1. Fiduciary Duty: Consistent with the fiduciary duty to clients, superior long-term risk-adjusted returns can be generated by considering sustainability criteria. Sustainability should therefore be at the heart of the investment philosophy.
Sustainable Asset Management: Key Messages and Recommendations of SFAMA and SSF
Regulatory Extracts from this
The objective of this paper is to give an overview about the main beliefs of the Swiss asset management industry and to provide asset managers with an effective guide for the implementation of a sustainable asset management process including governance, risk management, investment policy and strategy. The recommendations describe the most important elements that are crucial for the successful implementation of a sustainable asset management process. They provide a general overview of how ESG factors should be implemented into the different elements of an investment process for it to be considered sustainable. This paper does not take the form of binding SFAMA Guidelines.
2. Corporate Sustainability: Assets managers should consider social, economic and environmental impacts in all aspects of their business and anchor their values in a corporate sustainability policy.
3. Comprehensiveness: The Swiss asset management industry is committed to addressing the topic of sustainability in a comprehensive way in its asset management services. In doing so, it aims to integrate sustainability aspects in all elements of the investment process. Furthermore, and as a general rule, the internal sustainability policies should be binding and the relevant processes measurable and transparent.
4. Stewardship : It is good practice to be an active owner and integrate active ownership mechanisms into the asset management process.
5. Transparency: In implementing sustainability criteria, transparency is key, and they should be reported in an explainable, standardised and measurable way.
6. Data Quality: In implementing sustainability criteria, it is crucial to obtain comprehensive data from sources considered reliable and to encourage the continual improvement of data quality.
7. Climate risks: It is essential to assess climate risks along the decision-making process (e.g. investment analysis, investment decisions) and to address them through stewardship (active ownership). Each asset manager is responsible to implement such processes.
8. International Developments: There should be an ongoing commitment to observing international developments on sustainability and aligning business activities with them.
Risk assessment is not limited to traditional risk categories but also covers emerging risks resulting from ESG factors. This means, for example, that factors such as climate change should be integrated into the investment strategy if they could result in material financial risks or are expected to have an impact on performance. This helps the asset manager to avoid risks and identify opportunities linked to sustainability topics that materialise in the medium to long term.
The consideration of such financially relevant sustainability factors is therefore consistent with the asset manager’s obligation to achieve the best possible risk-adjusted return on investment, taking due care and protection of the customer’s interests into account.
An asset manager integrating ESG factors into the investment process may wish to integrate sustainability into their vision and mission, in order to assure alignment between the overall company strategy and the investment strategy. Integrating sustainability into the overall strategy by actively managing ESG topics that are considered relevant for the whole company (e.g. energy and resource consumption, diversity, good governance) contributes to the overall credibility of the sustainable investment strategy. Furthermore, a company expresses conviction, if the assets under its control (e.g. reserves, pension fund assets) are managed in line with the sustainable investment policy, but always subject to the asset manager’s mandate given to him by the asset owner.
Individuals with oversight roles are those with management or governance responsibility for ensuring that the organisation implements its policies and achieves its objectives and targets in relation to sustainable investment performance. Assigning oversight to a person, team or committee should not be seen as a way to compartmentalise ESG responsibility. Instead, the purpose is to ensure accountability for embedding ESG considerations within the organisation and investment processes.
Individuals with implementation roles are those charged with implementing specific aspects of the organisation’s sustainable investment practices. For example, conducting ESG-related research, incorporating ESG issues into investment strategies, voting on shareholdings, or engaging with companies. Implementation of ESG analysis in investment decision-making does not only apply to dedicated sustainability staff but could be a part of any role or activities.
As this is relevant to the manner in which an asset manager oversees its sustainable investment activities, this should include a description of the following items: • The board’s oversight of ESG risks and opportunities, and • The management’s role in assessing and managing ESG risks and opportunities.
In describing the board’s oversight of ESG issues, the asset manager should define and implement the following aspects: • Processes and frequency by which the board and / or board committees (e.g. audit, risk, or other committees) are informed about ESG issues. • Define the organisation’s objectives with regards to ESG and formulate an investment policy that includes its approach with regard to the consideration of ESG risks and opportunities in the investment process. • How the board monitors and oversees progress against goals and targets for addressing ESG issues. • The board’s risk tolerance and policy for overseeing ESG risks and opportunities as well as the role of management in implementing the decisions made by the board concerning the setting up, maintenance and regular review of the internal control system (ICS), including the related controls for overseeing ESG risks. • Keep track of international developments in sustainable finance and in alignment with the business model of the asset manager – adapt to these developments where necessary and useful (e.g. EU regulations in case of providing cross-border services).
