This report shows public data only. Is this your organisation? If so, login here to view your full report.

EG Funds Management

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.

EG’s investment objective is to generate long-term financial and sustainable returns for investors across its investment portfolio. As a fund manager, EG’s role is to utilise sound investment judgement within our social, sustainability and corporate governance framework.

It's part of EG’s fiduciary duty to consider all factors which may impact stakeholders, the community and the environment in which EG operates. EG accordingly incorporates ESG considerations throughout the life of an investment, including the acquisition, management and the disposal of assets.

EG has committed to not purchasing any assets from a range of specified industries and manufacturers pursuant to EG’s responsibilities as a signatory to the UN Principles for Responsible Investments (UNPRI).

EG is also continually developing our compliance program to provide confidence to our investors, meet our statutory and regulatory requirements, and achieve best practice standards for governance.  Our compliance program is supported by policies and procedures (both formal and informal) detailing how certain functions are to be performed across all business units.  We work hard at consistent and transparent communication with investors and we take a long-term view to investing, working collaboratively with partners to ensure we're aligned in achieving a positive outcome for all.

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]

EG has adopted an ESG Policy which mandates the consideration of ESG issues throughout the investment management process. The includes incorporating responsible investment principles in the acquisition, management and the disposal of assets. EG accordingly undertakes comprehensive asset due diligence to ensure that key ESG risks and opportunities can be identified and managed. For example, EG has developed an in-house risk management software (PRISMS) and bespoke due diligence checklist to systematically identify risks and opportunities which will not only affect the financial performance of the asset but will also have ESG impacts. 

EG’s due diligence checklist has a comprehensive ESG section with 14 questions covering a range of ESG risks and considerations. These questions consider, amongst other items, the environmental impacts of the asset and how initiatives can be undertaken to improve energy, water and waste efficiency. Consideration is also given to climate change risk. Social considerations are also assessed which often includes profiling tenants and "quality of place".  EG's PRISMS software similarly allows for a systematic approach to undertaking asset due diligence and monitoring of asset risks over time. EG reports on these ESG issues in investment proposals and then provides ESG updates to investors in quarterly reports. 

After the acquisition of an asset, EG continues to identify and manage ESG risks and considerations on an ongoing basis. EG incorporates where applicable, National Australian Built Environment Rating System (NABERS) ratings, performance monitoring, lifecycle assessments of plant and equipment, site specific OH&S risk assessments etc. in the active management of assets.

EG also manages the HISOT Fund, an ethical investment fund that focuses on improving the energy efficiency of property assets to at least 4.5 stars under the NABERS. NABERS is Australia’s building performance rating which is used to measure a building’s energy efficiency, carbon emissions, water consumption and waste production.

As a signatory to the UNPRI, EG reports annually on its adherence to the six principles of responsible investment across the business. The UNPRI are a voluntary and aspirational framework for incorporating environmental, social and corporate governance into decision-making.

For all active funds, EG is a member of the Global Real Estate Sustainability Benchmark (GRESB) and is working with a GRESB consultant to further integrate ESG consideration into its investment management processes. 

Finally, EG is continually working with an independent environmental-systems specialist to codify our Responsible Investment policy. Our external consultant has been tasked with identifying best-practice industry standards and incorporating these into EG’s 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.


02.3. Additional information [Optional].

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.

​EG’s conflicts of interest policy mandates:

  • the appointment of a Compliance Officer to manage potential or real conflicts of interest at all times;
  • that all staff members are adequately trained on conflicts;
  • that all staff members sign a declaration upon commencement of their employment at EG and on annual basis afterwards undertaking to disclose any conflicts of interest as soon as they arise;
  • that all staff members complete an interests register;
  • a formal Conflicts Register which identifies, reviews and reports on conflicts; and
  • a quarterly review by EG’s Board of Conflicts Register






03.3. Additional information. [Optional]

It is an employment requirement that EG staff disclose any potential or actual conflicts of interest. EG maintains a conflict of interest register which identifies conflict of interest, the magnitude of the risk and the mechanism for resolving/monitoring the conflict.

In the event that a potential or actual conflict of interest arises, EG reports the conflict and its management of that conflict to investors at the earliest opportunity. When a potential conflict is identified, the Compliance Officer will be guided by the definition outlined in RG181.  The Officer will evaluate the nature of the conflict and determine the magnitude of the risk and likelihood of the risk. Management of the conflict will be determined based on the outcomes of this evaluation. Management of the conflict will vary depending on its nature and may include avoidance, control or disclosure of the conflict. However, in all cases, whether potential or actual, EG actively excludes the conflicted staff member from any involvement in the matter to which the conflict gives rise. 

EG's approach is that conflicts in investment mandates should be avoided rather than managed.  As an independent unlisted fund manager, EG can commit to a 'zero conflict' policy in respect of its investment mandates. Accordingly, EG does not accept any new investment mandates that directly conflict, or have a competing investment agenda, with existing active EG mandates and does not invest as a principal in investments that conflict with existing active EG mandates. However, in rare occasions where an opportunity may fit more than one strategy, EG has a formal rotation policy which is disclosed to investors to address the conflict.

In the event EG recommends a deal to a fund's Investment Committee and the deal is rejected, EG retains a right to promote the rejected deal to other investors, but only as a one-off deal and never as part of a competing mandate.

SG 04. Identifying incidents occurring within portfolios (Private)