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Orbis Investments

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

          Conflicts of interest policy

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

Other description (1) Orbis' Statement on Responsible Investing also makes reference to the firm having issued a statement outlining how it applies the principles of the UK Stewardship Code.
Other description (2) Orbis' Statement on Responsible Investing also makes reference to the firm having issued a statement outlining how it applies the principles of the Japanese Stewardship Code.

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.

We seek to invest in shares of companies that trade at a significant discount to our assessment of the intrinsic value of the business—intrinsic value being what a prudent business person would pay for the company. We believe the share prices of such companies will eventually reflect that intrinsic value. But we can never know when the gap between the share price and intrinsic value will close. Sometimes it happens much quicker than we expect, while at other times our assessment of intrinsic value simply turns out to be wrong. At all times, we are prepared to be patient and to take a long-term perspective with each investment opportunity. We also recognise that even the best stockpickers are wrong about 40% of the time, so we seek to mitigate permanent losses of our clients' capital when this occurs. When executed in a disciplined and consistent manner over the long term, we believe such an investment philosophy offers the potential for superior returns and reduced risk of loss. 

As part of a bottom-up research process, our analysts consider a range of factors that might affect a company’s intrinsic value, which can include environmental, social and governance (ESG) issues. 

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]

We seek to earn the trust and confidence of our clients by providing superior long-term investment performance and outstanding client service. When we make investment decisions we always have our clients’ interests at heart and aim to act with a view to the interests of the Funds we manage on behalf of our clients. Effectively exercising our ownership responsibilities is consistent with this objective, and we aim to fulfil our stewardship responsibilities in two broad ways. First, by engaging with investee companies (actual and potential) and, if deemed appropriate, other shareholders to further the interests of our Funds as shareholders. And second, by voting at shareholder meetings.

As long-term investors, we have always believed it is critical to understand the full range of factors that might affect a company’s business and its stockmarket performance. ESG issues are therefore very important to us, and our analysts consider them for every company as part of our bottom-up investment process. For example, if a company makes money in a manner that is not sustainable from an environmental or social perspective, we will not gain conviction in the sustainability of its current level of profits. Similarly the consideration of governance issues is a critical part of our assessment of a company’s intrinsic value. Our analysts’ research of ESG factors informs decisions not to invest in a company as much as it informs decisions to invest, although there is no ESG issue that would automatically prevent us from investing in a company unless otherwise restricted by a Fund’s investment mandate. All “Phase Three” fundamental research reports that are submitted to a Policy Group Meeting – a forum for rigorous peer review – include a section on relevant ESG matters.

The key principles above have been in place since we launched the Orbis Funds in 1990. We first published a Statement on Responsible Investing in early 2017 in order to explain to clients our approach to such matters. We review this document approximately every two years.

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.

Other, specify (1) description

          Conflicts of interest policy

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.

Orbis has various internal policies governing improper market and conflict of interest transactions. Insider trading is addressed by the Insider Trading and Market Abuse Policy. This outlines how employees should deal with insider trading and market abuse through identification, avoidance and reporting. It also outlines how Orbis manages the risks of insider trading and market abuse through appropriate controls.

Personal trading in securities is addressed by the Personal Account Trading Policy. This applies to employees and consultants who work in Orbis offices for more than one month. Prior approval is required for personal trades in relevant securities. This enables us to identify any potential conflicts and resolve them appropriately. Requests for securities that may be of potential interest to the Orbis Funds are reviewed and approved, or denied, by one or more senior members of the investment team with knowledge of the Funds' intended trading activities. Those governed by the policy are required to disclose each quarter transactions in in-scope securities. Furthermore, some employees are subject to an additional policy on personal securities required by the U.S. Securities and Exchange Commission. 

Orbis also has a Conflicts Committee that considers material conflicts of interest brought to its attention.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)