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Common Interests

Service Providers Framework 2018

You are in Strategy and Governance » Responsible investment policy

Responsible investment policy

SG 01. Responsible investment policy

01.1. Describe how your organisation’s philosophy incorporates environmental, social and governance factors, and the link to your business offerings.

As Fiduciaries, we look to the future and the future of our clients and their beneficiaries. We think about their goals, both short term and long term. Future generations depend on the decisions we make today, both from a financial standpoint, and looking at the world and the legacy we leave behind. We believe in knowing what we own, and mindfully designing the impact of our portfolios by looking ‘under the hood’ of our investments, at the way the companies we own are run, and directing our investments in an attempt to meet our financial goals while also creating change in the world.

The Principles for Responsible Investment Mission calls on signatories to play a role in creating a sustainable global financial system which will “reward long-term, responsible investment and benefit the environment and society as a whole.” The preamble to the six Principles recognises that applying the Principles in investment decisions not only supports long-term value creation but may also better align investors with the broader objectives of society – in other words, the SDGs.

To support this mission, we start our investment process with The Sustainable Development Goals, which we believe represent the Crises facing the world over the next 30 years. As investors, we see Crisis and Opportunity as two sides of the same coin, so we use the SDGs to guide our investment process when we’re deciding which companies or investment managers to include in our portfolios.

Many investors believe that investments in companies will only be profitable over the long term if the global financial system and societies grow in a sustainable and equitable way. And while responsible investment has typically focused on how ESG factors affect the risk-return profile of investment portfolios, it has tended to overlook how it supports the broader objectives of society.

As such, we subscribe to the SDG agenda which requires signatories to move from a mere process-based approach of material ESG integration towards an outcomes-based approach that, while aiming to achieve market-rate return on investment, explicitly aims to contribute to the sustainability challenges put forward by the SDGs.


01.2. Indicate whether you have internal policies that formalise the incorporation of your beliefs in your business offerings.

01.3. Indicate the components/types of your internal policy

Policy components/types

01.4. Indicate how these are put into practice internally across the organisation.

          public disclosure on our website at

01.5. Additional information [OPTIONAL]

SG 02. Publically available policies

02.1. Indicate which of your policy documents or statements (if any) are publicly available. Provide the URL and an attachment of the document.

Policy or document name

02.2. Additional information. [OPTIONAL]

SG 03. Norms used to develop policies

03.1. Indicate what standards you have used to develop your organisation’s policies. Tick all that apply.

03.2. Additional information. [OPTIONAL]

SG 04. Policy offerings to clients

04.1. Indicate whether you offer standard, off the shelf, policies to clients as part of your product offerings, and/or whether you create tailored versions for individual clients.

Off the shelf Tailored
Asset class-specific RI guidelines
Sector-specific RI guidelines
Screening/exclusions policy
Engagement policy
(Proxy) voting policy
RI guidelines set out within the Investment Policy Statement (IPS)
RI guidelines set out in a freestanding RI policy
Multi-year RI implementation project plan
Conflict of interest management policy
Stockbroker allocation policy
Securities lending policy
Other, please specify (1)
Other, please specify (2)
Other, please specify (3)
None of the above

04.2. Briefly describe how you incorporate ESG factors and RI-consideration when advising clients on policies.

  • Links between SDGs, ESG screens, RI and why we follow the policies that we do: 
    • Materiality + Business' sustainability
    • Assessing Risk + client goals

04.3. Additional information. [OPTIONAL]

SG 05. ESG/RI in business offerings

05.1. Briefly describe how you include ESG/RI factors as part of your business offerings.

Business area

Advisory and Consultancy

How you include ESG/RI factors

We offer sustainability scoring of clients and prospective clients' current holdings for a flat fee. we have the capability to evaluate the ESG scores of either individual companies or fund families (active and passive). we can show clients where potential ESG issues may be in their portfolios, and if they are considering investing in a specific company, we can report on the sustainability of that company and identify key material risks to that company's business, when compared against their peer group. 

05.2. Indicate the roles in your organisation, and indicate for each whether they have oversight and/or implementation responsibilities for ESG/RI.

Roles present in your organisation Oversight/accountability for RI Implementation of RI
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Other chief-level staff

Please specify


Please specify

Other heads of department

Please specify


Please specify

Dedicated ESG/RI staff
Other role, specify (1)

Please specify


Please specify

Other role, specify (2)

Please specify


Please specify

Other role, specify (3)

Please specify


Please specify

Other role, specify (4)

Please specify


Please specify

None of the above

05.3. Indicate how you ensure ESG/RI expertise for the roles where there are RI oversight/accountability or implementation responsibilities.

05.4. Indicate whether your organisation has any ESG/RI linked incentives for its employees.

05.6. Additional information [OPTIONAL]

SG 06. Outsourcing of services (Private)

SG 07. Providing training/education

07.1. Indicate whether you provide training/educational services on ESG/RI. Tick all that apply.

          Business Students (graduate and undergraduate)
          Financial Advisors
          Emerging Workforce: financial professionals

07.2. Describe the main components of your training/educational services on ESG/RI and any variations depending on the group you provide training/education to.

  • Financial Advisors and Investment Managers- ESG and SRI Basics, engaging with clients on ESG and SRI, the history of ESG/SRI, and how to evaluate potential investments on an ESG/SRI basis.


