Aviva Pension CT Responsible Global Equity Pn
SRI Style:
Ethical Style
SDR Labelling:
-
Product:
Pension
Fund Region:
Global
Fund Asset Type:
Equity
Launch Date:
29/09/2008
Last Amended:
Jun 2023
Dialshifter (
):
Fund Size:
£26.71m
(as at: 30/11/2024)
ISIN:
GB00B3CT5Z57, GB00B689DG70, GB00BKKZR146
Contact Us:
Objectives:
The fund aims to achieve capital growth over the long term (at least 5 years).
Sustainable, Responsible
&/or ESG Overview:
This Pension product is linked to the "CT Responsible Global Equity" fund. The following information refers to the primary fund.
Awaiting update from manager - last updated June 2023
The objective is to achieve long-term capital growth. The Fund is actively managed. It is not constrained by its comparator benchmark, the MSCI World TR Index, and has significant freedom to invest in a portfolio that is materially different to the benchmark’s own composition. The Fund seeks to achieve this by investing in companies in any market screened against defined responsible and sustainable criteria, including exclusions on tobacco, alcohol, weapons, gambling, nuclear and pornography. The Fund also requires companies to meet sector standards on social and environmental issues, including systems for managing labour standards, human rights, supply chains, environmental impacts, water, waste, and biodiversity.
Primary fund last amended:
Jun 2023
Information directly from fund manager.
Fund Filters
Sustainability - General
Funds that have policies that consider (environmental and social) sustainability issues. Strategies vary but are likely to consider environmental issues like climate change, carbon emissions, biodiversity loss, resource management, environmental impacts; and social issues like equal opportunities, human rights, labour standards, diversity and adherence to internationally recognised codes. See fund information.
Find funds which substantially focus on sustainability issues
A core element of these funds aim to encourage higher sustainability standards across business practices through responsible ownership / stewardship / engagement / voting activity
Find funds that use the UN Global Compact to inform or help direct where they can or cannot invest and will typically not invest in companies with significant breaches (low standards) - although strategies vary. (The UNGC covers a wide range of issues - search 'UNGC'). See https://unglobalcompact.org/
Find funds that specifically aim to invest (and manage assets) in ways that help to address all or some of the UN's Sustainable Development Goals (SDGs). See https://sdgs.un.org/goals).
Find funds that publicly report their performance against specifically named sustainability objectives (in addition to reporting their financial performance)
Environmental - General
Funds that have policies which relate to environmental issues. These will typically set out the fund's stance on issues such as pollution, climate change, resource management, biodiversity loss, carbon emissions, plastics and/or additional environmental impacts. Strategies vary. See fund information for further information.
Funds that limit or 'reduce' their exposure to carbon intensive industries (ie sectors which are major contributors to climate change. Funds vary - some funds may be 'underweight' in this area which means they may have some investment in highly carbon intensive areas. Funds of this kind may choose companies they consider to be 'best in sector' and encourage ever higher standards. Strategies vary. See fund information for further details.
Funds that have written policies explaining the approach they take when companies damage the environment or are significant polluters. Funds of this kind may work with companies to encourage higher standards, or exclude companies - sometimes dependent on the situation. Strategies vary. See fund information for further detail.
Funds that aim to invest in companies with strong or market leading environmental policies and practices. Strategies vary - in particular the balance between 'financial' aspects and environmental benefits. Some may invest substantially in solutions or 'positive impact' companies - others may invest in more conventional companies providing certain environmental criteria are met. See fund information for further detail.
Nature & Biodiversity
Find funds that have a written biodiversity policy or theme aimed at encouraging and improving environmental protection and safeguarding the natural world (sometimes referred to as the preservation or enhancement of 'natural capital'). See eg https://www.un.org/en/climatechange/science/climate-issues/biodiversity
Find funds that have policies in place designed to ensure they do not invest in companies that are significantly involved in deforestation. This typically relates to palm oil plantations where biodiversity loss is a major concern (as well as other issues). Strategies vary. See fund information for further detail.
Find funds that have policies in place explaining that they avoid companies involved in illegal and/or unsustainable deforestation. This may relate to palm oil, cattle farming or other concerns. Strategies vary. See fund information for further detail.
Fund has a responsible palm oil policy which is likely to focus on the producers of palm oil and deforestation issues with a view to informing investment decisions (and / or engagement) to support and encourage high standards.
Find funds that aim to avoid investing in companies that produce genetically modified seeds or crops. (This does not typically include avoiding companies such as supermarkets). See fund literature for further information.
Climate Change & Energy
Funds that have policies (documented strategies that explain their position on) climate change related issues such as greenhouse gas/carbon emissions, net zero, transitioning to lower carbon. Strategies vary. Read fund details for further information.
Funds that avoid investing in major coal, oil and/or gas (extraction) companies. Funds vary: some may exclude all companies that extract oil. Others may have exposure to oil extraction via more diversified energy companies. See fund literature to confirm details.
Funds that avoid companies involved in fracking and tar sands - which are widely regarded as controversial methods of oil and gas extraction. Strategies vary. See fund information for further information.
Funds that avoid companies that are involved in extracting oil from the Arctic regions. See fund literature for further details.
Funds that avoid investing in companies with coal, oil and gas reserves. See fund information for further details.
A core element of these funds will aim to encourage the transition to lower carbon activities through responsible ownership / stewardship / engagement / voting activity
Funds that hold companies in the clean energy and renewable energy sectors (at the time research was supplied). Fund strategies vary, in particular the proportion of investment in these areas may vary significantly. Check fund literature for details.
Find funds that have policies which say they avoid or limit their investment in the nuclear industry. Strategies vary. See fund information for further detail.
The fund manager excludes companies with direct involvement in fossil fuel exploration (eg coal, oil and gas companies)
This fund has a strategy that aims ensure its holdings will gradually reduce their greenhouse gas emissions in line with targets set at COP21 in Paris. The ultimate aim is to achieve ‘net zero emissions by 2050’ and a ‘maximum global temperature increase of +1.5 to +2 degrees above preindustrial levels’. Strategies and opinions vary. Read fund information.
Will only invest in companies that report greenhouse gas emissions reduction strategies in line with the framework set out the by the Taskforce for Climate Related Financial Disclosure, which is increasingly becoming mandatory. See https://www.fsb-tcfd.org/ https ://www.ifrs.org/sustainability/tcfd/
Social / Employment
Find funds that have policies which set out their approach to social issues (e.g. human rights, labour standards, equal opportunities, child labour and adherence to internationally recognised codes such as the UN Global Compact). Funds with social policies typically avoid companies with low standards or work to encourage higher standards. See fund information for detail.
Find funds that have a labour standards policy - which can be expected to mean that the fund will invest in / favour companies that have higher standards in this area - although fund strategies can vary significantly (as with all policy areas). See eg https://www.ilo.org/international-labour-standards
Find funds that invest in line with positive strategies that relate to 'people' issues - such as having strong human rights, labour standards and equal opportunities practices. Such funds are likely to invest in companies that have market leading standards with regard to employee and supplier practices. Read fund literature for further information.
