OLD MUTUAL INVESTMENT GROUP RESPONSIBLE OWNERSHIP GUIDELINES
|
|
- Randall McKinney
- 5 years ago
- Views:
Transcription
1 RESPONSIBLE INVESTMENT POSITIVE FUTURES OLD MUTUAL INVESTMENT GROUP RESPONSIBLE OWNERSHIP GUIDELINES First published: JULY 2012 Latest update: JANUARY
2 TABLE OF CONTENTS 1. INTRODUCTION 1 2. OLD MUTUAL INVESTMENT GROUP S APPROACH TO RESPONSIBLE OWNERSHIP Introduction Governance of responsible ownership practices Listed-equity proxy voting and scrip lending Approach to management engagement and collaboration Promoting and protecting shareholder rights Conflicts of interest Disclosure and transparency 3 3. OLD MUTUAL INVESTMENT GROUP S EXPECTATIONS OF THE GOVERNANCE PRACTICES OF INVESTEE COMPANIES Introduction Company internal controls and risk management Processes Review and evaluation Board statement Relationship with shareholders Communication and disclosure Consistent treatment within classes Institutional shareholders Dialogue Evaluation of governance disclosures Stakeholder obligations Transformation Social, ethical, safety, health and environmental issues HIV/AIDS Black economic empowerment HR retention and development 6
3 1. INTRODUCTION These Responsible Ownership Guidelines (Guidelines) set out the Old Mutual Investment Group s approach to responsible ownership. The Guidelines build on the responsible ownership aspects of the Old Mutual Responsible Investment Guidelines, which state: Old Mutual Investment Group takes its responsibility as a shareholder seriously; as a result, we aim to ensure that the management teams of investee companies are accountable for company performance and conduct. We will act as a responsible steward of assets on behalf of our policy holders, clients and shareholders by: maintaining a copy of our Listed-Equity Proxy Voting Policy on our website; voting all proxies in a manner consistent with our Proxy Voting Policy and specific client guidelines; publishing the votes on our website; working with other co-investors regarding material environment, social and governance (ESG) issues at investee companies, being mindful of acting in concert; and reviewing and updating our proxy voting policy annually as required. Further to this, we will manage potential conflicts of interests through our existing conflict of interest management processes. Old Mutual Investment Group s Responsible Investment and Responsible Ownership guidelines and Proxy Voting Policy are reviewed and, if needed, updated annually, and are publically available on These Guidelines are applicable across all of Old Mutual Investment Group s investment boutiques, recognising: The unique value proposition of each boutique, the different asset classes and the independent nature of their investment styles. The mandated responsibility of the boutiques to pursue superior risk-adjusted returns on behalf of their clients. The document is structured as follows: Section 2: Presents an overview of Old Mutual Investment Group s approach to responsible ownership Section 3: Old Mutual Investment Group s expectations of the governance practices of investee companies 2. OLD MUTUAL INVESTMENT GROUP S APPROACH TO RESPONSIBLE OWNERSHIP 2.1 INTRODUCTION As a responsible investment manager, Old Mutual Investment Group s primary aim is to ensure the achievement of superior risk-adjusted returns in line with our client mandates. We recognise that confidence in the integrity and quality of management is essential to long-term value creation and investor confidence. Old Mutual Investment Group aims to contribute to investment performance by supporting the application of the highest standards of corporate governance in the investments we make on behalf of our clients. Our approach to responsible ownership practices draws on aspects of the King III Code on Corporate Governance; the governance provisions in the South African Companies Act 71 of 2008; the listing requirements of the JSE, and the Code for Responsible Investment South Africa (CRISA); as well as international guidelines such as the OECD Corporate Governance Principles (2004); the ICGN Statement on Global Corporate Governance Principles (2005); and the Association of British Insurers Guidelines, the the United Nations-supported Principles for Responsible Investing (PRI). 1
4 2.2 GOVERNANCE OF RESPONSIBLE OWNERSHIP PRACTICES Old Mutual Investment Group s responsible ownership practices are given effect through Old Mutual Investment Group s Responsible Investment Team, which consists of five members, namely, the Head of Responsible Investment, an ESG Analyst/Programme Manager, an ESG Engagement Manager, an ESG Research and Systems Analyst, and a Marketing and Communications Specialist. The Team is formally mandated to co-ordinate the Group s approach to responsible investment and supports Old Mutual Investment Group s boutiques in their responsible ownership practices. In order to ensure that these Guidelines are given effect across the organisation, and to ensure continuous improvement, we undertake an internal annual review of the application of the proxy voting process and policy. 2.3 LISTED-EQUITY PROXY VOTING AND SCRIP LENDING Old Mutual Investment Group commits to vote on all listed-equity shares. Our proxy voting is guided by our Proxy Voting Policy which is publically available online, along with our proxy voting records. Old Mutual Investment Group understands that scrip lending is an important feature of the market and that it has the potential to improve market liquidity, reduce trading risks and provide an additional return to its clients. We also note that scrip lending can increase share price volatility, and that speculation and can distort the outcome of shareholder votes. As a result, Old Mutual Investment Group will work towards the application of the International Corporate Governance Network Securities Lending Code of Best Practice. The key elements of this code of best practice include: ensuring that we retain the right to recall script for voting purposes; guidance on when script will be recalled for voting purposes; recalling scrip to vote on material issues; and ensuring transparency in scrip-lending practices and in providing disclosure to clients. 2.4 PROMOTING AND PROTECTING SHAREHOLDER RIGHTS Old Mutual Investment Group s investment teams meet regularly with company management on operational and company-specific issues, as well as on issues related to governance performance. Old Mutual Investment Group prefers not to take a public route when seeking change at companies. Our preference is to constructively engage with Boards and management in a non-public manner to achieve positive change. However, where no progress is made over an extended time period, Old Mutual Investment Group may, as a last resort, use the press and other public forums to drive change. We will normally notify a company in advance of briefing the media before taking this approach. Where we believe it will be in the best interests of our clients, and where we have exhausted our engagement with management, we will seek out opportunities to collaborate with co-investors on material issues as a means to drive change. Where such collaborative efforts are undertaken, we will ensure that conflicts of interest and issues relating to acting in concert are appropriately addressed. Old Mutual Investment Group s approach to engagement and collaboration is overseen by the Responsible Ownership Working Group in order to ensure a consistent approach. 2.5 PROMOTING AND PROTECTING SHAREHOLDER RIGHTS Old Mutual Investment Group will seek out opportunities to promote and protect shareholder rights through the participation and development of policy, regulation, and standards governing our investments. 2