In describing executive management’s role related to assessment and management of ESG issues, the asset manager should address the following items: • Assign executive management responsibility for the sustainable investment process (e.g. to a member of the executive management or committee) and define reporting lines. • Description of the associated organisational structure(s) and required resources. • Define appropriate tools to monitor ESG issues.
Once responsibilities are defined, an organisation should make sure relevant employees receive appropriate training to enable them to integrate sustainability factors into the investment process.
Generally, the investment policy contains an overall statement describing the approach of an asset manager to achieve its identified mission. It describes the investment strategy, defines the investment objectives and informs about the investment process, as well as applied standards for performance measurement. The investment policy should also cover the approach to sustainable investments or the way ESG factors are integrated into the investment activities.
Integrating ESG topics into the investment policy demonstrates an asset manager’s recognition of the materiality of ESG factors and the commitment to integrate such factors into the investment process in order to come to informed investment decisions. These factors play a central role when it comes to putting a sustainable investment policy into practice. As part of the investment process, it should be ensured that material ESG risks and opportunities form part of the investment analysis and hence could influence the investment decision. This can be done in many different ways as different ESG factors may be relevant, depending on the context.
The sourcing of reliable and high-quality data is crucial for the successful implementation of ESG factors into an investment process.
An asset manager should define the following: • Objectives: The asset manager’s objectives with regard to the consideration of ESG risks and opportunities and measures taken to achieve these objectives. For example, climate risks being one of the key sustainability topics should be covered by the asset manager’s objectives. In order to contribute to achieving the Paris Climate Agreement, the asset manager should assess climate risks along the decision-making process (e.g. investment analysis, investment decisions) and address them through active engagement. • Data quality and sourcing: The asset manager should define the process to source reliable ESG data and regularly monitor their quality and encourage a continual improvement. • Responsibilities: Who is formally in charge of applying sustainable investment practices. • Process: How ESG information is handled (e.g. from where it is obtained), how it is processed, how controversial ESG issues and ESG risks are addressed and handled (e.g. climate relevance in policy). • External fund managers: How the due diligence process for the ESG approach of external fund managers is designed. • Reporting: How to ensure regular reporting on sustainable investment activities and where to report on them. • Monitoring: How is a regular review of the process and its implementation ensured. • The approach to active ownership: – Description of how / if voting rights are exercised (e.g. regular basis or not) and if they are based on a dedicated policy. – Description of how / if the asset manager actively engages with companies.
The descriptions of §27 should form part of the asset manager’s investment policy. The investment policy should reflect the investment beliefs and convictions of the organisations.
The investment policy or a summary thereof should be published (e.g. via the website).
The investment strategy is a high-level plan which defines how the investment is performed and embeds comprehensive consideration of all long-term trends affecting the portfolio of the asset manager. Through the integration of material sustainability factors into the investment strategy, an asset manager aims to actively manage and monitor material risks and therewith operate as efficiently as possible for the benefit of his clients and other stakeholders.
An asset manager should inform about how it deals with ESG risks and opportunities in its investment process. It informs clients about the factors considered relevant and how they influence respective decision-making. The investment strategy should clarify the company’s general approach(es) applied to its different products and services, and also describe the tools and data used in the organisation.
While the investment strategy should be reasonably generic, the individual product presentations should give a more detailed view of the application of ESG in the respective investment process. The asset manager is expected to apply one of the approaches mentioned below, a combination thereof, or a new approach with similar effects. The objectives of the sustainable investment strategy can vary and usually envisage an improved risk / return profile, an alignment to values and norms and / or a positive contribution to the achievement of a sustainable economy.
If an asset manager claims to have a sustainable investment process in place, it should describe which approach or combination of approaches the process is based on (referring to the different forms of sustainable investing described above) and how the respective approaches are implemented.
The asset manager shall ensure that sufficient internal or external resources are committed to achieve the objectives stated in the investment policy and investment strategy in a meaningful way. An overstatement of measures (“greenwashing”) has to be avoided, while clients should be given a fair and realistic picture of the asset manager’s chosen approach towards ESG.
