1、Point of No Returns A ranking of 75 of the worlds largest asset managers approaches to responsible investment March | 2020 Acknowledgements ShareAction gratefully acknowledges the financial support of the KR Foundation for the ShareAction/ AODP project. The views expressed are those of ShareAction a

2、lone. We would like to thank the experts who gave their time for consultation on the development of this work. We also gratefully acknowledge the efforts made, and time given, by those who supplied information on behalf of their companies in this assessment. We would also like to thank the consultan

3、ts and asset owners who encouraged asset managers to complete our assessment. Report authors: Felix Nagrawala, Krystyna Springer of ShareAction. Contributors: Wolfgang Kuhn, Bethan Livesey, Peter Uhlenbruch, Sonia Hierzig of ShareAction. About ShareAction ShareAction is a non-profit working to build

4、 a global investment sector which is responsible for its impacts on people and planet. We mobilise investors to take action to improve labour standards, tackle the climate crisis, and address pressing global health issues, such as childhood obesity. Over the last 15 years, ShareAction has used its p

5、owerful toolkit of research, corporate campaigns, policy advocacy and public mobilisation to drive responsibility into the heart of mainstream investment. We want a future where all finance powers social progress. Visit shareaction.org or follow us ShareAction to find out more. Contact Felix Nagrawa

6、la Senior Analyst Financial Sector Research signalling stark misalignment with the goals of the Paris Agreement14. In light of this, passive investors should take significant steps in their risk management processes through stewardship activities and ESG integration. A business-as-usual approach cou

7、ld be putting clients money at risk from systemic ESG issues while negatively impacting the environment and society. Not only can management of ESG factors help ensure long-term financial security, but it can also be a source of competitive advantage. Japans Government Pension Investment Fund (GPIF)

8、, the worlds largest asset owner, has made it publicly clear that ESG-related stewardship is becoming a more important differentiator when selecting asset managers for passive mandates15. Leading practice examples of effective approaches to ESG integration and stewardship that can be adopted by pass

9、ive managers include: Choosing ESG-themed indices and benchmarks; Developing robust and comprehensive methodologies for identifying areas for company engagement on ESG issues; Engaging with investee companies on ESG issues using time-bound engagement objectives with escalation procedures for when ob

10、jectives are not met. These may include voting on ESG shareholder proposals, voting against the board of directors, and/or screening a company out of the investment universe; Weighting of constituent companies within the index based on ESG factors; Engaging with index providers to exclude companies

11、involved in ESG breaches from the overall index. v Defined here as holding over 60 per cent of AUM in fixed income. Chapter 1 Sleeping Giants: Are bond investors ready to act on climate change? ShareActions 2019 research on bondholder engagement examines whether corporate bond investors are addressi

12、ng the risks associated with climate change through stewardship16. The research found a lack of forceful engagement from bond investors that can be attributed to two main reasons: legal concerns and incomplete investment objectives that neglect negative impacts (an investment portfolios externalitie

13、s or footprints on environment and society). Best practice for asset managers on sustainable investment in bonds would include: Comprehensive mapping of debt portfolios impact profile; Investment Management Agreements setting out objectives on the management of negative portfolio impacts; Transparen

14、cy about company engagement, including expected engagement outcomes, escalation process and timelines, and reporting on the state of engagement activities; Communication with issuers on conditions for investment in new debt issues. Figure 11: Asset managers predominantly focused on fixed income Rank

15、ingAsset ManagerRating 6Aegon Asset ManagementBBB 8NN Investment PartnersBBB 9M A number of CA100+ investor signatories fail to support resolutions at CA100+ focus companies; A number of historical resolutions face relatively low levels of support, with investors sticking to their voting decisions t

16、hrough the years; Resolutions on corporate lobbying and climate-related disclosures seem to have entered the mainstream20. The full report including individual performance of asset managers is available here. 6.2 The majority of asset managers voting policies lack commitments on human rights due dil