5 2.6 CONFLICTS OF INTEREST Old Mutual Investment Group is mindful that conflicts of interests may occur in the course of our work. We define a conflict of interest as follows: A conflict of interest arises when an actual or a potential interest may influence you to not act fairly, independently and objectively towards your customer. Old Mutual Investment Group has implemented a Conflict of Interest Management Policy, which is publically available on The purpose of the Policy is to set out the parameters for managing any conflicts of interest that may arise in the rendering of financial services to customers. The Policy is applicable to all of Old Mutual Investment Group and all of its employees, and is reviewed annually, or as and when a need arises. The Policy was approved by Old Mutual Investment Group s Board of Directors, and any major amendments will require Board approval. In addition, the Policy is compliant with the requirements of the Financial Advisory and Intermediary Services Act (FAIS). Conflicts of interest manifest in a number of ways in the asset management industry. Once a conflict is identified, we either avoid such conflicts or mitigate it. We have identified key conflicts within our business, which we monitor in a number of ways. These include: A Personal Account Trading Policy is in place and processes are set to monitor such activity and mitigate the conflict. A Giving and Receiving Gifts and Benefits Policy governs the giving and receipt of gifts, along with a gift register. In addition, we have implemented a conflict of interest disclosure requirement in a number of our committees and processes as well as a Conflict of Interest register. Lastly, the Conflict of Interest Management Policy forms part of the Old Mutual Investment Group Code of Conduct, which is contained in employment contracts and is re-accepted annually by all employees. 2.7 DISCLOSURE AND TRANSPARENCY These Guidelines are available on our website, along with our Responsible Investment Guidelines, the Proxy Voting Policy and our CRISA Disclosure. This disclosure on Old Mutual Investment Group s responsible ownership practices is done on an annual basis, and forms part of Old Mutual Group s Annual Report. 3. OLD MUTUAL INVESTMENT GROUP S EXPECTATIONS OF THE GOVERNANCE PRACTICES OF INVESTEE COMPANIES 3.1 INTRODUCTION This section provides an overview of Old Mutual Investment Group s expectations of the governance practices of investee companies. By addressing these issues, Old Mutual Investment Group aims to gain a better understanding of the risk culture of the organisation and the quality of its governance practices. Old Mutual Investment Group will use these positioning statements as a means of guiding our engagement with the management of investee companies regarding their governance practices. 3.2 COMPANY INTERNAL CONTROLS AND RISK MANAGEMENT Processes The Board of a company should maintain a sound system of internal control to safeguard shareholders investments, the concerns of key stakeholders and the company s assets. Line management must be responsible for designing, implementing and monitoring the process of risk management on a daily basis. The internal audit function assesses the adequacy and effectiveness of line management s process and must report accordingly, which shall include suggestions for corrective action where necessary. 3
6 3.2.2 Review and evaluation The Board should, at least annually, conduct a review of the effectiveness of the company s system of internal controls and should report to shareholders that they have done so. The review should cover all material controls, including financial, operational and compliance controls and risk management systems Board statement The Board should present their internal control process to shareholders and furnish a statement regarding the results of their review of the company s system of internal controls. 3.3 RELATIONSHIP WITH SHAREHOLDERS Communication and disclosure It is a company s Board that is responsible for reporting on significant and relevant matters in a balanced and understandable manner. Directors reports should be transparent, reflect accountability, and be objective and transparent. Directors reports should contain a balance between positive and negative reporting of results to ensure a full, fair and honest account of a company s performance. More specifically, directors reports should contain the following: the directors responsibility to report fairly; an auditor s report on the financial statements of a company; a statement that adequate accounting records are kept, that there is an appropriate internal control procedure, and that a risk management strategy is in place and operational; a statement that consistent and appropriate accounting policies are in place and that prudent judgements have been applied; a statement that accounting standards were followed and, where applicable, departures from these standards must be quantified and explained; a statement that there is no reason to believe that a company will not be a going concern in the year ahead; a statement that a code of corporate governance and conduct is followed; and a statement regarding the manner in which the key material non-financial risks and opportunities have been assessed and integrated into the business strategy and performance management. The company must ensure that there is a fair publication of information from the company in order to keep instances of uneven disclosures of material information to a minimum Consistent treatment within classes The principles of communication and disclosure must apply equally to shareholders within the same class of shareholding. 3.4 INSTITUTIONAL SHAREHOLDERS Dialogue The Board of a company has the responsibility to ensure that a satisfactory dialogue with shareholders takes place, based on the mutual understanding of objectives. While recognising that most shareholder contact is with the Chief Executive Officer (CEO) and Financial Director (FD), the Chairperson (and the senior independent director and other directors as appropriate) should maintain sufficient contact with major shareholders to understand their issues and concerns. The CEO or FD should ensure that the views of shareholders are communicated to the Board. The Chairperson should be willing to discuss governance and strategy with shareholders. Non-executive directors should be offered the opportunity to attend meetings with major shareholders and should be expect to attend them if requested by major shareholders. 4
7 The senior independent director should attend sufficient meetings with a range of major shareholders to listen to their views in order to help develop a balanced understanding of the issues and concerns of major shareholders. The Board should state in the annual report the steps they have taken to ensure that the members of the Board, and in particular the non-executive directors, develop an understanding of the views of major shareholders about their company, for example through direct face-to-face contact, analyst or broker briefings and surveys of shareholder opinion. The Board should use the annual general meeting (AGM) to communicate with investors and to encourage their participation. The company should count all proxy votes and should indicate the level of proxies lodged on each resolution, and the balance for and against the resolution and the number of abstentions after it has been dealt with by means of a poll. The company should ensure that votes cast are properly received and recorded. Old Mutual Investment Group should request voting by poll where it is of the opinion that to do so would be in its clients best interests. The company should propose a separate resolution at the AGM on each substantially separate issue and should in particular propose a resolution at the AGM relating to the report and accounts. The Chairperson should arrange for the chairpersons of the Audit, Remuneration and Nomination committees to be available to answer questions at the AGM and for all directors to attend. The