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Jupiter Asset Management

PRI reporting framework 2020

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Promoting responsible investment

SG 09. Collaborative organisations / initiatives

09.1. Select the collaborative organisation and/or initiatives of which your organisation is a member or in which it participated during the reporting year, and the role you played.

Select all that apply

Your organisation’s role in the initiative during the reporting period (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

We are active signatories to the PRI. Members of our senior management and responsible investment personnel engaged directly with PRI representatives during the year. Our collaboration deepened during 2019. For example, we joined Climate Action 100+, a global investor initiative of which the PRI is a steering committee member. In another example of collaboration, we were signatories to a joint letter to the SEC, coordinated by the PRI, opposing proposed changes to Rule 14a-8 (shareholder proposal rule) and for proxy advisory firms. We agree that the shareholder proposal process is critical to the advancement of ESG integration in the U.S. and the fulfilment of the second PRI principle, active ownership. Proxy advisory firms play a vital role in providing impartial analyses of and recommendations on corporate issues that are important to investors. 

Your organisation’s role in the initiative during the reporting period (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

 We have actively participated on an industry level to further develop understanding of transition risks and opportunities relating to climate change. For example, in 2018 we supported CDP’s sector report on capital goods, which ranked 22 of the largest publicly listed capital goods companies on business readiness for a low-carbon economy transition. The report builds on Jupiter’s longstanding engagement with CDP but also reflects our view that their focus on the Capital Goods sector is particularly timely. We presented the report at the UK TCFD Preparers Forum, organised by UN PRI, UK Green Finance Initiative and the City of London, on how climate risk information is being used by the finance sector. We recognize the challenges highlighted by TCFD, including the variability of climate-related impacts across and within different sectors and markets. As long-term active investors, helping to develop thought-leadership that advances the understanding of risks and opportunities related to climate change aligns with the commitment to investor stewardship we have made to our clients.

Your organisation’s role in the initiative during the reporting period (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

We joined CA100+ in November 2019, this action followed our becoming members of IIGCC in February 2019. We have already played an active role in collective engagements facilitated by CA100+. For example, we have joined the engagement groups for Shell and BP. We also collaborated with the engagement groups for Anglo American and BP, the latter of which we acted as co-filers of a climate shareholder resolution which passed with near unanimous support at the 2019 AGM. 

Your organisation’s role in the initiative during the reporting period (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

We once again participated in the ICMA’s latest annual Green Bond Principles (GBP) consultation, which helps shape the agenda for the group in the coming year. As in our previous responses, we encouraged the GBP to include additionality explicitly in the framework and to improve the GBP Objective statement in order to align members better and help protect investors from green washing.

Your organisation’s role in the initiative during the reporting period (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

We joined IIGCC in February 2019. The IIGCC is a collective body through which European institutional investors and asset owners coordinate initiatives to tackle climate change, primarily via direct engagement with companies, but also industry dialogue on climate change and supports the implementation of related best practice. IIGCC also engages on finance and climate policy at the global, EU and national level across Europe. Our engagement with IIGCC encompasses each of these areas. We are participants in the Paris Aligned Portfolios Initiative, launched in Autumn 2019, which aims to explore and define how investors can align their portfolios to the Paris Agreement. We have also participated in various collective engagements during the year.

          Investor Forum
        

Your organisation’s role in the initiative during the reporting year (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

We have been members of the Investor Forum since inception. Our Vice Chairman is on the Board of the Forum and offers strategic advice, support and investor experience. During the period we engaged with the Investor Forum as part of our response to the UK Stewardship Code Consultation. We submitted an independent response but as members of the Forum considered other views which aided our own internal debate and empowered our response.

 

          Inaugural Stewardship Report by EY.
        

Your organisation’s role in the initiative during the reporting year (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

EY undertook an independent review of UK stewardship assessing the top 20 Asset Managers and Top 10 Asset Owners by AUM. EY devised a model to breakdown various ESG metrics and then assess the level of practice that was in evidence in the marketplace i.e. from nascent to advanced. This was based on assessing disclosures, policies and engaging with the asset manager/ owner. Jupiter participated in these conversations and in the subsequent investor outreach.

          Tomorrow's Company
        

Your organisation’s role in the initiative during the reporting year (see definitions)

Provide a brief commentary on the level of your organisation’s involvement in the initiative. [Optional]

Tomorrow's Company (TC) is a non-profit think tank which exists to inspire and enable companies to be a force for good in society. We started discussions with TC from 2018 and over the period held more discussions and attended roundtables to discuss demystifying stewardship, promoting stewardship across the investment chain and work on a project to discuss the role of active management and stewardship which is ongoing. 