All mining companies excluded
Ethical Values Led Exclusions
Find funds that have policies that set out their position on ethical or 'personal values' based issues. Strategies vary. See fund information for further detail.
Companies are excluded if they are involved in any aspect of the production chain for tobacco products, including cigarettes, vaping, e-cigarettes, chewing tobacco and cigars.
Find funds that avoid companies that manufacture products intended specifically for military use. Fund strategies vary - particularly with regard to non-strategic military products. See fund literature for fund specific details.
Find funds with a written civilian firearms exclusion policy - meaning that they will not invest in companies that make (or perhaps also sell) handguns made for non-military users.
Find funds that avoid investment in companies involved in the production of alcohol. Strategies vary; some funds allow a small proportion of profits to come from this area. See fund literature for further information.
Find funds that avoid companies with significant involvement in the gambling industry. Some funds may allow a small proportion of profits to come from this area. See fund policy for further details.
Find funds that avoid companies that derive significant income from pornography and related areas. Strategies vary. See fund details for further information.
Find funds with policies that require specific animal welfare standards to be met. These may reference well-known welfare standards (3Rs - Replace, Reduce, Refine) or certification schemes. Strategies vary. See fund information for further detail.
Human Rights
Find funds that have policies relating to human rights issues. Funds of this kind typically require companies to demonstrate higher standards, although some fund managers work to encourage improvements. Investee companies are often judged against internationally agreed norms or standards. Strategies vary. See fund information for further detail.
Find funds that have policies in place to ensure they do not invest in companies that employ children.
Banking & Financials
Fund excludes financial services companies with widely criticised, aggressive lending practices where interest rates are typically very high, includes ‘doorstep lending’)
Governance & Management
Find fund options that have policies that relate to corporate governance issues such as board structure, executive remuneration, bribery and/or corporate corruption. These funds will typically avoid companies with poor practices. Strategies vary. See fund literature for further information.
Find funds that aim to avoid investing in companies with poor governance practices.(e.g. board structure, management practices etc.) Views may however vary on what counts as 'poor' practices - and funds may not immediately divest as they may prefer to work to encourage higher standards. See fund literature for further information.
Fund managers encourage the companies they invest in to have more diverse board structures (e.g. more women on boards)
A core element of these funds will aim to encourage higher ESG standards through responsible ownership / stewardship / engagement /voting activity
Fund Governance
Find funds that have an external committee that helps steer or advise fund managers on SRI policy or strategy related issues. These people may be paid for their time but are not employees of the fund manager.
Find funds that factor in 'environmental, social and governance' issues as part of their investment decision making process. A focus on 'ESG' typically means a fund is carrying out additional research to help reduce ESG related risks. It does not necessarily mean a focus on sustainability. Strategies vary. See fund literature.
Asset Size
Find funds that invests more than half of their money into what are commonly regarded as 'large companies'. This will typically mean that the market capitalisation (or value) of the companies they hold is in excess of £5 to £10 billion.
Find a fund that invests in a combination of small, medium and larger (potentially multinational)companies.
Find funds that have SRI strategies and focus their investment stock selection on larger companies. (e.g. over circa £5-£10bn)
Impact Methodologies
Funds that aim to help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Funds that aim to measure the positive real world environmental and / or social benefits that are associated with their investment strategy. Funds that aim to deliver positive impacts and measure those impacts may be referred to as 'impact funds' - although impact measurement is not restricted to impact funds. Strategies vary. See fund information.
Find funds that specifically set out to help deliver positive environmental impacts, benefits or 'real world' outcomes.
Find funds that specifically state that they aim to deliver positive social (i.e. people related) impacts and/or outcomes.
Fund aims to deliver positive environmental and or social impacts (real world benefits) through its engagement with investee assets
How The Fund Works
Find funds that focus on finding and investing in companies with positive / beneficial attributes. This strategy can be applied in addition to exclusion criteria and engagement/stewardship activity.
Find funds where their main 'ethical approach' is to avoid companies by using negative screening criteria. Read fund literature for further information.
Find funds where their main approach is to apply positive or negative ethical, social and / or environmental screens. Strictly screened funds are likely to exclude more companies than other related fund options. See fund literature for further information.
Find funds that invest more heavily in those that have higher ESG ratings/standards or scores and less heavily in companies with lower ESG ratings. Where this is central to a fund's strategy you should expect it to invest in most sectors. Strategies vary.
Aims to avoid companies that do significant harm. This originates from the EU’s sustainable finance ‘DNSH’ (do no significant harm) work, which is not necessarily used by UK investors.
Find funds that have 'mapped' (reviewed) their investment selection and management strategies to identify which of the UN Sustainable Development Goals (SDGs) the fund is helping to address.
Find funds that have an ESG strategy (which is typically focused on avoiding companies that pose environmental, social or governance related risks) with additional criteria such as positive and/or negative screens, themes and stewardship strategies.
Find funds that consider both the 'positive' and 'negative' aspects of company behaviour and make balanced, considered decisions as part of their investment approach. May apply to a range of different issues and policy areas.
A major focus of these funds is the careful management of environmental, social and governance (ESG) related risks - typically by avoiding or being underweight in companies seen as posing major risks in these areas (i.e. not necessarily by using themes, exclusions etc).
Find funds that have published explanations of their ethical, social and/or environmental policies online (i.e. fund decision making strategies/ buy/sell &/or asset management strategies).
Unscreened Assets & Cash
All assets held in the fund - except cash - meet the sustainability criteria published in fund documentation.
Intended Clients & Product Options
Finds funds designed to meet the needs of individual investors with an interest in sustainability issues.
Finds funds designed to meet the needs of individual investors with an interest in ‘Impact investment funds’ which help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Find funds that are available via a tax efficient ISA product wrapper.
Fund Management Company Information
About The Business
Finds fund management companies that have a published company wide stewardship, engagement and / or responsible ownership policy or strategy that covers all investments. Stewardship typically involves encouraging higher ESG standards through voting and dialogue.
Find fund management companies that actively encourage higher 'environmental, social and governance' and/or 'sustainable and responsible investment' practices across investee companies - typically where the aim is to encourage positive change that is aligned with the best interests of investors. Strategies vary. See additional information and options.
Find fund managers that vote all* the shares they own at Annual General Meetings and Extraordinary General Meetings. A commitment to voting shares is a key indicator of 'responsible share ownership' demonstrating their support for or disagreement with management policy. (*situations can legitimately, occasionally occur where voting proves impossible, but in principle all shares should be voted.)
Find fund management companies that aim to align all their investments (across all funds) to help meet the aims of the UN Sustainable Development Goals.
Find funds run by fund managers that apply Responsible ownership or 'Stewardship' policies to all or most of their investment assets. This means active involvement (e.g. voting, dialogue) with the companies they invest in across funds (not normally limited to ethical or SRI options.) Read fund literature for further information.