17、igence, remuneration structures and non-discrimination While 53 per cent of the surveyed asset managers report that their voting policy covers human and labour rights, few make specific voting commitments in this area. Around 32 per cent explicitly state support for inclusion and diversity at invest

18、ee companies, however, for the most part, this is limited to board-level gender diversity. Only a few voting policies indicate clear support for shareholder resolutions that call for the setting of diversity objectives and addressing “glass ceilings” at all levels of the organisation. Interestingly,

19、 support for diversity-related resolutions is not a proxy for a progressive stance on gender pay gap reporting. The majority of asset managers who express support for workplace gender diversity in their policies stop short of including clear voting guidelines on the disclosure of gender pay gap data

20、 and only commit to voting on this issue on a case-by-case basis. Perhaps most concerning, however, is that only around 12 per cent of asset managers voting policies include an acknowledgement of investee companies responsibility for upholding human rights and a commitment to vote for resolutions ca

21、lling for improvement of due diligence in this area. While the lack of specific policy commitments does not prevent asset managers from supporting resolutions on environmental issues, it also creates no guarantee for clients that managers will act to safeguard their long-term interests. Weak voting

22、policies send an ambiguous message about asset managers commitment to active stewardship and contribute to the generally low level of transparency on stewardship practices within the industry. vii Note that this was a separate assessment of asset managers voting on 65 resolutions to the assessment c

23、arried out for the creation of the ranking in this report, which included five resolutions. 3233 Asset managers voting record on human rights resolution at Tyson Foods At Tyson Foods 2019 AGM, a shareholder proposal was put forward requesting that a report be published on human rights due diligence

24、processes at the company. Of the asset managers in our ranking who voted on the resolution, 60 per cent voted against it. This is despite MSCI data indicating that Tyson Foods faces “significant concerns related to Labour Management Relations”21. Given that the commitment requested by the resolution

25、 was relatively high-level (it focused solely on disclosure on human rights due diligence and did not commit the company to any specific actions), the lack of shareholder support reinforces the impression that asset managers human rights voting policies and practices still need improvement. The low

26、performance in this instance could perhaps be attributed to the fact that the major proxy advisors were split on this resolution: ISS recommended voting against the resolution, while Glass Lewis recommended voting forviii. However, this only serves to reinforce the point that asset managers need to

27、have their own clearly defined human rights voting policy commitments to ensure that their voting decisions are in line with a robust approach to human rights. 6.3 Only a few of the assessed voting policies contain explicit guidance for biodiversity-related resolutions While 36 per cent of asset man

28、agers state that their voting policy covers biodiversity, hardly any of the reviewed policy documents contain explicit guidance for biodiversity-related resolutions. Around seven per cent of voting policies include a general commitment to vote in favour of increased transparency with regard to the w

29、ider environmental impact of company operations, typically including toxic emissions, resource use and waste management. We found only one case of a voting policy containing an explicit commitment to vote in favour of proposals asking companies to abstain from operating in environmentally sensitive

30、areas or using products produced from materials extracted from such areas. viii For an in-depth analysis of the role of proxy advisors in the investment system, see ShareAction investor briefing: Another Link in the Chain: Uncovering the Role of Proxy Advisors. Chapter 2 Figure 14: Asset managers vo

31、ting disclosure - frequency Chapter 2 Transparency on voting and engagement activities Effective stewardship is widely regarded as a driver of enhanced operational and financial performance. It helps to reduce risks and maximise returns at the individual investment level, as well as enhance overall

32、market stability and maximise positive impacts on society and the environment more generally. The wider relevance and economy-wide implications of asset managers active ownership practices evidence the need for greater transparency on their voting and engagement activities. In recognition of this, c

33、lauses referring to the disclosure of active ownership activities have been included in the stewardship codes of several countries22, as well as in the EUs Shareholder Rights Directive II, which states that “asset managers should publicly disclose information about the implementation of their engage

