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Baillie Gifford

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.

Baillie Gifford recognises that owning a company's shares on behalf of clients confers certain rights and responsibilities. As active managers, a key part of our investment strategy is to assess the quality of company management, in particular management attitudes to shareholders. When combined with financial information, ESG-related business information can provide a valuable insight into the overall quality of management. As a truly long-term investor these issues are central to how we invest, how we manage our own affairs, and how we interact with our clients. As a private partnership, we know from our own experience how critical ownership structures and corporate cultures are to good long-term outcomes. Our low portfolio turnover relative to our industry highlights our genuinely long-term perspective. If you analyse a company’s business prospects over the next decade, not the next quarter, you have to think deeply about the way it interacts with a variety of stakeholders and the impact ESG issues can have on the business. The interconnected relationships between asset owners, investors and company managers are central to that conversation, and to the task of reconnecting savers with the users of their capital through good stewardship.


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]

Our ESG policies are set at firm level. The extent to which governance and sustainability research is incorporated into the investment case is based on the materiality of any issue to the long-term sustainability of the company’s business. As a result the key governance and sustainability issues will vary depending on the industry sector, geographic region and core business activities of each company. The following list is neither exhaustive nor exclusive, but is representative of some of the specific governance and sustainability topics taken into consideration:

  • Board composition, skills, experience and diversity
  • Remuneration and incentive structures
  • Capital allocation decisions and share issuances
  • Environmental performance
  • Climate change
  • Labour relations
  • Health & Safety performance
  • Supply chain management and control
  • Bribery and corruption
  • Stakeholder relationships

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.

Baillie Gifford maintains a firm-wide Conflicts Matrix, which identifies conflicts and potential conflicts of interest that exist within the firm, and the procedures and controls that have been adopted to manage these conflicts. It is subject to review and approval by our Compliance Committee, which consists of a cross section of senior management. Each partner and employee has a responsibility for the identification of conflicts through adherence to the firm’s Code of Ethics Manual. Training is provided on the terms of the Code as part of new employee inductions and annually thereafter. Baillie Gifford’s firm wide conflict of interest disclosure is available on our website. The Governance & Sustainability team’s conflicts of interest policy is available on request.

Our conflicts of interest policy can be found on our website:

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)