Sustainability factors should be integrated into the different levels of strategic and tactical asset allocation. On a strategic level, an asset manager might consider taking material sustainability factors into account when defining its target allocation for the various asset classes (e.g. leave aside certain sectors or countries). On a tactical level, sustainability information might influence top-down decisions regarding the attribution to different sectors or markets at a given point in time. Asset managers might also decide to apply ESG factors purely in the bottom-up process, integrating such factors in the assessment of individual portfolio holdings.
There are many different ways of integrating sustainability factors into an investment process. The following approaches are prevalent in the market and serve different needs or motives of different investors. They are not mutually exclusive, and investors usually choose to combine different forms, depending on their motivation. The application of these approaches also varies across different asset classes (e.g. equities, fixed income, alternative investments) or investment styles (e.g. fundamental / quantitative investing, active / passive investing).
The exclusion approach (or negative screening) refers to the deliberate exclusion of issuers from an investment portfolio due to activities or business practices that violate given norms or values – based on client’s preferences – or due to anticipated risks.
The Federal Act on War Material (WMA) of 13 December 199613F14 forms the basis for norms-based exclusions practised by many Swiss investors. It was amended in February 2013 to include provisions on financing in the context of war materials prohibited in Switzerland, e.g. nuclear, biological and chemical weapons, anti-personnel mines and cluster munitions. It prohibits the direct financing of the development, manufacture or acquisition of prohibited war materials (Article 8bWMA). The indirect financing of prohibited war materials is banned only if intended to circumvent the ban on direct financing (Article 8c WMA). It refers to participation in companies that develop, manufacture or acquire prohibited war materials, or the acquisition of debt securities or other investment products issued by such companies. Based on this regulation – and taking current investment practice into account – excluding companies that produce such war materials prohibited in Switzerland is considered a minimum requirement for sustainably managed assets.
This approach prioritises investments in companies with high sustainability standards across different sectors. A company’s or issuer’s ESG performance is compared with the ESG performance of its peers (e.g. of the same sector or industry) based on sustainability research / data. All companies or issuers with a rating above a pre-defined threshold are considered investable. The threshold can be set at different levels (e.g. 30 % best performing companies or all companies that reach a minimum ESG rating). The level of the pre-defined threshold defines the size of the remaining investment universe. Some best-in-class approaches focus on a small share of the total investment universe, while others still define bigger shares of the total universe as investable.
The best-in-class approach can support the focus on companies that have a reduced financial risk due to higher sustainability standards. Asset managers can rely on external sustainability ratings when applying a best-in-class approach, as the preparation of ESG ratings for a large universe is quite resource-intense. Using ESG benchmarks that are based on a best-in-class approach can also help an asset manager to implement such a strategy.
ESG integration refers to the inclusion of ESG risks and opportunities in the traditional financial analysis and investment decision based on a systematic process and on appropriate research sources. The idea is to get a holistic view of a specific issuer of securities. There are different forms of how ESG factors can be integrated into the financial analysis or the investment decision. Sustainability information can be used to adapt estimates of future cash-flows or it can lead to adjusted discount rates, to name just two examples. Usually, ESG factors are only integrated into the investment decision if they are expected to be financially material. Hence, a company with a low sustainability performance in some areas might still be considered an interesting investment, as long as the expected financial risk / return of an investment remains attractive. This is a major difference to the best-in-class approach, where a minimum sustainability standard is defined for each investment.
The terms stewardship or active ownership are often used to refer to a combination of engagement and voting. In practice, asset managers either combine the two approaches or focus on one of them.
This term refers to investors addressing concerns about ESG issues by actively exercising their voting rights based on ESG principles or an ESG policy. Investors might choose to reject a certain proposal at the Annual General Meeting (AGM) based on the fact that it is not in line with their overall ESG policy. Many of the AGM agenda points do not directly refer to environmental or social topics, but rather to governance aspects. In some cases, investors therefore chose to indirectly express their discontent with a sustainability strategy by voting against other agenda items (e.g. blocking the re-election of certain board members who do not support the company’s progressive ESG strategy).
An asset manager can establish their own voting policy covering the aspects perceived as relevant for the organisation (e.g. renumeration standards, governance structures, diversity) or act on the advice of external, specialised providers.
A structured engagement process defines clear engagement targets with a clear timeframe and reports on outcomes such as changes in a company’s strategy and processes so as to improve ESG performance and reduce financial risks.
