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Responsible Investment Association Australasia RIAA

Service Providers Framework 2019

You are in Strategy and Governance » Policy on ESG beliefs

Policy on ESG beliefs

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.

RIAA's Mission has ESG at its core: 

RIAA’s mission is to promote, advocate for, and support approaches to responsible investment that align capital with achieving a healthy and sustainable society, environment and economy.

Our work and business offerings are directly tied to delivering on this mission, including the main services as articulated through our core offerings.

The RIAA board ensures we deliver on this mission, through our 3 year strategy that sets out the over-arching levers we work on to deliver this mission (driving demand, shifting policy, strengthening capacity of professional members and working with super funds), working within our three key domains (market, members and the organisation), with measurable targets to report on our progress. 

 

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

01.3. Indicate the components/types of your internal policy and provide the URL and/or an attachment of the document/s if they are publicly available.

Policy components/types
          Strategy which sets the mission and our means for delivering on it
        

Public availability

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

01.5. Additional information [OPTIONAL]


SG 02. Norms used to develop policies

02.1. Indicate what frameworks and guidelines you have used to develop your organisation’s policies. Tick all that apply.

          Taskforce for Climate related Financial Disclosures
        
          Sustainability Accounting Standards Board (SASB)
        
          Global Impact Investing Network (GIIN’s) Impact Measurement & Management
        

02.2. Additional information. [OPTIONAL]

These global standards are used to assist and direct many of the activities of RIAA including our collaborative corporate engagement work, our policy and advocacy work, as well as the working groups of RIAA such as on human rights.


SG 03. Policy offerings to clients

03.1. 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

03.2. Provide a brief description of the key elements, any variations, or exceptions applying to these policies.

For RIAA, such guidelines and policies are embedded across our work program in many ways which are then used to inform our members (client) on their own implementation methods. 

For example, our industry benchmarking research articulates guidelines as best practice guidance across superannuation funds, impact investors, ESG integration and ethical investment. 

Furthermore, such guidelines and policies are embedded in RIAA's investment fund Certification Program where we articulate such policies and guidelines to applicants across different sectors. One such example is set out below: 

Responsible Investment Certification Program

#11 Program Expectations for ESG Integration

Context

The last decade has seen Responsible Investment emerge from being a niche industry to a point today where a significant proportion of the investment industry has committed to implementing a responsible investment approach. For large institutional investors, this has focused primarily on applying ESG integration practices to traditional financial analysis.

Defining and measuring ESG integration practices is challenging due to limited disclosure and a broad variation in depth of integration - from systematic implementation embedded into investment valuation practices and company engagement, to more ad hoc approaches.

For the purposes of providing guidance to certified members consistent with trending industry behaviours and heightening consumer expectations, RIAA has identified key aspects of ESG integration. We expect that this will change over time as our members try and test this in practice; and we intend to watch and learn and to update these, as leading practice evolves.

Performance Expectation

Currently certified funds who claim ESG integration as one of their RI strategies as part of their application for entry to the RIAA RI Certification Program show compliance with or reasonable progress towards the following expectations outlined in Table 1.

The Performance Expectations table sets out the methodology to assessing the level of ESG integration adopted by investment managers. It is based on 7 pillars that constitute elements of leading practice for the integration of ESG. These pillars have been established based on reviews of organisations in the responsible investment field who are working on defining what is leading practice in RI (including SIFs, GSIA, PRI, asset consultants and others).

The Performance Expectations table uses these pillars to establish a scoring process whereby those who score a sufficiently high rating are included as demonstrating leading practice in ESG integration (scoring a minimum of 82% or 11.5 points out of 14). This ensures a scoring system that is not prescriptive in what investors must have in place for demonstrating good ESG integration, but rather allows each organisation to implement a variety of measures that meets their organisation's needs and style.

 

03.3. Additional information. [OPTIONAL]


SG 04. ESG/RI in business offerings

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

Business area

Research and Data Provision

How you include ESG/RI factors

Our research program incorporates benchmarking and leading practice case studies across the RI spectrum.

Increasingly we are providing data feedback to our members on where they sit on this spectrum, performance against their peers and their year on year performance. 

 

Other, specify (1)

          Promotion of responsible investment
        

How you include ESG/RI factors

Our focus on growing demand for RI through promotion in the media, social media and via our Certification Program is focused entirely on the RI benefits of funds and investing and articulating these to consumers and their intermediaries. 

Other, specify (2)

          n/a
        

How you include ESG/RI factors

n/a

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

Roles present in your organisation
Oversight/accountability for ESG/RI
Implementation of ESG/RI
Board
Directors
Chief Executive Officer (CEO), Chief Financial Officer (CFO)
Chief Operating Officer (COO), Chief Information Officer (CIO)
Other chief-level staff

Please specify

          Executive Manager
        

Please specify

          Executive Manager
        
Other heads of department
Dedicated ESG/RI staff
Other role, specify (1)

Please specify

          Research Manager
        

Please specify

          Research Manager
        
Other role, specify (2)

Please specify

          Certification Manager
        

Please specify

          Certification Manager
        
Other role, specify (3)

Please specify

          Impact Investment Forum Program Manager
        
None of the above

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

          Involvement in industry events and activities to stay up to date
        

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

04.5. Describe the ESG/RI linked incentives.

CEO has an incentive to grow assets flowing into RI products and services in our market

04.7. Additional information [OPTIONAL]


SG 05. Outsourcing of services

05.1. Indicate whether you outsource some of your services. Report percentage of services outsourced as percentage for that specific business area.