company should arrange for the Notice of the AGM and related papers to be sent to shareholders at least 21 days before the meeting Evaluation of governance disclosures When evaluating companies governance arrangements, particularly those relating to Board structure and composition, Old Mutual Investment Group gives due weight to all relevant factors drawn to its attention. Old Mutual Investment Group will carefully consider explanations given for departure from a company s code of corporate governance and makes reasoned judgements in each case. Old Mutual Investment Group will give an explanation to the company, in writing where appropriate, and be prepared to enter into a dialogue if they do not agree with the company s position. Old Mutual Investment Group will avoid a box-ticking approach to assessing a company s corporate governance and will consider the substance and application corporate governance practices Old Mutual Investment Group bears in mind, in particular, the size and complexity of the company and the nature of the risks and challenges it faces Stakeholder obligations Reporting to stakeholders requires an integrated approach whereby issues are categorised at various reporting levels, namely, matters that arise from a company s reporting to stakeholders, the implementation of practices and the steps taken to implement changes, and a demonstration of the benefits of changes made. A company s Board should guide and approve the necessary stakeholder policy, strategy and structure, including the establishment of adequate and effective systems of internal control. The company secretary should provide the company s directors with guidance as to its obligations to stakeholders. Non-financial information should be represented as reliable, relevant, clear and unambiguous, verifiable and comparable over time. Guidelines for materiality should be developed to ensure consistent reporting. Old Mutual Investment Group supports the application of the Global Reporting Initiative (GRI) framework for non-financial disclosure Transformation A company should have in place specific policies and procedures that encourage a diversified workforce at all levels within the organisation. Specifically, a company should make a commitment to the principles contained in the Employment Equity Act and those principles should be regularly enforced throughout the organisation. Progress on transformation should be reported regularly to all stakeholders and also included in the company s annual report. The disclosure should be on the basis of a balanced score card in line with conditions stipulated in the Employment Equity Act. 5
8 3.4.5 Social, ethical, safety, health and environmental issues A company should demonstrate how it has integrated material social, environmental, safety and health risks and opportunities into its approach to business strategy and performance management. Public disclosure must be made on an annual basis regarding progress and performance with regard to material sustainability issues. This may be in the form of a stand-alone sustainability report or by way of the company s integrated annual report. Old Mutual Investment Group supports companies making use of third-party auditors to provide assurance on key sustainability performance metrics. With regard to this, Old Mutual Investment Group supports the use of the GRI reporting standards for disclosure purposes. A company should commit to a social investment outreach programme and ensure that it is supported, both financially and by employee involvement. A code of ethics should be developed to guide a company s relationship with its stakeholders; commitment to the code should be indicated by the development of procedures to implement, monitor and enforce the code of ethics at a high level, by assessing a candidate s integrity when promoting, and by conducting training on a company s ethical values. Directors reports should include references to this commitment. A company s relationship with other entities with a lower ethical commitment should be re-evaluated. A company should commit to enforcing South African occupational health and safety legislation, which prescribes that employers must provide and maintain a safe and healthy, low-risk working environment. In terms of environmental legislation, there is a duty on a company and its Board to not engage in business practices that result in significant pollution and/or environmental degradation. A company should show this commitment in its financial reporting, as well as ensure that it enters into business relationships with other entities that uphold this commitment HIV/AIDS In terms of the Employment Equity Act, every company must have an HIV/AIDS policy and an implementation programme. A company s Board should adopt the appropriate strategy, plan and policies to address and manage the potential impact of HIV/AIDS on the company and its employees. Furthermore, performance should be regularly measured using established indicators and progress should be reported to stakeholders Broad-based black economic empowerment A company should commit to ensuring that it makes a significant contribution to broad-based black economic empowerment (BBBEE) and that it adopts initiatives that will advance historically disadvantaged people on a large scale. A company should integrate its BBEEE strategy with its overall strategy for the organisation HR retention and development A company should implement a programme of human capital development by monitoring and addressing the number of staff within the organisation, the progression towards employment equity targets, the provision of training that will increase employees competency and also providing opportunities for women, previously disadvantaged and disabled individuals. These Responsible Ownership Guidelines, along with Old Mutual Investment Group s Responsible Investment Guidelines, Proxy Voting Policy and CRISA Disclosure, are available on Old Mutual Investment Group (Pty) Limited (FSP 604) and Old Mutual Customised Solutions (FSP721) are a licensed financial services providers, approved by the Registrar of Financial Services Providers ( to provide intermediary services and advice in terms of the Financial Advisory and Intermediary Services Act 37 of Old Mutual Investment Group and Old Mutual Customised Solutions (Reg No 200/028675/07 are wholly owned subsidiaries of Old Mutual (Emerging Markets) Limited. Old Mutual Investment Group (Pty) Limited (FSP 604) and Old Mutual Customised Solutions (FSP721) are a licensed financial services providers, approved by the Registrar of Financial Services Providers ( to provide intermediary services and advice in terms of the Financial Advisory and Intermediary Services Act 37 of Old Mutual Investment Group (Reg No 1993/003023/07) and Old Mutual Customised Solutions (Reg No 200/028675/07 are wholly owned subsidiaries of Old Mutual (Emerging Markets) Limited. The following entities are licensed Financial Services Providers (FSPs) within Old Mutual Investment Group (Pty) Ltd Holdings approved by the Registrar of Financial Services Providers ( to provide advisory and/or intermediary services in terms of the Financial Advisory and Intermediary Services Act 37 of These entities are wholly owned subsidiaries of Old Mutual Investment Group Holdings (Pty) Ltd and are members of the Old Mutual Investment Group. Old Mutual Investment Group (Pty) Ltd (Reg No 1993/003023/07), FSP No:604. Old Mutual Customised Solutions (Pty) Ltd (Reg No 200/028675/07, FSP No:721. Old Mutual Alternative Investments (Pty) Ltd (Reg No 2013/113833/07), FSP No: African Infrastructure Investment Managers (Pty) Ltd (Reg No 2005/028675/07), FSP No:4307. Futuregrowth Asset Management (Pty) Ltd (Reg No 1996/18222/07), FSP No:520. Marriott Asset Management (Reg No 1987/03316/07), FSP No: 592. Old Mutual Property (Pty) Ltd (Reg No 1996/011259/07), FSP No: 817.