There are different forms and levels of engagement: • In the case of direct company engagement, each investor holds an individual dialogue on ESG aspects with companies. Such engagements are often carried out by analysts or portfolio managers that hold a dialogue with senior management and / or boards of the companies they invest in. • In a collaborative engagement process, different investors team up to bundle their forces and investor power in the dialogue with companies or when co-filing shareholder proposals. The PRI (Principles for Responsible Investment) offers a “Collaborative Platform” on which investors can post initiatives and look for allies for their engagement processes. Some collaborative engagement processes are formalised into separate organisations (e.g. Climate Action 100+, The Institutional Investors Group on Climate Change IIGCC). • A third form of engagement is public policy engagement, where investors lobby politicians for improved frameworks for a sustainable economy (e.g. calling for a carbon tax).
Investors might choose to outsource the engagement process to a service provider that pools the interests of different investors and thereby carries more weight in the dialogue with the companies. An asset manager can establish their own engagement policy covering the aspects perceived as relevant for the organisation or rely on an engagement policy of a respective service provider. The engagement policy should also address the escalation process foreseen in case an engagement is not successful.
Sustainable thematic investments refer to investment in businesses contributing to sustainable solutions both in the environmental and / or social dimension. In the environmental segment, this could include investments in renewable energy, energy efficiency, clean technology, low-carbon transportation infrastructure, water treatment and / or resource efficiency. In the social segment, this includes investments in education, health systems, poverty reduction and / or solutions for an ageing society.
Impact investments intend to generate a measurable, beneficial social and / or environmental impact alongside a financial return. Important differentiating factors to other forms of sustainable investments (namely thematic investing) are the intentionality of an investment in a sector or activity that has such a positive impact, the management process that allows for a direct impact, and the measurability of the impact through relevant Key Performance Indicators (KPIs). Impact investments can be made in both emerging and developed markets and target a range of returns from below-market to above-market rates, depending upon the circumstances.
If an asset manager claims to provide impact investment products, regular reporting is crucial for the intention, the respective management processes and the achieved impact, based on relevant KPIs.
An effective implementation of a sustainable investment policy requires continuous monitoring of the process. Specific sustainability KPIs are the basis for such monitoring. Usually, such KPIs – e.g. sustainability ratings provided by an external provider or internally prepared KPIs – are integrated into the portfolio management and reporting system. This allows for tracking specific sustainability indicators (e.g. average sustainability rating of a portfolio) or the violation of a defined policy (e.g. black-listed company appears in a portfolio). The evolution of the sustainability KPIs can be made a mandatory agenda item at portfolio management or risk management meetings. Furthermore, such KPIs can be integrated into personal objectives of relevant staff. The asset manager should describe how the process of ESG implementation (chapter 1.6.2) is managed, ensured and monitored. He also defines management responsibilities for the monitoring process. The asset manager ensures that it has allocated sufficient resources that allow for proper monitoring of the investment process. The portfolio should be tested against the pre-defined sustainability KPIs regularly, e.g. once a year.
Based on the SFAMA Specialist Recommendation on Risk Management, asset managers should integrate sustainability risks and opportunities into their existing risk management processes for identifying such risks and opportunities. They should also define how they identify, assess and manage sustainability risks and opportunities for each product or investment strategy. This might include a description of the resources and tools used in the process.
Based on SFAMA’s Specialist Recommendation on Risk Management regarding the creation of a risk profile for a collective investment scheme or an asset management mandate, ESG risks and the approach to manage them at product level should be documented in the risk profile.
Both institutional and private clients increasingly expect to be informed on a regular basis about the implementation of the sustainable investment policy including the data used. There are different forms for asset managers to provide this transparency and keep their clients informed. Building on existing frameworks that make recommendations for sustainable investment reporting may help to increase comparability for clients.
Asset managers should inform their clients about the sustainability performance of a given product by integrating relevant ESG Key Performance Indicators and / or additional information on relevant developments (e.g. ESG reasons behind major investments / divestments) into their client communication (e.g. in the product factsheet and / or through separate communications tools).
The asset manager has to ensure that he has access to data and has the right tools in place that allow for appropriate reporting on the sustainability performance of its portfolios. It should be possible to provide clients with the necessary information to make an objective assessment of the asset manager’s goals and outcomes.