Find fund management companies that consider environmental, social and governance (ESG) issues when deciding whether or not to invest in a company for all / almost all of their funds and other assets. This is increasingly seen as part of sound risk management.
Finds organisations / fund managers that have an in-house (company wide) diversity improvement programme - meaning that they are working to ensure that within their own businesses they employ people from diverse backgrounds - often typically focused on ethnicity and/or sex.
Find fund management companies that encourage the companies they invest in to have strong diversity, race, gender and other equality policies across all assets held, not simply screened or themed SRI/ESG funds. (ie Asset Management company wide).
Collaborations & Affiliations
Find fund management companies that have signed up to the UN backed 'Principles of Responsible Investment'.
Find fund management companies that are members of UKSIF - the UK Sustainable Investment and Finance association
Find fund management companies that have partnered with Fund EcoMarket - meaning that they are helping to improve access to information on sustainable and responsible investment by paying an annual fee to us which enables us to publish information for free. Partner funds are listed ahead of other funds and have their logos displayed.
A member of the Taskforce for Nature Related Financial Disclosures group which aims to aid risk management and shift money towards nature-positive outcomes.
Fund management entity is a member of the Investment Association https://www.theia.org/
Resources
Find fund management companies that employ people to steer and support fund managers in voting shares at company AGM's and EGMs in ways that are consistent with encouraging higher ESG/sustainability standards.
Find a fund management company that directly employs specialist ESG/SRI/sustainability researchers or analysts. This allows asset managers to discuss environmental, social and governance risks and opportunities directly with companies.
Find fund management companies that makes use of expert external research companies. This can help deliver specialist expertise and means resources are pooled with other investors.
Finds organisations / fund managers that have one or more ESG/sustainability experts on all investment teams or 'desks' (all asset types)
Accreditations
Finds organisations / fund managers that have an A+ PRI rating - meaning they are highly rated according to the 'Principles of Responsible Investment'
Find fund managers that are signatories to the FRC UK Stewardship Code, which sets out a framework for constructive investor / investee relations where fund managers are encouraged to behave like responsible, typically longer term 'company owners'.
Engagement Approach
Find fund management companies that regularly initiate or run industry wide (collaborative) investor projects aimed at raising environmental, social and governance standards amongst investee companies.
Find fund management companies that are working with the companies they invest in to encourage more responsible corporate taxation.
Fund manager has stewardship /responsible ownership strategy that is focused on addressing climate change with investee assets.
Asset manager has a stewardship /responsible ownership strategy that involves working with fossil fuel companies on climate change related issues. See fund manager website for details.
Asset manager has stewardship /responsible ownership strategy with involves encouraging investee asset to reduce plastic waste and pollution.
Asset manager has a stewardship / responsible ownership policy that means they are working to encourage more responsible mining practices - where environmental and social issues are properly dealt with by the companies they invest in.
The asset manager has a responsible ownership / stewardship strategy that focuses on biodiversity and nature issues relating to the assets they invest the aim of which will be to reduce harm and or deliver improvement. Strategies vary. https://tnfd.global
Asset manager has a responsible ownership / stewardship strategy which means they are working to encourage the shift to more sustainable business practices in ways that respect and are sensitive to social issues and the impact change has on people effected by the changes that are taking place. https://www.transitionpathwayinitiative.org/ https://transitiontaskforce.net/
Asset manager has responsible ownership / stewardship strategy in place which aims to address human rights issues in investee companies (and potentially their suppliers) with the aim of raising standards
Asset manager has responsible ownership / stewardship strategy in place that aims to improve labour standards for the benefit of employees in investee companies (and potentially their suppliers)
Asset management company has a stewardship strategy in place which involves working to raise diversity, equality and inclusion standards across investee assets
Fund managers have stewardship strategies in place that focus on improving governance standards across investee assets
Asset manager has stewardship strategy in place which involves discussing mental health issues with investee companies - with the aim of raising standards
Has a stewardship / responsible ownership strategy that encourages responsible supply chain - ie the managers will discuss environmental, social and governance issues with investee companies with the aim of raising standards
Company Wide Exclusions
Find fund management companies (not funds) that avoid investment in 'controversial weapons' across all of their funds and other investment vehicles.
Climate & Net Zero Transition
Fund management organisations that have pledged to reduce their greenhouse gas emissions to ‘net zero’. Strategies vary - this area is changing rapidly.
Fund manager AGM / EGM voting strategy has processes in place that mean they will normally be expected to vote in a way that will encourage the transition to net zero greenhouse gas emissions.
This asset management company has set a date by which they plan to achieve net zero greenhouse gas / CO2e emissions.
Find fund management companies that are working with the companies they invest in to encourage reductions in carbon dioxide and other greenhouse gas emissions.
Finds organisations / fund managers that have a company wide carbon transition plan - meaning that they have plotted a path to how they will move away from activities that produce or use carbon based energy sources (that emit greenhouse gases) towards clean, alternative, renewable energy sources.
Finds organisations / fund managers that have published ‘forward looking climate metrics’ e.g. 'implied temperature rise' data that are a total of the asset management company's share (% owned) of all the investee company emissions of the assets they manage, as well as their own direct and other indirect emissions.
This asset management company plans to achieve net zero greenhouse gas (CO2e) emissions with the help of a scheme that will lock away an amount of carbon that is equivalent to the company’s own emissions – so that the end result is ‘net zero’. Calculations and scope vary.
Find fund management companies that are working to reduce their own (fund management company) carbon/greenhouse gas emissions.
Finds organisations / fund management companies that are in the process of working out how to make a ‘net zero commitment’ - meaning that when that is finalised they will have started the process of reducing their total greenhouse gas emissions to'zero'.
See https://sciencebasedtargets.org/
Transparency
Find fund management companies that publish a report detailing their responsible investment ownership - also known as 'Stewardship' - activity.
Find companies that publish information about their sustainable and responsible investment strategies on their company website.
Find fund management companies that will supply information about their sustainable and responsible investment activity on request.
Fund management companies that publish a full record of how they vote their shares at AGMs (annual general meetings) and EGMs (extraordinary general meetings). Voting strategies have an important role to play encouraging higher environmental, social and governance standards.
This asset management company has published a plan that explains how they are to become a sustainable business - without significant negative environmental or social impacts.
This asset management company has published a plan that explains how they will align to the climate change commitments made at the Paris Climate Talks, COP21.
This asset management company has published a plan that explains how they are going to achieve net zero greenhouse gas / CO2e emissions.
Find fund management companies that have supplied Dialshifter information. See Dialshifter tab within record for more information.