OLD MUTUAL INVESTMENT GROUP LISTED-EQUITY PROXY VOTING POLICY
RESPONSIBLE INVESTMENT POSITIVE FUTURES OLD MUTUAL INVESTMENT GROUP LISTED-EQUITY PROXY VOTING POLICY JANUARY 2016 TABLE OF CONTENTS 1. INTRODUCTION 1 2. OLD MUTUAL INVESTMENT GROUP S APPROACH TO PROXY
More informationCCLA s Statement in Response to the UK Stewardship Code
CCLA s Statement in Response to the UK Stewardship Code The Stewardship Code aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to
More informationENVIRONMENTAL SOCIAL GOVERNANCE (ESG) POLICY INTRODUCTION
ENVIRONMENTAL SOCIAL GOVERNANCE (ESG) POLICY INTRODUCTION As long-term stewards of our clients capital, Coronation is focussed on the long-term prospects of the assets in which we invest on our clients
More informationPrinciple 1: Ethical standards
Proposed updated NZX Code Principle 1: Ethical standards Directors should set high standards of ethical behaviour, model this behaviour and hold management accountable for delivering these standards throughout
More informationNovember 2016 LGIM Response to UK Stewardship Code Principles. UK Stewardship Code LGIM Response to UK Stewardship Code Principles
UK Stewardship Code LGIM Response to UK Stewardship Code Principles Introduction At LGIM we take our stewardship responsibilities seriously and devote significant resource to ensure our clients assets
More information2018 LGIM Response to UK Stewardship Code Principles. UK Stewardship Code LGIM Response to UK Stewardship Code Principles
UK Stewardship Code LGIM Response to UK Stewardship Code Principles Introduction At LGIM we take our stewardship responsibilities seriously and devote significant resource to ensure our clients assets
More informationAdrian Bertrand Principles for Responsible Investment. Responsible Investment
Adrian Bertrand Principles for Responsible Investment Responsible Investment An investor initiative in partnership with Responsible Investment 31 August 2016 - R E S P O N S I B L E I N V E S T M E N T
More informationStatement of Compliance with UK Stewardship Code
Statement of Compliance with UK Stewardship Code May 2017 Staffordshire Pension Fund Statement of compliance with the UK Stewardship Code (Published May 2017) Introduction The Staffordshire Pension Fund
More informationInstitutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities.
BP Investment Management Limited ( BPIM ) Stewardship Policy BP Investment Management Limited ( BPIM ), a wholly owned investment management subsidiary of BP Pension Trustees Ltd, manages certain assets
More informationResponsible Investment Policy
Responsible Investment Policy This Responsible Investment Policy details the approach that BCPP will follow in fulfilling its commitment to the partner funds in the delegation of RI and stewardship responsibilities.
More informationStewardship Statement
Rathbone Unit Trust Management Contact us 020 7399 0399 rutm@rathbones.com Stewardship Statement October 2016 About us Rathbone Unit Trust Management is a leading UK fund manager. We are an active management
More informationThe UK Stewardship Code
The UK Stewardship Code Principle 1 Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities. The Stewardship Code (the Code ) is a UK
More informationJune The annexure includes a key to where our corporate governance disclosures can be located.
Appendix 4G Key to Disclosures Corporate Governance Council Principles and Recommendations Name of entity: Black Rock Mining Limited ABN / ARBN: Financial year ended: 59 094 551 336 30 June 2018 Our corporate
More informationOverview 02. SIM broadens its investment responsibilities 03. Categories of resolutions declined. 04
SIM Responsible Investment Report December 2017 Contents Overview 02 SIM broadens its investment responsibilities 03 Categories of resolutions declined. 04 Categories of remuneration-related resolutions
More informationPrinciple 1 Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities
LOCAL PENSIONS PARTNERSHIP Statement of Compliance with the UK Stewardship Code Introduction Local Pensions Partnership Ltd (LPP) is a pension services provider for public sector pension funds. Our aim
More informationSIM Responsible Investment Policies and Procedures Document
SIM Responsible Investment Policies and Procedures Document September 2016 Index 1. Governance Policy (G) 1.1 Overview p 2 1.2 Governance Policy 4 1.3 Proxy voting guidelines 12 1.4 Escalations 16 1.5
More informationWest Midlands Pension Fund. Responsible Investment Framework 2015
West Midlands Pension Fund Responsible Investment Framework 2015 June 2015 Responsible Investment Framework 2015 1) Introduction This framework defines the commitment of West Midlands Pension Fund ( the
More informationAustralian Unity Office Fund
Australian Unity Office Fund 18 September 2018 Corporate Governance Statement Issued by: Australian Unity Investment Real Estate Limited ( Responsible Entity ) ABN 86 606 414 368, AFS Licence No. 477434
More informationElectus Fund Managers. Responsible Investing and Proxy Voting Policy
Electus Fund Managers Responsible Investing and Proxy Voting Policy Contents 1. INTRODUCTION... 4 2. ELECTUS APPROACH TO PROXY VOTING... 4 2.1. INTRODUCTION... 4 2.2. INCORPORATING RESPONSIBLE INVESTING
More informationThe Code s Seven Principles, and how and to what extent CIC Capital Fund Ltd incorporates them into our investment process, are described below.