SG 09.2. Assets managed by PRI signatories

Indicate approximately what percentage (+/- 5%) of your externally managed assets under management are managed by PRI signatories.

93 %

SG 10. Promoting RI independently

10.1. Indicate if your organisation promotes responsible investment, independently of collaborative initiatives.

10.2. Indicate the actions your organisation has taken to promote responsible investment independently of collaborative initiatives. Provide a description of your role in contributing to the objectives of the selected action and the typical frequency of your participation/contribution.

Description

          Jupiter was approached by a leading local authority pension fund to provide a workshop on ESG from an active fund manager viewpoint. The request that we provide a very grounded and realistic view on the challenges and pitfalls and different approaches that are taken by our managers. Approximately 20 of the UK's largest pension funds were represented and they heard from our Japan, Global and Fixed Income fund managers, as well as from our ESG specialists.
        

Frequency of contribution

Description

          Jupiter is represented on various responsible investment committees with the Investment Association and over the period we particularly focused on SRDII, namely how should the 'significant vote' provisions be applied. That is, we didn’t want a situation for this reform to be geared at votes against or negative scenarios but in essence a significant vote should also encompass the valuable work and engagement that led to a vote in favour. As discussed we are also on various IA working groups and Committees which are actively considering transparency and disclosure.
        

Frequency of contribution

Description

          Our CIO and Head of Governance spoke at a Tomorrow's Company event which centred on the principles of Truth, Trust and Transparency. The event featured corporates, asset owner, managers and civil society groups. The main debate focused on the perceived dichotomy whereby we are in a state where there is increased transparency (from business) but this has not resulted in more trust. The forum discussed the role of stewardship in bridging this gap.
        

Frequency of contribution

Description

          Green bonds – two steps forward, one step back?: https://www.jupiteram.com/UK/en/Professional-Investors/Insights/Jon-Wallace/Rhys-Petheram-and-Jon-Wallace-Green-bonds-two-steps-forward-one-step-back 

-	What is financial inclusion and how are we investing to capture this secular growth theme? https://www.jupiteram.com/UK/en/Institutional-Investors/Insights/Abbie-Llewellyn-Waters/Abbie-Llewellyn-Waters-What-is-financial-inclusion-UK-Institutional-July-2019
        

Frequency of contribution

Description

          Jupiter responded to the UK stewardship consultation during the period.
        

Frequency of contribution

Description

          Our Vice Chairman is a member of the Investor Forum. Our CEO is on the Board of the Investment Association.
        

Frequency of contribution

specify description

          Help better inform corporates of ESG demands and direction of asset managers on this subject.
        

Description

          The focus on ESG reforms, best practice and regulation is most welcome but it can feel overwhelming for corporates who feel they are subject to various demands and can be confusing as to what shareholder priorities are. We have continually encouraged policymakers to ensure corporates are also included in consultation exercises. During the period under review one of the main corporate advisory / IR consultancy firms approached us to help educate them on the landscape who can then channel this information to their clients which are companies we hold. This whole situation arose because the said consultancy had observed our stewardship and engagement approach when they represented our investee companies found this effective and asked us to help. It was a symbiotic situation as everyone gained from this exercise.
        

Frequency of contribution

10.3. Describe any additional actions and initiatives that your organisation has taken part in during the reporting year to promote responsible investment [Optional]


SG 11. Dialogue with public policy makers or standard setters

11.1. Indicate if your organisation - individually or in collaboration with others - conducted dialogue with public policy makers or regulators in support of responsible investment in the reporting year.

If yes

11.2. Select the methods you have used.

11.3. Where you have made written submissions (individually or collaboratively) to governments and regulatory authorities, indicate if these are publicly available.

11.4. Provide a brief description of the main topics your organisation has engaged with public policy-makers or regulators on.

STEWARDSHIP CODE - INVESTOR FORUM

We discussed the IF's response to the UK Stewardship Code consultation during the period. We also hosted an IF presentation to our fund management department. During this session our fund managers were interested in how we could improve overseas collaborative efforts, recognising the effective work that the IF had done in the UK.

INVESTMENT ASSOCIATION

2020 STEWARDSHIP CODE CONSULTATION: i) Participated in investor outreach by the IA to obtain views on the 2020 Code. ii) Jupiter is represented on the IA's Stewardship Framework Reporting Working Group, which is an investor collective looking developing best practice around Stewardship Code reporting.