Sustainable, Responsible &/or ESG Policy:
Investment Philosophy
Our responsible investment philosophy is based on three pillars:
- Avoid: Avoid companies with damaging or unsustainable business practices
- Invest: Invest in companies that make a positive contribution to society and the environment
- Improve: Use influence as an investor to encourage best practice management of ESG issues through engagement and voting
This philosophy underlies the process that is applied to define the investable universe through screening, the subsequent investment analysis, stock selection and active ownership. Our company selection approach is broadly summarised below:
High quality business
- Competitive advantages
- Long-term growth drivers
- Strong sustainability characteristics
- Understandable
Strong management
- Proven management team
- Consistent execution
- Responsible capital allocators
- Appropriate incentives
Attractive price
- Identification of long-term value creators
- Sustainable superior returns
- Margin of safety
- Use of discounted cash flow & relative valuation
- How well a company manages its ESG responsibilities is an indicator of management quality, long-term strategic thinking and the resilience of a business. Companies that perform well on these metrics should create more sustainable shareholder value over time. We try to seek these sustainability leaders or potential leaders.
- We explicitly focus our investment horizon on the long term and find that particular themes linked to sustainable development are a rich source of ideas.
- We favour companies with proven business models, delivering consistent returns and stable cash flow and where management have proven themselves to be responsible allocators of capital with high standards of corporate social responsibility.
- We apply a disciplined valuation process to determine attractive entry points to take long term positions (with the aim of a holding period of at least 5 years).
- Post investment we endeavour to develop relationships with the company management and board to engage in a constructive ongoing dialogue on all elements of business strategy including key environmental, social and governance issues. We believe we have a responsibility as shareholders to exercise the rights and responsibilities of ownership and that through engagement and active voting we can encourage companies towards meeting or setting best practice in the management of ESG issues. This should ultimately support long term performance, reduce risk and contribute to promoting a fairer and more sustainable world.
Process:
Investment Process
There is a five-step investment process led by the Global Equities team:
- Idea generation
- Ethical and sustainability screening
- Fundamental analysis
- Portfolio construction
- Engagement and proxy voting
Step 1: Idea generation (Global Equities team)
The process starts with idea generation on the investment team. We find a rich source of ideas comes from considering long term social and environmental themes, looking across industries and along value chains. We believe companies that are contributing to solutions to key sustainability challenges, and building successful business models around this will see a long-term tailwind to their growth opportunities. The identification of themes helps to focus our analytical efforts rather than imposing a strict thematic structure on the portfolio, our themes are outlined below:
- Connect and protect – technological advances create opportunities to accelerate our connectivity, and progress social well-being, supply chain efficiencies and sustainable cities.
- Digital empowerment – data can be harnessed for good, to enable better healthcare or empower smaller businesses, which can lead to broader competition and employment opportunities.
- Energy transition – transformation is required across all types of energy use, including power generation and transport.
- Health and well-being – with increased globalisation and urbanisation comes rising communicable diseases. With ageing demographics, rising obesity and an increasing prevalence of non-communicable diseases, the demand for healthcare is rising while the supply remains constrained, particularly in emerging markets.
- Resource efficiency – we must use our planet’s finite resources in a more sustainable way, while minimising the impact we have on the environment.
- Sustainable cities – a growing global population puts cities under increasing stress, such as the provision of reliable healthcare and education, and environmental challenges such as global warming.
- Sustainable finance – by integrating sustainability into their business strategies and decision-making, financial institutions can play a significant role in adapting and promoting innovation to address global sustainability challenges.
We additionally try to look for companies who are leaders, or have the potential to show meaningful improvement, in how they manage key ESG issues, whether or not their business fits a particular theme. Additional input into idea generation comes from the experience available through other internal equity teams. Research and company meetings are shared across all equity desks. External input includes sell-side research, conferences, industry experts and macro considerations. Any companies not already in the acceptable universe are then put forward to the Responsible Investment team for screening against the strategy’s acceptability criteria.
Step 2: Ethical and sustainability screening (Responsible Investment team)
All stocks considered for investment first undergo screening by members of the Responsible Investment team, to determine if they meet the criteria for inclusion in the portfolio’s investable universe. The Responsible Investment team has created a thorough and robust process to analyse companies to determine whether they meet the strategy criteria:
- The Strategy will exclude companies with exposure to any business activities deemed to be socially or environmentally damaging, with particular tolerance thresholds. These excluded activities have adapted over time with the development of major social and environmental issues.
- The Strategy will also exclude companies which do not meet sufficiently high standards in how they operate, based on a detailed assessment of their policies and performance with respect to overall sustainability management. The focus will vary by sector according to relevance and includes certain absolute exclusions in company behaviour but is otherwise often a qualitative judgement. In order to make these assessments, we have established particular positions on a range of relevant issues, such as climate change and what we consider to be progressive approaches to these issues by companies. These positions are based on a range of inputs that include evolving international norms and agreements, extensive primary research, including field visits and the input of our Responsible Investment Advisory Council.
The independent Responsible Investment Advisory Council is also involved in reviewing the approvability ratings of companies as well as in developing the screening criteria for the strategy and targeting engagement activity. Input is also frequently sought from a range of stakeholders.
The Responsible Investment team has a quarterly monitoring system to identify:
- Changes to business e.g. through mergers and acquisitions
- Whether the criteria continue to be met by the company (ethical, environmental and social)
- Any controversies that may affect the company rating (e.g. mis-selling, environmental damage or corruption).
Step 3: Fundamental analysis (Global Equities and Responsible Investment teams)
Stocks that enter the investment universe undergo a process of fundamental investment analysis by the Global Equities team. Sector research responsibilities are allocated across the team. This ensures that there is a ‘centre of excellence’ for each sector and theme within the team, with a thorough understanding of the drivers affecting each sector and theme as well as the relative position of the constituent companies within them. However, this is not an exclusive process and individuals can champion ideas in any sectors.
We believe the key to superior investment performance lies in investing over the long term in high-quality companies that are attractively valued. For any potential investment we will:
- Develop a detailed understanding of the company’s business model and market
- Understand key business drivers
- Understand the sensitivity to changes in these key drivers
- Determine the strengths and potential weaknesses of the management team
- Consider how the company is positioned within its specific markets, how strong the competition is and the scale of pricing and cost pressures
- Identify catalysts which may impact the share price.
The RI team and the Global Equities team work together to fully incorporate ESG risks and opportunities into the fundamental valuation of each company. To flag key Environmental, Social, and Governance risks and opportunities, the Global Equities team works with the RI team and an important data source that we use is Morgan Stanley Capital International (MSCI) ESG Research ratings and analysis. The MSCI ESG approach identifies key issues by industry for each company and rates companies on social, environmental and governance performance both in absolute terms and relative to their specific industry. We also review a list of what we consider to be 20 key governance indicators and also any significant controversies a company may have been involved in.
However, whilst ESG data quality has improved over time, it is still not perfect. We therefore also
make our own assessments through the RI team’s own analysis of ESG considerations and engagement efforts, in order to establish our own views of all material ESG risks and opportunities facing a company. Our RI team therefore leverages their experience across different ESG issues and ‘scrubs’ the MSCI data where we see deficiencies, in order to arrive at cleaner ESG data points that leverage the breadth of the MSCI coverage, but yet the depth of ESG knowledge within our RI team.
