the appropriate documentation based on the Policies and Procedures for each asset class.  Quarterly metrics and performance are provided for the appropriate strategies to the firm’s Risk Management Committee. 

Research Tools:  MSCI ESG Program Manager or equivalent programs are utilized to incorporate ESG considerations.

Firm-wide and Investment Team Training:  The firm will provide orientation to ESG for new employees either through their investment teams and/or through annual informational sessions.

ESG Committee Membership: (Voting members unless otherwise noted)
•Director, Performance & Reconciliation – Chair of Committee
•Managing Director, Business Development & Relationship Management
•Managing Director, Public Equity
•Managing Director, Private Client Group
•VP, Portfolio Manager, Focused Equity
•VP, Portfolio Manager, High Yield
•AVP, Sr. Portfolio Manager, IG Credit
•Managing Director, Private Equity
•AVP, Marketing
•President & Chief Executive Officer
•Co-Chief Investment Officers
•Chief Financial Officer
•Chief Risk Officer
•Chief Compliance Officer (non-voting)
        

SG 01 CC. Climate risk (Private)


SG 02. Publicly available RI policy or guidance documents

この指標には新しい設問が追加されています。事前に入力されている回答を精査してください。

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。

URL/添付ファイル

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。

URL/添付ファイル

02.3. 補足情報 [任意]


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。

Potential conflicts of interest are identified through the combined efforts of Fort Washington’s Risk Management Committee, Compliance Department, and the firm’s Senior Management Team. 

Fort Washington seeks to put the interests of its clients first, consistent with its fiduciary duty.  Conflicts of interest include activities or relationships in which an adviser’s interests compete with the interests of its clients.  Fort Washington has policies in place to mitigate risks associated with areas of potential conflict, and makes full and fair disclosure of all material facts as to any potential or actual conflicts of interest. The Matrix is reviewed at least annually and presented to Senior Management.

The Risk Management Committee, Compliance Department, and Senior Management are responsible for identifying and addressing potential conflicts of interest.  The Compliance Department maintains a Conflicts of Interest Matrix detailing all potential and actual conflicts of interest. 

Both the Compliance Department and the Risk Management Committee work in conjunction with Fort Washington's Senior Management Team, comprised of the firm's President and Chief Executive Officer, Chief Investment Officer, and other Senior Officers of the firm in seeking to ensure that potential conflicts of interest are identified, discussed, and addressed in a proactive manner.

03.3. 補足情報 [任意]

Key to the risk management process at Fort Washington is the independence with which it is applied. Our Chief Risk Officer (CRO) has overall responsibility for our risk management process and reports to the Chairman, and the President & CEO of Western Southern Financial Group. The CRO has responsibility of Risk Management within Western Southern and Fort Washington.

Both Fort Washington’s and Western & Southern’s Codes of Ethics also address other conflicts of interest, outside business activities, fiduciary duties, gifts and entertainment, and provides proper behavioral standards and a venue for anonymous reporting of violations to the Codes. Employees of Fort Washington receive annual training and are required to attest to our code of ethics each year.

Fort Washington believes all material conflicts of interest have been identified and disclosed in the Firm's Form ADV. More specifically, Fort Washington's policies are in place to mitigate the risk associated with areas specifically related to employee trading, principal trading, and directed brokerage are as follows:

Employee Trading

Fort Washington’s Code of Ethics describes policies and procedures for personal trading by employees. Except for the transactions specified in the exemptions section, Section II “Personal Trading Guidance” of the Code of Ethics, all securities transactions, including purchases in an initial public offering and transactions in private placements, in which an employee or immediate family member has or acquires a beneficial interest must be pre-cleared with Compliance.

Principal Trading Policy

Fort Washington’s policy and practice is that the firm may engage in principal transactions, however any such transactions may only be executed when proper written disclosures are provided, client consents obtained, and appropriate approvals received and records maintained.

Fort Washington will provide clients with disclosure regarding each principal transaction including information about the adviser's conflict of interest, the price of the transaction or current quoted price, market best price information regarding security and, if applicable, any commission charges. Fort Washington will obtain consent from a client regarding any principal transaction prior to settlement of the transaction.

The Compliance Department will maintain records of all principal transactions, disclosures, and client consents. Fort Washington will not engage in principal transactions for ERISA-covered clients absent an appropriate exemption from applicable regulations.

Directed Brokerage Policy

Fort Washington may accept client instructions for directing the client’s brokerage transactions to a particular broker-dealer. Any client instructions to Fort Washington are to be in writing with appropriate disclosures that for any directed brokerage arrangements Fort Washington will not negotiate commissions, may not obtain volume discounts or aggregate directed transactions, and that commission charges will vary among clients and best execution may not be obtained.

Any client directed brokerage instructions and arrangements are to be in writing and must be reviewed by the Best Execution and Client Service.

Fort Washington provides appropriate disclosures in the firm’s disclosure document and/or the firm’s advisory agreement. Any client brokerage instructions are maintained in the client document file. Any relationships and conflicts of interest relating to arrangements in which brokers refer clients to the firm are disclosed to clients.


SG 04. Identifying incidents occurring within portfolios (Private)


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