Approach in which a company’s or issuer’s environmental, social and governance (ESG) performance is compared with that of its peers (e.g.in the same sector or category) based on a sustainability rating. All companies or issuers with a rating above a defined threshold are considered investable. The threshold can be set at different levels (e.g. 30% best performing companies or all companies that reach a minimum ESG score).
Conditional exclusions of companies based on negative business practices, such as breaches of certain norms, regulations or global ESG standards (often referred to as norms-based exclusions, e.g. systematic violation of human rights).
Engagement is an activity performed by investors (typically shareholders or bondholders) with the goal of convincing management to take account of environmental, social and governance criteria. This dialogue includes communicating with senior management and / or boards of companies and filing or co-filing shareholder proposals. Successful engagement can lead to changes in a company’s strategy and processes so as to improve ESG performance and reduce risks. Such engagement can be performed as direct interaction between an investor and an investee company or in the form of collaborative engagement, where a number of investors team up to hold a joint dialogue (often carried out by a respective service provider)
ESG stands for Environmental (e.g. energy consumption, water usage), Social (e.g. talent attraction, supply chain management) and Governance (e.g. remuneration policies, board oversight). ESG factors form the basis for the different SI approaches
Such an analysis includes collecting information on how an investment target manages and performs on environmental, social and governance factors. When an investment institution wishes to track to what extent potential investments (e.g. companies, countries and issuers) are exposed to ESG risks and opportunities and how they actively manage them, they carry out an ESG Analysis
The explicit inclusion by investors of ESG risks and opportunities in traditional financial analysis and investment decisions based on a systematic process and appropriate research sources
An approach excluding companies, countries or other issuers based on activities considered not investable. Exclusion criteria (based on norms and values) can refer to product categories (e.g. weapons, tobacco), activities (e.g. animal testing), or business practices (e.g. severe violation of human rights, corruption)
Investments intended to generate a measurable, beneficial real-world social and environmental impact alongside a financial return. Impact investments can be made in both emerging and developed markets and target a range of returns from below-market to above-market rates, depending upon the circumstances
Individuals with implementation roles are those charged with implementing specific aspects of the organisation’s sustainable investment practices.
Individuals with oversight roles are those with management or governance responsibility for ensuring that the organisation implements its policies and achieves its objectives and targets in relation to sustainable investment performance.
Responsible investment (analogous to sustainable investment) refers to any investment approach integrating environmental, social and governance factors (ESG) into the selection and management of investments. There are many different forms of responsible investing, such as best-in-class investments, ESG integration, exclusionary screening, thematic investing and impact investing. They are all components of responsible investments and have played a part in its history and evolution.
The terms stewardship or active ownership are often used to refer to a combination of engagement and voting. In practice, asset managers either combine the two approaches or focus on one of them.
Ratings reflecting how a company / country / fund manages and / or performs with regards to environmental, social and governance (ESG) factors. Sustainability ratings give investors a snapshot of the sustainability performance of a company / country / fund and are the basis for many sustainable investment approaches.
Sustainable Development Goals
The SDGs are 17 goals set by the UN in 2015 to be achieved by 2030, aiming to catalyse sustainable development. They include goals such as no poverty, gender equality, decent work, sustainable consumption, climate action and reduced inequalities. The goals were developed to replace the Millennium Development Goals (MDGs) which ended in 2015. Unlike the MDGs, the SDG framework does not distinguish between “developed” and “developing” nations.
Sustainable finance refers to any form of financial service integrating environmental, social and governance (ESG) criteria into the business or investment decisions for the lasting benefit of both clients and society at large. Activities that fall under the heading of sustainable finance include (but are not limited to) the integration of ESG criteria into asset management, sustainable thematic investments, active ownership, impact investing, green bonds, lending with ESG risk assessment and the development of the whole financial system in a more sustainable way.
Investment in businesses contributing to sustainable solutions both in an environmental or social dimension. In the environmental segment this includes investments in renewable energy, energy efficiency, clean technology, low-carbon transportation infrastructure, water treatment and resource efficiency. In the social segment this includes investments in education, health systems, poverty reduction and solutions for an ageing society.
Unconditional exclusions of products or business activities incompatible with the investor’s values (often referred to as values-based exclusions, e.g. exclusions of weapon manufacturers) or leading to excessive risks (e.g. coal mining).
This refers to investors addressing concerns about environmental, social and governance (ESG) issues by actively exercising their voting rights based on ESG principles.