With increasing rhetoric from both the fund management industry and within the investee corporate landscape regarding sustainability, we look to stay true to what our investors expect of us; that we are clearly, deliberately and diligently investing in companies that are truly delivering upon sustainability challenges. With that in mind, the A.I.M. framework was established:
- Additionality: Is the company a leader in its industry, making a real difference to the positive direction of the industry? Here we focus on and evidence the fund’s exposure through our view of high quality, wide moat businesses.
- Intentionality: How core is sustainability to the company’s strategy and overall raison d’être? Here we leverage our extensive engagement capability to assess the company’s transparency and communication around strategic goals, which will evidence the management team and Board’s intentions in prioritising these issues/opportunities.
- Materiality: How material are sustainability opportunities for the company? Here, we make an assessment of the company’s revenue alignments to our 7 sustainability themes.
When it comes to valuation, we place particular emphasis on cash flows as we believe these provide the most rigorous base for analysis of the underlying financial strength, and therefore quality, of any company. Discounted cash flow models (DCFs) are a key component of our valuation work to determine a ‘conservative assessment of the intrinsic value’ of a share price (CAIV). DCFs are also an important tool to help us determine the margin of safety in a stock by looking at what is implied in the current share price.
Here, ESG factors are considered directly in the analysis of the business model and the assessment of management quality. We factor them into the valuation by flexing assumptions and discount rates as appropriate. For example, we may flex revenue or profitability assumptions across different outcomes reflecting ESG risks and opportunities.
The inputs into our proprietary “alternate weighted average cost of capital” (ALT-WACC) used as a discount rate within our DCF analysis also incorporate our views on ESG risks/opportunities as well as our sustainability assessment as depicted above.
At the end of this process, a formal investment research note is produced by the analyst and discussed with the wider team. Stocks researched by the team are rated 1 (most positive), 2 (neutral), or 3 (most negative). The ratings are active with no neutral rating, determined by the combination of margin of safety and upside to their ‘intrinsic value’ and the level of confidence we have in the quality of the business. The forum for discussing research is our twice weekly research meetings. These are rigorous and thorough meetings during which an analyst will present their research on a stock which must stand up to detailed scrutiny by the team.
Step 4: Portfolio construction (Global Equities team)
The output of the fundamental analysis forms the basis of portfolio construction. We consider that higher quality companies will justify a larger active position on the portfolio. Timing, regional, sector and aggregate risk considerations are taken into account. Analytical responsibilities are divided between the team by sector or theme specialisation. Daily desk discussion of ideas exchange and news-flow monitoring is supplemented by a more formal weekly Stock Review Meeting and Portfolio Construction Meeting; ensuring that monitoring and review at team level takes place.
The Strategy observes the following self-imposed limits:
- Stock constraints: We typically hold between 40-60 stocks in the portfolio. Most position sizes will typically be in the 1.0%-5.0% active weight range.
- Country/Sector/Industry constraints: We do not impose any formal limits; however, diversification is considered as part of the portfolio construction process. In terms of geographical exposure, we typically limit our regional position to +/-10 percentage points relative to benchmark, to ensure the majority of risk in the portfolio remains stock specific.
The biggest constraint that applies to our portfolio construction is the ethical and sustainable screening process that defines the investable universe and will result in certain structural biases, such as an underweight position relative to the benchmark in extractive industries. The Strategy has a predictable style bias to mid-cap and growth companies that results partly from the screening process and partly from the investment style of the portfolio managers. The approved list is hard-coded into the dealing system to avoid inadvertently investing in unacceptable securities. The risk profile of the overall portfolio is reviewed on a regular basis in which we ensure:
- Stock-specific risk comprises the main element of the risk budget.
- The main stock contributors to tracking error are consistent with the intended shape of the portfolio.
- The risk contribution from countries and sectors is consistent with the intended shape of the portfolio.
- The risk budget is appropriately spread across the main positions.
- Tracking errors are consistent with the portfolio objectives.
- Positions by country, sector and stock are within mandate restrictions.
Individual weightings are initially determined by the strength of conviction of each idea on a risk adjusted return basis, taking into account the quality of the investment thesis.
Sell discipline
Our sell discipline is not rules based, but a sale would likely be triggered by a fundamental breach of the investment case, or a stock becoming fully valued with no further upside foreseen over the medium term.
Step 5: Engagement and proxy voting (Global Equities and Responsible Investment teams)
We operate an active ownership policy, and seek to influence positive change and support best practice through engagement and voting. After meeting the ethical and sustainability screening standards, we will engage companies and encourage them to meet or set emerging best practice in the management of key ESG issues. We engage on company specific issues, sector and broader thematic issues and at public policy level. Our aim is to reduce risk to enhance long term performance, and to encourage a positive contribution to broader social and environmental issues. We use constructive confidential dialogue, typically working one to one with companies, but taking a collaborative approach where this has more impact. We will vote at all shareholder meetings of companies under the strategy, based on its detailed proxy voting guidelines.
Resources, Affiliations & Corporate Strategies:
Responsible Investment Team
We have a dedicated in-house Responsible Investment (RI) team, one of the most experienced and established teams of its kind. The award-winning 40+ member team supports our clients, our investment teams and our overall business through expertise across ESG thematic research, ESG integration, ESG policy, client reporting and thought leadership content. Beyond these core activities, the team also supports a plethora of activity from representation on responsible investment industry groups, public policy contribution, ESG thought leadership, ESG product development, portfolio level ESG analytics, screening for specialist ESG portfolios and reporting on active ownership activities. Active ownership is a key aspect of our RI work, and within the team there are more than 20 professionals focused on engagement and voting activity.
The RI team works hand in hand with our research and investment professionals to enrich their understanding of key sustainability trends as they relate to specific sectors and issuers, collaborating to highlight risks and opportunities within industries and sectors, informing investment decisions across asset classes.
The RI team was awarded ‘Best ESG Research Team’ at the 2018, 2019 and 2020 Investment Week Sustainable & ESG Investment Awards, ‘Best ESG Reporting – Asset Manager: Large’ at the 2019 Environmental Finance Awards, and ‘Best ESG Research: Fixed Income’ at the 2020 Environmental Finance Awards. We were also awarded ‘Best ESG Fund House’ at the 2022 ESG Clarity Awards.
Responsible Investment Advisory Council
The Council is a six-member committee of experts, who are leaders in their fields and bring international experience across responsible investment, ethical, environmental, and social issues. Their primary role is to provide advice on the ethical criteria for our specialist Responsible strategy range. The Responsible Investment team is also able to draw on their expertise in informing our broader engagement and responsible investment approach.
The Council’s president is the Most Reverend Justin Welby, Archbishop of Canterbury. The Chair, who heads the quarterly meetings, is Howard Pearce, formerly Head of Environmental Finance and Pension Fund Management at the UK’s Environment Agency Pension Fund (EAPF). More detail on the Council can be found here.
Affiliations & Memberships
We make efforts to promote responsible investment in multiple ways, including participation in speaking engagements, industry working groups, responsible investment conferences and collaborative initiatives.
A list of key responsible investment memberships and affiliations for Columbia Threadneedle Investments is shown below.
