Our approach to engagement is described in our Responsible Investment Policy and various other documents, including our Proxy Voting Guidelines. Key documents and significant changes of policy are reviewed by our ESG Working Group and Asset Management Operating Committee.
Across all our funds, we use the special rights that come with shareholder status to expand our investable universe and create positive change on behalf of our investors. Through engagement, we alert companies to ESG risks, propose solutions to the tough challenges they face and encourage them to improve their ESG performance – seeking to protect value for shareholders and keep companies accountable to all stakeholders.
We draw on established norms to define our approach, including the Principles for Responsible Investment, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines, a corporate responsibility standard endorsed by the Government of Canada. Through corporate engagement we also seek to support the Sustainable Development Goals (SDGs) – a worldwide effort by governments, business and civil society to end poverty and ensure opportunity for all, within planetary resource boundaries, by pursuing 17 environmental, social and governance goals between now and 2030.
Our Corporate Engagement Program is applied across all our listed equity holdings and consists of three main elements:
- The centrepiece of our corporate engagement approach is the Focus List: in-depth dialogues, announced at the start of the year, on a range of specific ESG issues, conducted independently or through collaboration, targeting at least 25% of our holdings. We also undertake tactical dialogues in response to emerging risks and opportunities: these include companies identified through our evaluations process where there are concerns about lack of disclosure or effectiveness of mitigation of key sector ESG risks that could threaten company value, as well as companies currently facing major ESG challenges that have been identified through our Management Breach Investigation and/or OECD Due Diligence processes. In addition, we undertake stewardship outreach focusing on governance matters to all our larger and/or significant holdings.
- We select companies for dialogue with consideration for: investment exposure – the scale of holdings within our funds; risk and opportunity exposure – the significance of the ESG issues identified; impact potential - where our intervention is most likely to result in change. Our engagement focuses on companies where we have holdings, although we may also engage with companies where ESG concerns are creating a barrier to investment.
- Our preferred tool is constructive dialogue, but we will escalate to filing or co-filing shareholder proposals where necessary, if we feel dialogue is not progressing.
- We reach out to company contacts at various levels (board. senior management, IR, corporate governance, sustainability, operations) depending on nature of the topic and the degree of escalation that we deem it requires.
- We also respond to many proactive requests from companies for investor perspective on sustainability issues.
- Transparent, engaged voting on company annual meeting agenda items based on guidelines promoting sustainability and good governance.
- “Feedback on Proxy” - input to companies on governance practices as part of Corporate Dialogues.
- Engaging policy-makers on corporate regulations and standards to create broader change and facilitate responsible investment.
- Participation in multi-stakeholder sustainability initiatives.
Engagement is carried out by our in-house team, who receive internal training and coaching from senior engagement staff as well as attending engagement-focused conferences and calls to exchange with peers. In some cases we may engage collaboratively alongside external manager subadvisors that also have engagement capacity.
We have procedures in place to address conflict of interest and the potential for selective disclosure of material information. An individual ESG team member does not vote on a company where a conflict of interest exists, and we undertake a process to track this. At the start of all engagement meetings, we renew our agreement with the company that, while the ESG issues under discussion may be material to the long-term performance of the company, no material undisclosed information will be sought or divulged, and we undertake a compliance process to track this.
If a company is unresponsive to repeated engagement effort on a critical ESG issue, a decision may be taken to divest the holding.
We track all engagement and publish quarterly and annual updates on the progress of company dialogues and policy interventions on our website.
Details of our approach to proxy voting can be found in our Proxy Voting Guidelines https://www.neiinvestments.com/pages/responsible-investing/esg-difference/proxy-voting/