UK Stewardship Code This statement sets out how CIC Capital Fund Ltd. applies the principles of the UK Stewardship Code. CIC Capital Fund Ltd Is a Canadian public close-ended fund with investee company
More informationCREATING VALUE FOR SHAREHOLDERS: THE ROLE OF THE BOARD IN ORGANIZATIONAL PERFORMANCE
CREATING VALUE FOR SHAREHOLDERS: THE ROLE OF THE BOARD IN ORGANIZATIONAL PERFORMANCE INSTITUTE OF CERTIFIED PUBLIC ACCOUNTANTS OF KENYA 4 TH ANNUAL GOVERNANCE & ETHICS CONFERENCE MR. PAUL MUTHAURA, Ag.
More informationProposed Revision to the UK Stewardship Code Annex A - Revised UK Stewardship Code
Consultation Financial Reporting Council January 2019 Proposed Revision to the UK Stewardship Code Annex A - Revised UK Stewardship Code The FRC s mission is to promote transparency and integrity in business
More informationNedgroup Investments Proxy Voting Guidelines
Nedgroup Investments Proxy Voting Guidelines Introduction This Policy sets out Nedgroup Investments guidelines for the voting of shareholder resolutions as they pertain to listed equity. Stakeholders should
More informationStewardship Code Compliance Statement
Stewardship Code Compliance Statement Principle 1 Institutional investors should publicly disclose their policy on how they will discharge their stewardship responsibilities. The Henderson investment approach
More informationCONFLICTS OF INTEREST MANAGEMENT POLICY ( THE POLICY )
CONFLICTS OF INTEREST MANAGEMENT POLICY ( THE POLICY ) Policy Control Version 4 Update of Legal Structure Effective date of Implementation 22 February 2012 Policy Owner Reviewed Investment Group Head:
More informationeastsussex.gov.uk UK Stewardship Code Statement
eastsussex.gov.uk UK Stewardship Code Statement November 2018 Introduction The East Sussex Pension Fund (the Fund) recognises that Environmental, Social and Corporate Governance ( ESG ) issues can have
More informationUK Stewardship Code Statement
UK Stewardship Code Statement Asset managers that are authorised by the Financial Conduct Authority (the FCA ) are required under the FCA s Conduct of Business Rules to produce a statement of commitment
More informationLONG TERM SHAREHOLDER ENGAGEMENT AND CORPORATE GOVERNANCE Not For Distribution
LONG TERM SHAREHOLDER ENGAGEMENT AND CORPORATE GOVERNANCE Not For Distribution Changes from JURI Committee Text to EP Plenary Voted Text Text provisions to pay attention to European Commission proposal
More informationASX LISTING RULES Guidance Note 9
ASX LISTING RULES DISCLOSURE OF CORPORATE GOVERNANCE PRACTICES The purpose of this Guidance Note The main points it covers To assist listed entities to comply with the disclosure and other requirements
More informationA GUIDE FOR SUPERANNUATION TRUSTEES to monitor listed Australian companies
A C S I G O V E R N A N C E G U I D E L I N E S May 2009 May 2009 A GUIDE FOR SUPERANNUATION TRUSTEES to monitor listed Australian companies J U L Y 2 0 1 1 A guide for superannuation trustees to monitor
More informationESG AND RESPONSIBLE INVESTMENT PHILOSOPHY
ESG AND RESPONSIBLE INVESTMENT PHILOSOPHY February 2017 AMP CAPITAL ESG AND RESPONSIBLE INVESTMENT PHILOSOPHY 1 AMP Capital is one of Asia Pacific s largest investment managers. We have a single goal in
More informationDIRECTIVE PF NO. XXX FINANCIAL SERVICES BOARD PENSION FUNDS ACT, 1956 SUSTAINABILITY REPORTING AND DISCLOSURE REQUIREMENTS
DIRECTIVE PF NO. XXX FINANCIAL SERVICES BOARD PENSION FUNDS ACT, 1956 SUSTAINABILITY REPORTING AND DISCLOSURE REQUIREMENTS I, Dube Phineas Tshidi, Registrar of Pension Funds, hereby, in terms of regulation
More informationMyners Principles - Application Principle Best Practice Guidance (CIPFA) Havering Position/Compliance
1. Effective decision-making Administrating authorities should ensure that : (a) Decisions are taken by persons or organisations with the skills, knowledge, advice and resources necessary to make them
More informationGOVERNANCE AND REMUNERATION REVIEW
44 GOVERNANCE AND REMUNERATION REVIEW This section of the report presents the corporate governance and remuneration practices of the group for the reporting period. This year, key governance tasks have
More informationEnvironmental, Social and Governance (ESG)
Environmental, Social and Governance (ESG) Sustainable and Responsible Investment Policy for ODIN FORVALTNING Versjon 1.4 2017 Innhold 1. Introduction...3 2. Objective...3 3. Integrating ESG into our investment
More informationGRINDROD SOUTH AFRICA//Policy Risk and opportunity governance framework
Document number GP24 Revision number 02 Issue date 23 May 2017 Author name Andrew Davies Approval Risk Committee 02 CONTENTS 1 Purpose 04 2 Objective 04 3 Risk and opportunity governance policy 04 4 Governance
More informationENVIRONMENTAL, SOCIAL AND GOVERNANCE POLICY
1.0 ESG Philosophy Manulife Asset Management(Manulife AM) provides comprehensive asset management solutions for clients across a wide range of asset classes and investment objectives, all sharing the common
More informationGranate Asset Management. Responsible Investing Policy
Granate Asset Management Responsible Investing Policy Contents Overview... 3 Principles of CRISA... 3 Principle 1... 3 Principle 2... 3 Principle 3... 4 Principle 4... 4 Principle 5... 4 Principles of
More informationNOTICE OF ANNUAL GENERAL MEETING
Datatec Integrated Report 2015 169 Datatec at a glance Our focus Our performance Governance Our impacts Consolidated annual financial statements Notices and references NOTICE OF ANNUAL GENERAL MEETING
More informationNottinghamshire Pension Fund INVESTMENT STRATEGY STATEMENT. Introduction. Purpose and Principles. March 2017
Nottinghamshire Pension Fund March 2017 INVESTMENT STRATEGY STATEMENT Introduction 1. The County Council is an administering authority of the Local Government Pension Scheme (the Scheme ) as specified
More informationStewardship Principles for Institutional Investors
Stewardship Principles for Institutional Investors Chapter 1 Institutional Investors and Their Duties Institutional investors can be classified into two types based on their business models: 1. "Asset
More informationWAM Global Limited (ACN ) (Company) Corporate Governance Statement
WAM Global Limited (ACN 624 572 925) (Company) Corporate Governance Statement This Corporate Governance Statement sets out the Company s current compliance with the ASX Corporate Governance Council s 3
More information1 P a g e V e r s i o n 1 M a r c h
1 P a g e The London Collective Investment Vehicle (CIV) was formed as a voluntary collaborative venture by the London Local Authorities in 2014 to invest the assets of London Local Government Pension
More informationAcknowledgments...2. Summary and relevance statement...3. Committee on Responsible Investing by Institutional Investors in South Africa...