- Environmental
Climate Action 100+
Climate Action 100+ is an investor initiative launched in 2017 to ensure the world’s largest corporate greenhouse gas emitters take necessary action on climate change. We are a member of the investor coalition, leading 8 and supporting 38 engagements.
Date of joining: CTML: 2017, TAML: 2021
Transition Pathway Initiative (TPI)
A PRI sponsored initiative; this is an asset-owner led initiative which assesses companies' preparedness for the transition to a low carbon economy. It is supported by London School of Economics, a research driven initiative on high emitting sectors carbon transition and strategic/management commitment to address climate transition.
Date of joining: CTML: 2020, TAML: 2021
Net Zero Asset Managers Initiative
Founder signatory of this international group of asset managers committed to supporting the goal of net zero greenhouse gas emissions by 2050 or sooner, in line with global efforts to limit warming to 1.5 degrees Celsius; and to supporting investing aligned with net zero emissions by 2050 or sooner.
Date of joining: CTML: 2020, TAML: 2021
Carbon Disclosure Project (CDP)
Non-profit organisation that runs the global disclosure system for investors, companies, cities, states and regions to manage their environmental impacts. We are member of the investor coalition, leading and supporting several engagements.
Date of joining: CTML: 2000, TAML: 2005
Carbon Trust
We partner this organisation that supports companies to accelerate towards Net Zero. From target setting, Net Zero pathways, assurance and footprinting, to policy advice, strategy setting and programme delivery.
Date of joining: 2010
Task Force on Climate-related Financial Disclosures (TCFD)
We have committed to producing reporting as part of TCFD, an organisation that was established in December 2015 with the goal of developing a set of voluntary climate-related financial risk disclosures.
Date of joining: CTML: 2020, TAML: 2022
Sustainability Accounting Standards Board (SASB)
ESG standard setter (Member Standards Advisory Group & sub-groups). SASB guides the disclosure of financially material sustainability information by companies to their investors.
Date of joining: 2018
Science Based Targets initiative (SBTi)
The SBTi is a partnership between CDP, the United Nations Global Compact, World Resources Institute (WRI) and the Worldwide Fund for Nature (WWF). Guides companies to set science-based targets to mobilize the private sector to take urgent climate action.
Date of joining: 2020
Impact Investing Institute
Focuses on the development of outcome related investment, to encourage more investment made with the intention to generate positive, measurable social and environmental impact alongside a financial return. TAML is a Founding supporter and member of the Advisory Council and working group for the Green+ Gilts
Date of joining: 2020
Institutional Investor Group on Climate Change (IIGCC)
IIGCC works with business, policy makers and investors to help define the investment practices, policies and corporate behaviours required to address climate change. A member of the RI team serves on the Board. We lead and support several engagements.
Date of joining: 2001
IIGCC's Global Investor Statement
A joint statement coordinated by the seven Founding Partners of The Investor Agenda to all world governments urging a global race-to-the-top on climate policy and warns that laggards will miss out on trillions of dollars in investment if they aim too low and move too slow.
Date of joining: 2009
IIGCC’s Investor Position Statement on Transition Planning
Signatory of this investor statement by 56 leading investors calling for the implementation of new corporate governance measures to ensure shareholders can hold companies to account in achieving net zero emissions commitments.
Date of joining: 2021
Ceres Land Use and Climate WG (Biodiversity)
Ceres works with the most influential capital market leaders to advance innovative solutions to the climate crisis and achieve a zero emissions future where people and the planet can prosper.
Date of joining: 2020
Cerrado Manifesto SoS
Public statement committing to halt deforestation in the Cerrado, adopt sustainable land management practices and mitigate financial risks associated with deforestation and climate change. It is endorsed by global FMCG companies and institutional investors.
Date of joining: 2021
ChemScore
Benchmark created by NGO International Chemical Secretariat (ChemSec). It ranks the world’s top 50 chemical producers on their work to reduce their chemical footprint.
Date of joining: 2021
Nature Action 100
Founding member of investor-led collaborative engagement programme to engage with companies and policymakers on nature.
Date of joining: 2022
Taskforce for Nature-related Financial Disclosures
As a forum member, we support the taskforce aiming to develop and deliver a risk management and disclosure framework for organisations to report and act on evolving nature-related risks.
Date of joining: 2020
Sustainability Policy Transparency Toolkit (SPOTT)
SPOTT scores palm oil, tropical forestry, and natural rubber companies annually against over 100 sector specific ESG indicators to benchmark their progress over time. As an investor supporter we express need for enhanced transparency.
Date of joining: 2019
Investor Policy Dialogue on Deforestation
Collaborative investor initiative set up to engage with public agencies and industry associations on the issue of deforestation. The goal is to coordinate a public policy dialogue on halting deforestation. We are a member of the Advisory Council, leading/supporting engagements going forward.
Date of joining: 2021
ShareAction Chemicals Working Group
Investor group focused on engagement with the chemicals sector on decarbonisation.
Date of joining: 2021
- Social
Global Network Initiative (GNI)
Member of this initiative seeking to safeguard freedom of expression and personal privacy against government restrictions. The protections are facilitated by a coalition of companies, investors, civil society organisations, academics, and other stakeholders.
Date of joining: CTML: 2008, TAML: 2002
Interfaith Centre on Corporate Responsibility (ICCR)
Coalition of over 300 global faith- and values-based institutional investors. We are members of the Food Justice and Racial Equity workstream.
Date of joining: 2020
ICCR's Investor Alliance on Human Rights (IAHR)
Part of the ICCR, IAHR provides a collective action platform to facilitate investor advocacy on a full spectrum of human rights and labour rights issues.
Date of joining: 2020
ICCR's Investors for Opioid and Pharmaceutical Accountability (IOPA) Part of the ICCR, IOPA addresses the fallout of the opioid crisis and other business risks by seeking accountability and mitigating further risk at pharmaceutical companies through comprehensive shareholder reforms.
Date of joining: 2021
ShareAction Good Work Coalition
Investor engagement initiative aimed at driving up standards in the workplace. Engagement focus on labour standards, living wage standards, accreditation, transparency of the FTSE350, extension to DEI with a focus on ethnic diversity.
Date of joining: 2021
ShareAction Healthier Markets Investor initiative aimed at improving children's health by increasing access to affordable, healthy food.
Date of joining: 2021
Access to Medicine Foundation
Member of the investor coalition, leading and supporting several engagements. Independent, non-profit organisation working to stimulate and guide the pharmaceutical industry. Produces the Access to Medicine Index, Antimicrobial Resistance Benchmark, Access to Vaccines Index.
Date of joining: 2021
Investor Action on Antimicrobial Resistance (AMR)
A coalition between the Access to Medicine Foundation, the FAIRR Initiative, the Principles for Responsible Investment and the UK Government Department of Health and Social Care to galvanise investor efforts to address global AMR. We are leading and supporting engagements.
Date of joining: 2021
Investor Initiative for Responsible Care
Collaborative engagement group coordinated by UNI Global Union focused on working standards and quality of care in the listed nursing care sector.