INVESTMENT ASSOCIATION

ASSET MANAGEMENT TASKFORCE - STEWARDSHIP WORKING GROUP: AMT was designed to encourage greater dialogue between the government, the industry and the FCA to ensure the UK asset management industry continues to deliver for consumers and the wider economy. The Stewardship Working Group (of the AMT) will consider how the Asset Management Taskforce can promote and enhance the UK as a centre of excellence for stewardship. Jupiter is represented on the Working Group. Discussions are ongoing but so far the role of stewardship has been discussed as well as focusing on stewardship across other asset classes (namely fixed income).

INVESTMENT ASSOCIATION - SHAREHOLDER RIGHTS DIRECTIVE II

We engaged with the IA policy team on SRDII and our views on significant vote reporting, namely that market practice should not just develop to use this to highlight voting against but in terms of in-depth stewardship it is important to retain flexibility as to why managers are voting in favour of certain motions.

INVESTMENT ASSOCIATION

Jupiter are engaged with the UK Investment Association and have an active position on the Responsible and Sustainability Committee. The role of the committee is to grow awareness, help shape understanding and potential development standards around Responsible and Sustainable Investment amongst its members and the wider investment community.

EUROPEAN FUND & ASSET MANAGEMENT ASSOCIATION - SHAREHOLDER RIGHTS DIRECTIVE II

As above participated in a regulatory conversation with regards to SRDII requirements. We echoed the points above about significant vote disclosure.

FINANCIAL REPORTING COUNCIL

Participated in FRC's investor outreach programme about the new Code. The new Code was supposed to be published in summer 2019 but this was pushed back to October 2019. However, the FRC re-engaged with investors and our Vice Chairman and Head of Governance & Sustainability met with the FRC to discuss progress and impart our views on the feedback that had been provided on certain areas.

JAPAN FSA, Ministry of Finance and Ministry of Economy, Trade and Industry

Conversations centred on the JAPAN FEFTA (Foreign Exchange and Foreign Trade Act). On initial inspection we viewed the proposals to amend the provisions where foreign shareholders have to file a 'pre-acquisition notification' from 10% of a company (in a restricted sector) to 10%.

GLOBAL INVESTOR STATEMENT ON CLIMATE CHANGE

Jupiter was a signatory to the Global Investor Statement to Governments on Climate Change in advance of the UN Secretary General's Climate Action Summit in New York in September 2019. The statement called on governments to phase out thermal coal power worldwide, put a meaningful price on carbon pollution, end government subsidies for fossil fuels, and update and strengthen nationally determined contributions to meet the emissions reduction goal of the Paris Agreement.

SEBI and BSE Ltd (India)

We engaged with the Indian financial markets regulator and stock exchange to inform them of suspected violations of listing rules with regards to proxy voting and shareholder meetings. These communications resulted in investigations and enforcement actions on the matters raised by both bodies.

Environmental Protection Agency (EPA)

We co-signed a collective investor statement facilitated by the Interfaith Center on Corporate Responsibility on the need for continued regulation of methane in the oil & gas industry, which was sent to thirty-five upstream and mid-stream oil & gas companies, including BP and Shell. In total 140 institutions including members of the Institutional Investors Group on Climate Change (IIGCC) representing over $5 trillion in AUM were signatories. The statement was published in response to concerns regarding the Environmental Protection Agency's (EPA) proposed rollback of oil and gas methane emission regulations. We considered the case put forward by the proponents and agree with the central point that the long-term role of oil and gas in the global energy mix will be influenced by the extent to which the oil and gas industry reduces its emissions of methane, a potent greenhouse gas. In response to the statement, BP issued a public response stating their support for the direct regulation of methane emissions by the EPA. Shell issued a public response detailing their opposition to the rollback and the communication of this stance to the EPA. We continue to monitor the outcome of these regulatory developments.

Joint letter to Senior Audit Partners of Shell, BP and CRH

We signed a joint shareholder letter sent to the Audit Committee Chairmen and Auditors of these systemic carbon emitting companies seeking enhanced disclosures demonstrating that the groups' financial statements appropriately incorporate material climate-related risks. The companies have announced measures to address climate risks following engagement with members of the Institutional Investors Group on Climate Change and the Climate Action 100+ investor initiative. The letter sought to ensure that their strategic responses flow through into the different elements of financial reporting and are appropriately reflected in the accounting and audit process. We saw merit in participating as the group's engagement objectives are aligned with our own priorities. These concerns were also raised by the same engagement group with the Financial Reporting Council (FRC).


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