Index INDEX Acknowledgments...2 Summary and relevance statement...3 Foreword...4 Committee on Responsible Investing by Institutional Investors in South Africa...5 Introduction...6 Purpose...7 Application...8
More informationPrinciples applicable to auditors reports to regulators
Guidance for reporting in accordance with the Client Asset Requirements issued by the Irish Financial Services Regulatory Authority ( Financial Regulator ) in November 2007. This guidance is issued by
More informationResponsible Ownership: Proxy and Engagement Report
Responsible Ownership: 2017 Proxy and Engagement Report March 2018 Introduction Russell Investments believes that being an active owner is an important component of its investment responsibilities. Through
More informationOECD GUIDELINES ON INSURER GOVERNANCE
OECD GUIDELINES ON INSURER GOVERNANCE Edition 2017 OECD Guidelines on Insurer Governance 2017 Edition FOREWORD Foreword As financial institutions whose business is the acceptance and management of risk,
More informationESG Risk Management Policy MLC Nominees Pty Limited PFS Nominees Pty Limited (the Trustees )
MLC Nominees Pty Limited PFS Nominees Pty Limited (the Trustees ) Policy Administration Information Schedule Policy Name ESG Risk Management Policy Version Number 1.0 Approval Date 26 June 2014 Effective
More informationNotice of Annual General Meeting
Notice of Annual General Meeting DATATEC LIMITED (Incorporated in the Republic of South Africa) Registration number: 1994/005004/06 Share code: DTC ISIN: ZAE000017745 ( Datatec or the Company or the Group
More informationOMF FAIS Conflict of Interest Management Policy
OMF FAIS Conflict of Interest Management Policy WHY THE FAIS CONFLICT OF INTEREST MANAGEMENT POLICY? WHY: To ensure we avoid or control any conflict of interest situations that could negatively affect
More informationNGS SUPER RESPONSIBLE INVESTMENT POLICY
Your fund. Your wealth. Your future. NGS SUPER RESPONSIBLE INVESTMENT POLICY Managing long term risks in order to maximise prospective long term returns EXTRACT FROM RESPONSIBLE INVESTMENT POLICY DOCUMENT
More informationFOR PROFESSIONAL CLIENTS ONLY. Environmental, social and governance (ESG) investment policies
FOR PROFESSIONAL CLIENTS ONLY Environmental, social and governance (ESG) investment policies 2016 1. Does your organisation have a policy regarding the integration of environmental, social and corporate
More informationPERPETUA INVESTMENT MANAGERS PROXY VOTING POLICY
PERPETUA INVESTMENT MANAGERS PROXY VOTING POLICY Shareholder voting increasingly contains material issues involving shareholder rights and corporate governance which deserve careful review and consideration.
More informationGOOD PRACTICES FOR GOVERNANCE OF PENSION SUPERVISORY AUTHORITIES
. GOOD PRACTICES FOR GOVERNANCE OF PENSION SUPERVISORY AUTHORITIES November 2013 GOOD PRACTICES FOR GOVERNANCE OF PENSION SUPERVISORY AUTHORITIES Introduction 1. Promoting good governance has been at the
More informationCONFLICT OF INTEREST MANAGEMENT POLICY AS REQUIRED BY THE FAIS GENERAL CODE OF CONDUCT FOR THE LAWYER S VOICE PTY LTD FSP NO.32782
CONFLICT OF INTEREST MANAGEMENT POLICY AS REQUIRED BY THE FAIS GENERAL CODE OF CONDUCT FOR THE LAWYER S VOICE PTY LTD FSP NO.32782 Definitions COI means conflict interest Conflict of interest means any
More informationFIRSTRAND LIMITED FAIS ACT CONFLICT- OF-INTEREST POLICY
1 FIRSTRAND LIMITED FAIS ACT CONFLICT- OF-INTEREST POLICY Policy tier FirstRand Limited Policy management Group Ethics Officer and Group FAIS Compliance Officer Policy governance FirstRand Limited Risk,
More informationIntroduction. The Assessment consists of: A checklist of best, good and leading practices A rating system to rank your company s current practices.