Date of joining: 2022
Workforce Disclosure Initiative (WDI)
Disclosure body. We are Signatory, member of the Advisory Group; leading/supporting several engagements. Investor initiative aimed at improving corporate transparency and accountability on workforce issues. Provide companies and investors with comprehensive and comparable data.
Date of joining: CTML: 2021, TAML: 2020
Global Investor Collaboration on Farm Animal Welfare & Global Investor Statement on Farm Animal Welfare
Engagement collaboration with BBFAW (Business Benchmark on Farm Animal Welfare), member of the investor coalition, supporting and leading several engagements.
Date of joining: 2021
Platform Living wage Financials
Coalition of financial institutions that encourages and monitors investee companies to address the non-payment of living wage in global supply chains. We are chair of the Platform's Garment Working Group; member of the Food, Retail and Agri working group.
Date of joining: 2020
Find it, fix it, prevent it
Engagement collaboration. Member, leading on engagements. Investor led initiative targeting UK-listed companies to demonstrate commitment to eradicating modern slavery from their supply chains.
Date of joining: CTML: 2020, TAML: 2021
KnowTheChain
Engagement collaboration. Member of the investor coalition, supporting several engagements. KnowTheChain is a resource for companies and investors to understand and address forced labour risks within their global supply chains.
Date of joining: 2021
Access to Nutrition Index
Engagement collaboration. Member of the investor coalition, supporting several engagements. Independent, non-profit organisation producing the Access to Nutrition Index. Benchmark evaluates the world's largest food and beverage manufacturers' policies and performance related to the world's most pressing nutrition challenges: obesity and undernutrition.
Date of joining: 2021
Human Capital Management Coalition (US)
Engagement collaboration. Member of the coalition of investors to elevate human capital management. Engages companies and other market participants with the aim of understanding and improving how human capital management contributes to the creation of long-term shareholder value.
Date of joining: 2021
Investors for Racial Justice
Member of this information sharing network and engagement collaboration.
Date of joining: 2020
Votes Against Slavery 2022
Member of this investor collaboration engaging with FTSE 350 companies on their compliance with the Modern Slavery Act 2015. We joined the collaboration for the 2021 campaign.
Date of joining: 2021
- Governance
International Corporate Governance Network (ICGN)
Member of investor led organisation advancing the highest standards of corporate governance and investor stewardship worldwide in pursuit of long-term value creation.
Date of joining: CTML: 2007, TAML: 2017
Investment Association (IA)
Member of UK industry body; facilitates the monitoring and responding to ESG policy and regulatory changes impacting our activities.
Date of joining: CTML: 2000, TAML: 1998
Corporate Governance Forum
European focus - UK based asset management governance teams. Informal discussion on companies and industry issues.
Date of joining: 2012
Global Institutional Governance Network (GIGN)
US/Global focus - Global asset management governance teams. Discussions on companies and industry issues.
Date of joining: 2012
Council of Institutional Investors (CII)
Member of this non-profit organisation promoting effective corporate governance policies.
Date of joining: 1996
Investor Forum
Member and proactive collaborator with the Forum, which helps investors to work collectively to escalate material issues with the Boards of UK-listed companies.
Date of joining: 2005
Asia Corporate Governance Association
Member of independent, non-profit membership organisation dedicated to working with investors, companies and regulators in the implementation of effective corporate governance practices throughout Asia.
Date of joining: CTML: 2004, TAML: 2010
Asia Research & Engagement (ARE)
Engagement collaboration. Organisation that structures, implements and assembles investor collaborative engagement programmes across Asia. Performs in-depth industry and company research that provides strategic insight into key ESG issues to underpin engagement work.
Date of joining: 2021
Pre-Emption Group (PEG)
Members of the UK Capital markets group that sets guidelines on the application/dis-application of pre-emption rights in UK capital issuance.
Date of joining: 2016
30% Club UK Investor Group
Campaign for greater representation of women on company boards. Member of the investor coalition, leading and supporting several engagements.
Date of joining: 2021
30% Club France Investor Group
Member of this investor-led group aiming to boost the number of women in board seats and executive leadership of companies in the SBF 120 index.
Date of joining: 2021
30% Coalition (US)
Campaign for greater diversity on company boards. Member of the investor coalition, leading and supporting several engagements.
Date of joining: 2021
Women in Finance Charter
First asset manager signatory to the UK charter committing to support the progression of women into senior roles in the financial services sector, set targets and publicly report on progress against these targets to support transparency and accountability.
Date of joining: 2016
Eumedion
Member of this non-profit organisation aiming to promote good corporate governance and sustainability policies at Dutch listed companies and to promote engaged and responsible shareholding by its members.
Date of joining: 2009
- Environmental, Social & Governance
Principles for Responsible Investment (PRI)
Global responsible investment association, membership is a pre-requisite for many clients. TAML & BMO GAM are Founding Signatories to the UN supported PRI. CTML, formerly known as BMO GAM EMEA, was part of BMO GAM at the time of becoming a signatory. BMO GAM EMEA business was acquired by Ameriprise Financial, Inc. in 2021. CMIA became a signatory in 2014.
Date of joining: CTML & TAML: 2006, CMIA: 2014
UK Stewardship Code
Set of principles for asset owners and managers. We are signatories of the 2020 code.
Date of joining: 2012
Investor Stewardship Group (ISG)
Members of the network of investors and asset managers formed to promote good practice in stewardship and corporate governance, specific to the US.
Date of joining: 2018
Investment Company Institute (ICI)
US Industry body; facilitates the monitoring and responding to ESG policy and regulatory changes impacting our activities.
Date of joining: 2019
UK Sustainable Investment and Finance Association (UKSIF)
Network focused on the UK sustainable investment market, pre-requisite for FNG certification. A member of the RI team chairs the Policy Committee.
Date of joining: CTML: 2000, TAML: 2020
Taiwan Stewardship Code
Signatory to the Taiwan Stewardship Code, which is based on a ‘comply or explain’ approach.
Date of joining: 2022
Japan’s Stewardship Code
Signatory to Japan’s Stewardship Code, which is maintained by Japanese Financial Services Agency, based on a ‘comply-or-explain’ approach where signatories comply with the principles of the code or explain why they do not comply.
Date of joining: 2022
Global Real Estate Benchmark (GRESB)
Member of this organization whose data facilitates our ability to track trends in corporate environmental and social risk management performance as it relates to property.
Date of joining: 2013
London Stock Exchange
Members of the LSE’s Primary Markets Group, advising on primary market issues.
Date of joining: 2012
The Big Exchange
TAML is a founding partner and members of the Impact Committee.
Date of joining: 2019
Global Impact Investing Network (GIIN) Member of this leading non-profit dedicated to increasing the scale and effectiveness of impact investing
Date of joining: 2020
FAIRR Collaborative investor network that focuses on ESG risks and opportunities around animal agriculture.