Business area

05.2. For each business area, describe what components you outsource to other organisations.

In-house consultants manage the research program and work with partner organisations such as universities, Top 4 accounting firms (eg: KPMG), ESG specialists (eg CAER) and data providers (eg: MorningStar) to produce a variety of Responsible Investment Benchmark Reports.

 

05.3. For each business area, describe how you ensure the organisation implementing your outsourced services adheres to your beliefs and policies on ESG/RI.

Consulting research manager works in-house and co-ordinates with and conveys our beliefs and policies to RIAA's research partner organisations.
RIAA's research partners are most likely members of RIAA. It is also a requirement of RIAA membership that organisations select to acknowledge RIAA's mission - to promote, advocate for, and support approaches to responsible investment that align capital with achieving a healthy and sustainable society, environment and economy.


SG 06. Providing training/education

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

          Financial Advisers
        

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

Conferences, published Research, ESG themed webinars and workshops, and Certification program. We also provide training and education for financial advisers, including providing CPD points for their participation. 

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

          We do charge for members and others to participate in some of our events, such as our conference and investor field trips
        

06.4. Additional information. [OPTIONAL]


SG 07. Applying, advancing and promoting the PRI principles

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

Our work is dedicated to advancing and promoting responsible investment and all of our activities are about making the investors embed ESG considerations in their investment beliefs and account for them in risk assessments, investment decision making and other day to day financial services work. 

We actively support our members to:

- incorporate ESG issues into their investment processes through provision of tools, guidance and awareness of the key ESG issues in the market; also, the Certification Program sets minimum requirements for stewardship and accounting for ESG factors in investment decision making.

- implement active ownership principles, through guidance, relevant and timely briefings on relevant issues, annual benchmarking of funds and superfunds on engagement and voting, the Corporate Engagement Working Group and the Certification Program requirements for stewardship practices. 

- improve disclosures of listed companies as well as lifting the disclosure in the investment sector itself (e.g. through requiring full holdings disclosure in our Certification Program, promotion of the TCFD)

- promote these concepts across the full market, working with investors, advocating for policy change, and building awareness and the case for RI

We are the most active network in our region convening an active platform for collaboration by the industry in the interests of driving RI

We report to our members regularly in formal and informal ways on the way we are advancing this agenda.

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


SG 08. Actions taken to promote responsible investment

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

8.2. Additional information. [OPTIONAL]


SG 09. Long term trends

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

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

This has effect both on the consumers of our members' products, shifting the demand profile, as well as within the broader economy where our members are investing. We address this as one of the set of issues via our conferences, events and working groups.

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

This impacts across all of our members and so we address this in much of our work, through corporate engagements, policy advocacy and events. This is relevant both for preparing our members to the shocks and strains of physical and transition risk that climate change poses, and also through the creation, distribution and promotion of financial products and services aimed at addressing climate change for example through the RIAA RI Certification Program

 

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

As per climate change.

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

This is addressed as an issue of focus within forums of membership such as corporate engagement, and events. 

This is resulting in our members actively considering the changing market dynamics from technology, and the risks exposed to by their investee companies through tech development. This has lead to many activities in our membership, such as engagement on tech stocks due to privacy issues.


SG 10. Interaction with asset owners (Not Applicable)


SG 11. Aligning approach with investor goals

11.1. Describe how you typically align your organisation’s philosophy and approach to ESG/RI with your investor clients’ goals.

We work hard to help articulate the benefits of RI in delivering on investor outcomes. We provide the research and evidence base to articulate this consistency, as well as provide this for our members to articulate this in their own organisations and with their respective customers. 

 

11.2. Additional information. [OPTIONAL]


SG 12. ESG recommendations not aligned with investor goals

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

We have a diverse investment organisation base that come to RI from different perspectives, some primarily driven by values and others driven by delivering on risk adjusted returns / investment outcomes - all care in the strong financial outcomes.

We see it as important to articulate the need for investors to align their investment strategies with the interests and values of their clients, which does involve considering their personal values. We have helped articulate this in our market through consumer research that sets the benchmark expectations and how the values should be weighted in investment. We also published the Financial Adviser Guide to Responsible Investing to assist with this in the provision of financial advice. RIAA also worked to lift the bar on aligning ESG recommendations with investor clients’ goals by (for example):

Improving the example Fact Find for Certified Financial Advisers (including this in the Financial Adviser Guide to Responsible Investing)

Making submission to the NZ Code of Professional Conduct for Financial Services

Participating in the Australian Productivity Commission’s inquiry into Productivity of Superannuationand alignment with member benefits.

12.2. Additional information. [OPTIONAL]


SG 13. Seeking feedback from clients

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

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

We undertake an annual member survey of our members to inform our work program and strategy. We distribute the results of this survey with members, make it available on our website and use the findings to inform the following year’s work plan priorities.  


SG 14. Managing conflicts of interest

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

14.2. Describe how you manage potential conflicts of interest.

We have processes at board level to manage conflicts of interest, involving standing items in the board agenda requiring declarations of conflicts (real or perceived).

We have a conflicts of interest policy that applies to both board and staff members with comprehensive conflict management guidelines which is signed off at a board level. 

We also have embedded in our Certification Program guidance for managing conflicts of interest. 

 

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

We have declarations as part of our annual auditing process that require reporting of any personal interests gained from the company by board members or executives. We have no further formal process for managing this from an employee perspective, beyond the close oversight of board and executives of our small team.  

14.4. Additional information. [OPTIONAL]


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