ESG / CSR / Sustainability Governance and Management Assessment By Coro Strandberg President, Strandberg Consulting www.corostrandberg.com September 2017 Introduction This ESG / CSR / Sustainability Governance
More informationAUDIT & RISK COMMITTEE CHARTER
AUDIT & RISK COMMITTEE CHARTER www.afrimat.co.za F2016 1. Constitution 1.1 In line with the requirements of the Companies Act as amended ( Act ) and the King Report on Governance for South Africa 2009
More informationResponsible investment policy
PROSPERITY CAPITAL MANAGEMENT Responsible investment policy 3/27/2018 OBJECTIVE This Policy sets out how Prosperity Capital Management (hereinafter PCM) discharges its responsibility towards PCM s clients
More informationASX LISTING RULES Guidance Note 9
ASX LISTING RULES DISCLOSURE OF CORPORATE GOVERNANCE PRACTICES The purpose of this Guidance Note The main points it covers To assist listed entities to comply with Listing Rules 4.10.3 (corporate governance
More informationcrisa code For responsible investing in South africa
crisa code For responsible investing in South africa 1 Executive Summary The world has entered a period of significant change. Global economies, politics and capital markets are all affected. Key drivers
More informationRole of Institutional Investors
Role of Institutional Investors Chapter 2 ROLE OF INSTITUTIONAL INVESTORS Leadership in governance and responsible ownership 2.1 OVERVIEW Institutional investors are in a unique position to exercise influence
More informationRisk Review Committee
Risk Review Committee Committee Charter A strong and comprehensive risk management framework is required to support the ongoing success of Coast Capital Savings Credit Union ( Coast Capital Savings ) and,
More informationCorporate Governance & Proxy Voting
Asset management Professional clients only Corporate Governance & Proxy Voting Policy & Procedures 1 Our approach to governance and stewardship UBS Asset Management's stewardship policy is our commitment
More informationRECM VOTING PRINCIPLES
RECM VOTING PRINCIPLES Contents Introduction Section I Corporate Governance Framework Code for Responsible Investing in South Africa (CRISA) Section II. Resolutions Relating to Financial Statements. Composition
More informationNotice of annual general meeting
Notice of annual general meeting ETION LIMITED (previously known as Ansys Limited) (Incorporated in the Republic of South Africa) Registration number: 1987/115237/06 JSE share code: ETO ISIN: ZAE000257739
More informationSTANLIB Classic Preservation Pension Plan Terms and Conditions
STANLIB Classic Preservation Pension Plan Terms and Conditions Saving for your retirement is vital. The Classic Preservation Pension Plan allows you to save the money you receive from an employer pension
More informationSINGAPORE GOVERNANCE AND TRANSPARENCY INDEX (SGTI)
SINGAPORE GOVERNANCE AND TRANSPARENCY INDEX (SGTI) A Collaboration Between Strategic Media Partner The Singapore Governance and Transparency Index (SGTI) is aimed at assessing companies on their corporate
More information1 Purpose and objectives of the policy
Date of this Policy: 27 March 2018 The information in this document forms part of the following Product Disclosure Statements: Cbus Industry Super Product Disclosure Cbus Sole Trader Product Disclosure
More informationINVESTMENT POLICY POLICY NO: 0126
INVESTMENT POLICY POLICY NO: 0126 1 TABLE OF CONTENT LEGISLATIVE FRAMEWORK AND BEST PRACTICES... 4 LEGISLATIVE FRAMEWORK AND BEST PRACTICES... 4 PURPOSE... 4 DEFINITIONS... 5 SCOPE... 7 DELEGATION OF POWERS...
More informationResponsible Investment: A Matter of Principles
Responsible Investment: A Matter of Principles IMAS LunchTime Talk 18 November 2016 1 What is Stewardship? Responsible wealth creation How can a business thrive and sustain growth while enhancing the wealth
More informationTEXTS ADOPTED. Long-term shareholder engagement and corporate governance statement ***I
European Parliament 2014-2019 TEXTS ADOPTED P8_TA(2015)0257 Long-term shareholder engagement and corporate governance statement ***I Amendments adopted by the European Parliament on 8 July 2015 on the
More informationCHANNEL FOUR TELEVISION CORPORATION ARRANGEMENTS UNDER SCHEDULE 9 OF THE COMMUNICATIONS ACT 2003
CHANNEL FOUR TELEVISION CORPORATION ARRANGEMENTS UNDER SCHEDULE 9 OF THE COMMUNICATIONS ACT 2003 NOVEMBER 2011 ARRANGEMENTS UNDER SCHEDULE 9 OF THE COMMUNICATIONS ACT 2003 INDEX Introduction 3 Page Part
More informationOCEAN PARK CONSERVATION FOUNDATION, HONG KONG
OCEAN PARK CONSERVATION FOUNDATION, HONG KONG CODE OF GOVERNANCE Prepared: Mar 2012 Revised: Jun 2013 Page 1 of 22 OCEAN PARK CONSERVATION FOUNDATION, HONG KONG The Ocean Park Conservation Foundation ("OPCF")
More informationIntermediaries in the short-term insurance market are. Intermediaries are key business partners and critical to the sustainability of our business.
26 Component objective Component sub-issues Intermediaries are key business partners and critical to the sustainability of our business. Santam sells most of its insurance products through that deal directly
More informationCommunication with stakeholders
Communication with stakeholders MCCG Intended Outcome 11.0 There is continuous communication between the company and stakeholders to facilitate mutual understanding of each other s objectives and expectations.
More informationFor personal use only
NOTICE OF ANNUAL GENERAL MEETING AND EXPLANATORY MEMORANDUM TO BE HELD AT: RSM Bird Cameron Level 21, 55 Collins Street, Melbourne, Victoria At 10:00 am on Wednesday, 22 November 2017 TO BE VALID, THE
More informationIOPS Technical Committee DRAFT GOOD PRACTICES FOR GOVERNANCE OF PENSION SUPERVISORY AUTHORITIES. Version for public consultation
IOPS Technical Committee DRAFT GOOD PRACTICES FOR GOVERNANCE OF PENSION SUPERVISORY AUTHORITIES Version for public consultation DRAFT GOOD PRACTICES FOR GOVERNANCE OF PENSION SUPERVISORY AUTHORITIES Introduction:
More informationSOUTH AFRICA (as of April 2014) Annex I: Banks
SOUTH AFRICA (as of April 2014) Annex I: Banks Milestones and changes in inter standards) inter 1. Reducing reliance on CRA ratings in laws and regulations (Principle I) Based on the findings from the
More informationFAIS Conflict of Interest Management Policy
Bryte Insurance Company Limited A Fairfax Company Registration number: 1965/006764/06 VAT number: 4530103581 Authorised Financial Services Provider No. 17703 15 Marshall Street, Ferreirasdorp, Johannesburg,
More informationLONDON BOROUGH OF HARROW PENSION FUND INVESTMENT STRATEGY STATEMENT
LONDON BOROUGH OF HARROW PENSION FUND INVESTMENT STRATEGY STATEMENT March 2017 CONTENTS Executive Summary 1. Introduction 2. Statutory background 3. Directions by Secretary of State 4. Advisers 5. Objective
More information2011 AGM SHAREHOLDERS QUESTIONS & COMMENTS
IAG encouraged shareholders to ask questions of, or make comments to, the board and management in advance of the 2011 Annual General Meeting (AGM), via a form included with the 2011 Notice of Meeting.