34、ment policy, and in particular how they have exercised their voting rights”23. Against this backdrop, we asked the surveyed asset managers about their practices relating to the disclosure of voting information and reporting on engagement activities. Based on the collected data, this section represen

35、ts an assessment of whether the industry provides enough transparency for current and prospective clients and other stakeholders to be able to hold asset managers to account for their voting decisions and progress on engagement. FINDING 7 While publishing proxy voting records is becoming more widesp

36、read, reporting on voting rationales is still in its infancy 7.1 55 per cent of the assessed asset managers disclose a record of proxy votes cast in annual general meetings (AGMs) of investee companies and 28 per cent do so within one month of the date of the vote Around 55 per cent of the assessed

37、asset managers disclose their voting records publicly. While this is done with varying frequency, 28 per cent of investors publish their votes within one month of the date of the AGM. The majority of asset managers in this subset do so immediately after the meeting. At least every month Every quarte

38、r Every 6 or 12 months Do not disclose 8% 19% 45% 28% 3435 7.2 Only 17 per cent of asset managers publish rationales for their voting decisions Proxy voting is often the only measurable evidence that asset owners, clients and other stakeholders have of asset managers commitment to active stewardship

39、 and responsible investment more generally. In light of this, it is crucial that asset managers provide a satisfactory explanation of their voting decisions for controversial shareholder resolutionsix and decisions that seem inconsistent with their voting policy. It is therefore concerning that only

40、 17 per cent of asset managers publish rationales for their voting decisions. ix Controversial votes are defined by the Investment Association as votes with 20% shareholder rebellion. Chapter 2 Proxy voting transparency key issues A 2018 ShareAction study of UK charity fund managers voting records c

41、oncluded that there are three main areas with regard to voting transparency that require the attention of regulators and industry bodies24: 1. Publishing comprehensive voting records. Rather than only publishing ad-hoc, limited rationales or rationales provided by proxy advisors, asset managers shou

42、ld provide sufficient explanation for controversial votes that reflect a considered position and ensure a level of comparability between managers. 2. Explaining special exemptions and abstentions. Voting decisions that go against an asset managers voting policy are often justified as “special exempt

43、ions”, with little further explanation. Asset managers should be clearer about their policy relating to special exemptions or abstentions and clients should seek explanation when their managers use of special exemptions is significantly more frequent than industry average. 3. Providing transparent v

44、oting records. Asset managers should publish voting records in a format that makes it easy to identify specific voting decisions and do so within a reasonable timeframe from the date of the vote. FINDING 8 Most asset managers report on their ESG-related engagement at an aggregate level, but rarely p

45、rovide detail on their engagements and outcomes 8.1 36 per cent of the assessed asset managers disclose no information about their ESG-related engagement activities publicly Around 36 per cent of the surveyed asset managers publish no information on ESG-related engagement across all portfolios under

46、 management and 8 per cent report that they only communicate this information to clients. In the latter case, the details of engagement are largely only available on request and there is limited evidence that engagement records and outcomes are regularly communicated to clients. 8.2 Overall quality

47、of reporting on engagement is low, with only 17 per cent of asset managers publicly disclosing a comprehensive record of ESG-related engagement Only 17 per cent of the surveyed asset managers include a representative sample of detailed case studies of ESG-related engagement in their reports. 39 per

48、cent of asset managers provide more limited disclosure, typically including a handful of short examples of engagement in their reports and/or a detailed split of the number of engagements by topic. Overall, only 52 per cent of asset managers report on the number of engagements or targeted companies

49、and only a few provide information on the type of engagement (letter or meeting with management etc.). As a result, it is very difficult to quantify the differences in the level of ambition and quality of engagement between asset managers. Figure 15: Quality of reporting on engagement activities x We refer here to the five shareholder resolutions analysed for the purpose of the report. Chapter 2 Representative sample of engagement activities Some examples of engagement activities Disclosing only number of engagements No engagement-related disclosure 17% 39%