  • CPAs- ESG and SRI Basics + High Level Instruction, SASB Overview, Materiality (provided for CE once accepted by the CPA Board)


  • Business Students- ESG and SRI Basics

07.3. Describe whether these training/educational services include any commercial elements.

          CPA CE classes may be provided for a fee.

07.4. Additional information. [OPTIONAL]

SG 08. Applying, advancing and promoting the PRI principles

08.1. Describe how your organisation applies, advances and promotes the PRI Principles.

We apply the principles through our investment choices and recommendations to our clients. We have made RI, the PRI and the SDGs a centerpiece of our website and marketing materials.

We seek to advance the mission of the PRI and the Principles through presentations to the general public and the financial industry. We have partnered with other signatories (including founding signatories) to do webinars and broaden the reach and engagement of our message.

We promote the principles through our advocacy work. In our first year, we've signed on to two shareholder letters, one promoting the acceptance and standardization of ESG Data at the Securities Exchange level, and one promoting sustainable agriculture in the production of Palm Oil. We highlight these efforts through our social media and website.

08.2. Highlight whether there are any ways that your organisation would like to engage further with the PRI. [OPTIONAL]

Common Interests was founded with the principle of service at the core of our firm's identity. We would love to be more engaged with the PRI in any way possible, and welcome the opportunity to serve.

SG 09. Actions taken to promote responsible investment

9.1. Indicate which of the following actions your organisation has taken to promote responsible investments during the reporting year, independently of collaborative initiatives.

9.2. Additional information. [OPTIONAL]

SG 10. Long term trends

10.1. Indicate which of the following long-term trends are addressed in your product outputs.

10.2. Explain how this long-term trend affects your product outputs.

Within our practice, we are offering multigenerational financial planning meetings to help ease the intergenerational transfer of wealth and begin bringing the beneficiaries of our accounts into the investment process so we can get an idea of what values they want to see expressed in their portfolios. Within our investments, we are looking at long term healthcare issues and other investments that we believe will be needed more as the population ages. 

10.2. Explain how this long-term trend affects your product outputs.

We are concerned about the risks to our portfolios from a number of climate related factors. from stranded asset risk to energy companies to floods and droughts, to increased chances of severe weather to the economies of every country. We demand that the managers we work with take these risks into account in their investment process. 

10.2. Explain how this long-term trend affects your product outputs.

This represents a classic supply/demand mismatch. We have been watching Water especially carefully in light of South Africa's zero day, and have added water investments to our portfolios to try to both solve the problem and capitalize on the need. 

10.2. Explain how this long-term trend affects your product outputs.

A sleeve of our portfolios is devoted to investing for the "Next Economy" which we believe will be based technologies such as clean energy, energy storage, and other technological innovations. 

10.4. Additional information. [OPTIONAL]

SG 11. Interaction with asset owners

11.1. Indicate whether you interact with asset owner clients.

11.2. Indicate the typical frequency and type of interactions with your asset owner clients.

Type of interaction



11.3. Additional information. [OPTIONAL]

SG 12. Aligning approach with investor goals

12.1. Describe how you align your organisation’s philosophy on and approach to ESG/RI with investor goals.

We use our website: to introduce the overall concept to our clients. For our smaller clients, we determine whether they have specific themes they would like to see in their portfolios, then pick a low-cost, off the shelf, managed model for them to invest in without commissions. for our larger clients, we begin by talking about the screens we use in our core models that are managed in house, and set alternate positions within the models to customize their investments to their values set. for instance, if a client wishes to feature gender lens investing, we will substitute a gender fund for our large-cap holding, where doing so will not change the asset allocation, but will provide the client the exposure and advocacy they seek. 

12.2. Additional information. [OPTIONAL]

Plan to capture more detailed client impact goals

SG 13. ESG recommendations not aligned with investor goals

13.1. Describe what steps you take, if any, when your ESG recommendations are not in line with investor goals.

We believe that ESG factors provide an additional layer of risk management, and that it is wise and prudent to include them in the investment process. We discuss our views on ESG with each client, but when clients do not wish to include ESG factors in their investment strategy, we are obligated to follow their wishes. For these clients, we individually build portfolios that align with their objectives.

13.2. Additional information. [OPTIONAL]

SG 14. Seeking feedback from clients

14.1. Indicate whether you seek feedback from clients on your RI/ESG services and product offerings

14.2. Describe how you use this feedback in your RI/ESG services and product offerings.

Within our models, we have the ability to build custom Impact portfolios within our fixed income sleeve. We seek feedback from our clients as to which impact themes they want to see highlighted in their portfolios as a way of helping them express their values in their investments.

14.4. Additional information. [OPTIONAL]

SG 15. Managing conflicts of interest

15.1. Indicate whether your organisation has a policy for managing potential conflicts of interest.

15.2. Describe how you manage potential conflicts of interest.

Potential conflicts of interest are fully disclosed to the best of our ability. Our RIA is responsible for setting these policies, and our practices are governed by their policies and oversight.

15.3. Describe how you ensure that company employees do not derive any personal gain from the use of information collected during your work process.

Our RIA sets this policy and is an independent organization responsible for keeping us in compliance with these rules and regulations.

15.4. Additional information. [OPTIONAL]