More informationRESPONSIBLE INVESTMENT POLICY. Principles for Responsible Investment... 2 ESG Issues and Objectives... 3 ESG approach... 5 Engagement...
RESPONSIBLE INVESTMENT POLICY Principles for Responsible Investment... 2 ESG Issues and Objectives... 3 ESG approach... 5 Engagement... 5 June 2017 1 Principles for Responsible Investment Responsible investment
More informationESG REQUIREMENTS MAY 2017
ESG REQUIREMENTS MAY 2017 1 INTRODUCTION Frontier Investment Management ( the Fund Manager ) is a private equity infrastructure fund manager with offices in Copenhagen and East Africa with a unique focus
More informationThe State of Responsible Investment in South Africa
The State of Responsible Investment in South Africa Findings from a recent survey with South African institutional investors By Gloudi van der Ahee (Department of Accounting, Stellenbosch University) and
More informationCONTENTS PREAMBLE... 1 THE TASKS OF THE BOARD OF DIRECTORS... 3 THE BOARD OF DIRECTORS: A COLLEGIAL BODY... 4
CONTENTS PREAMBLE... 1 THE TASKS OF THE BOARD OF DIRECTORS... 3 THE BOARD OF DIRECTORS: A COLLEGIAL BODY... 4 THE DIVERSITY OF FORMS OF ORGANISATION OF GOVERNANCE... 4 THE BOARD AND COMMUNICATION WITH
More informationEast Sussex Pension Fund Governance compliance and the Pensions Regulator s code of practice
East Sussex Pension Fund Governance compliance and the Pensions Regulator s code of practice The role of the local pension board is to Secure compliance with the scheme regulations and other legislation
More informationConflict of Interest Management Policy
Conflict of Interest Management Policy Document Number: POL-031 Approved By: Board of Directors Approval Date: 02 August 2017 Next Review Cycle: July 2018 Version: 4.1 Type: Governance Policy Owner: Executive
More information1 INTRODUCTION. Frontier Investment Management ( the Fund Manager ) is a private equity infrastructure
ESG REQUIREMENTS MAY 2017 1 INTRODUCTION Frontier Investment Management ( the Fund Manager ) is a private equity infrastructure fund manager with offices in Copenhagen and East Africa with a unique focus
More informationResponsible Investing Policy
Responsible Investing Policy Prepared September 2018 Version: 4.0 Issuing details: Prepared by: Suzanne Branton Chief Investment Officer Approved by: Board of Directors, CARE Super Pty Ltd Date of Approval:
More informationLazard ESG Integration: 2017 Second Half Report
Lazard ESG Integration: 2017 Second Half Report At Lazard, we are committed to providing clients with innovative investment solutions and superior performance. ESG is a critical component of this investment
More informationRESPONSIBLE INVESTMENT POLICY. Columbia Management Investment Advisers, LLC
POLICY Columbia Management Investment Advisers, LLC APPROACH TO RESPONSIBLE INVESTMENT COLUMBIA THREADNEEDLE INVESTMENTS This brochure provides a broad outline of the approach to responsible investment
More informationGeneral principles on the governance of listed companies
General principles on the governance of listed companies Editorial When Caisse des Dépôts is exercising its shareholder right by voting at a general shareholders meeting, it bases its position on its principles
More informationSTANLIB Classic Retirement Annuity Fund Terms and Conditions
STANLIB Classic Retirement Annuity Fund Terms and Conditions The Classic Retirement Annuity Fund is ideal if you want to save for your retirement. You need flexibility when it comes to making a contribution
More informationEuropean SRI Transparency Code Version 3:0
European SRI Transparency Code Version 3:0 December 2014 The European SRI Transparency Code (the Code) focuses on SRI funds distributed publicly in Europe and has been designed to cover a range of assets
More informationTHE GENUINE POWER OF OUR INVESTMENT APPROACH IS IN THE INFORMED DEBATE THAT OUR INDEPENDENT ANALYSIS AND MODELLING PROCESS PROVOKES.
OLD MUTUAL EQUITIES THE GENUINE POWER OF OUR INVESTMENT APPROACH IS IN THE INFORMED DEBATE THAT OUR INDEPENDENT ANALYSIS AND MODELLING PROCESS PROVOKES. Peter Linley, Head: Old Mutual Equities OLD MUTUAL
More informationAnalysis of Corporate Governance Disclosures in Annual Reports. Annual Reports
Analysis of Corporate Governance Disclosures in Annual Reports Annual Reports 2012-2013 December 2014 Contents Executive Summary 1 Principle 1: Establish Clear Roles and Responsibilities 10 Principle 2:
More informationResponsible Investment: Policies and Principles
Responsible Investment: Policies and Principles At Franklin Templeton Investments (FTI), responsible investment (RI) refers to the integration of environmental, social and governance (ESG) factors into
More informationIFSA Guidance Note No Corporate Governance: A Guide for Investment Managers and Corporations. July 1999
Corporate Governance: A Guide for Investment Managers and Corporations July 1999 Main features of this Guidance Note are: The first four Guidelines in the Guidance Note provide a series of guidelines for
More informationKiltearn Partners LLP FCA Ref: Stewardship Code Statement
Kiltearn Partners LLP FCA Ref: 540470 This document describes how Kiltearn Partners LLP ( Kiltearn ) has applied the principles of the Financial Reporting Council s ( FRC s ) Stewardship Code (the Stewardship
More information