Date of joining: 2021
Investor Tailings Safety Initiative & Investor 2030 Mining Agenda We are the founding supporter of this initiative and will co-lead on some of the corporate engagements.
Date of joining: 2021
Centre for Audit Committee and Investor Dialogue Network initiative that enables investors, audit committee members and auditors to discuss issues of common interest.
Date of joining: 2013
International Capital Markets Association (ICMA)
The development of green, social and sustainability bond principles relevant to our fixed income investments in an RI context. Members of the Social Bond Working Group and members of working groups on the SDGs and on impact reporting.
Date of joining: 2016
Source: Columbia Threadneedle Investments, as at March 2023. Includes memberships held by CMIA, TAML, CTML and other group affiliates. CMIA = Columbia Management Investment Advisors, LLC; TAML = Threadneedle Asset Management Limited; CTML = Columbia Threadneedle Management Limited.
Fund Holdings
Disclaimer
Important Information
PRIVATE AND CONFIDENTIAL
All information provided within this document is for the attention of the addressee only and solely for the purpose of evaluating the investment and advisory management services available from Columbia Threadneedle Investments. The information provided is on the basis that it remains private and confidential between the addressee and Columbia Threadneedle Investments. Accordingly, the addressee is not permitted, in the event that a request for information is made under the Freedom of Information Act 2000, to disclose any of the information provided herein by Columbia Threadneedle Investments, given the duty of confidentiality that exists as between Columbia Threadneedle Investments and the addressee. Columbia Threadneedle Investments is the global brand name of the Columbia and Threadneedle group of companies.
CONTRACTUAL AGREEMENT
This document is issued by Columbia Threadneedle Management Limited. Should you decide or wish to receive the services detailed within this document, your contractual agreement will be with Columbia Threadneedle Management Limited. This entity is a wholly owned subsidiary of Columbia Threadneedle Investments UK International Limited, whose direct parent is Ameriprise Inc., a company incorporated in the United States.
Past performance should not be seen as an indication of future performance. The value of investments and income derived from them can go down as well as up as a result of market or currency movements and investors may not get back the original amount invested. The information, opinions, estimates or forecasts contained in this document were obtained from sources reasonably believed to be reliable and are subject to change at any time.
The “Firm” referred to herein is part of the group of legal entities acquired by Ameriprise Financial Inc. on 8th November 2021. On 4th July 2022, we reached a significant milestone in the integration of our businesses being rebranded as Columbia Threadneedle Investments. We have made significant progress with the integration of our businesses, and while we now present ourselves externally as a single brand, there may be instances where the Firm’s legacy functions, systems, teams or policies remain in place until further integration milestones are reached. Where applicable, this document may make reference to such functions, systems, teams or policies, with any such references being subject to change as the integration work continues.
Fund Name | SRI Style | SDR Labelling | Product | Region | Asset Type | Launch Date | Last Amended |
|
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Aviva Pension CT Responsible Global Equity Pn |
Ethical Style | - | Pension | Global | Equity | 29/09/2008 | Jun 2023 | |
ObjectivesThe fund aims to achieve capital growth over the long term (at least 5 years). |
Fund Size: £26.71m (as at: 30/11/2024) ISIN: GB00B3CT5Z57, GB00B689DG70, GB00BKKZR146 Contact Us: clientsupport@columbiathreadneedle.com |
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Sustainable, Responsible &/or ESG OverviewThis Pension product is linked to the "CT Responsible Global Equity" fund. The following information refers to the primary fund. Awaiting update from manager - last updated June 2023 The objective is to achieve long-term capital growth. The Fund is actively managed. It is not constrained by its comparator benchmark, the MSCI World TR Index, and has significant freedom to invest in a portfolio that is materially different to the benchmark’s own composition. The Fund seeks to achieve this by investing in companies in any market screened against defined responsible and sustainable criteria, including exclusions on tobacco, alcohol, weapons, gambling, nuclear and pornography. The Fund also requires companies to meet sector standards on social and environmental issues, including systems for managing labour standards, human rights, supply chains, environmental impacts, water, waste, and biodiversity. |
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Primary fund last amended: Jun 2023 |
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Information received directly from Fund Manager |
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Fund FiltersSustainability - General
Sustainability policy
Funds that have policies that consider (environmental and social) sustainability issues. Strategies vary but are likely to consider environmental issues like climate change, carbon emissions, biodiversity loss, resource management, environmental impacts; and social issues like equal opportunities, human rights, labour standards, diversity and adherence to internationally recognised codes. See fund information.
Sustainability focus
Find funds which substantially focus on sustainability issues
Encourage more sustainable practices through stewardship
A core element of these funds aim to encourage higher sustainability standards across business practices through responsible ownership / stewardship / engagement / voting activity
UN Global Compact linked exclusion policy
Find funds that use the UN Global Compact to inform or help direct where they can or cannot invest and will typically not invest in companies with significant breaches (low standards) - although strategies vary. (The UNGC covers a wide range of issues - search 'UNGC'). See https://unglobalcompact.org/
UN Sustainable Development Goals (SDG) focus
Find funds that specifically aim to invest (and manage assets) in ways that help to address all or some of the UN's Sustainable Development Goals (SDGs). See https://sdgs.un.org/goals).
Report against sustainability objectives
Find funds that publicly report their performance against specifically named sustainability objectives (in addition to reporting their financial performance) Environmental - General
Environmental policy
Funds that have policies which relate to environmental issues. These will typically set out the fund's stance on issues such as pollution, climate change, resource management, biodiversity loss, carbon emissions, plastics and/or additional environmental impacts. Strategies vary. See fund information for further information.
Limits exposure to carbon intensive industries
Funds that limit or 'reduce' their exposure to carbon intensive industries (ie sectors which are major contributors to climate change. Funds vary - some funds may be 'underweight' in this area which means they may have some investment in highly carbon intensive areas. Funds of this kind may choose companies they consider to be 'best in sector' and encourage ever higher standards. Strategies vary. See fund information for further details.
Environmental damage and pollution policy
Funds that have written policies explaining the approach they take when companies damage the environment or are significant polluters. Funds of this kind may work with companies to encourage higher standards, or exclude companies - sometimes dependent on the situation. Strategies vary. See fund information for further detail.
Favours cleaner, greener companies
Funds that aim to invest in companies with strong or market leading environmental policies and practices. Strategies vary - in particular the balance between 'financial' aspects and environmental benefits. Some may invest substantially in solutions or 'positive impact' companies - others may invest in more conventional companies providing certain environmental criteria are met. See fund information for further detail. Nature & Biodiversity
Biodiversity / nature policy
Find funds that have a written biodiversity policy or theme aimed at encouraging and improving environmental protection and safeguarding the natural world (sometimes referred to as the preservation or enhancement of 'natural capital'). See eg https://www.un.org/en/climatechange/science/climate-issues/biodiversity
Deforestation / palm oil policy
Find funds that have policies in place designed to ensure they do not invest in companies that are significantly involved in deforestation. This typically relates to palm oil plantations where biodiversity loss is a major concern (as well as other issues). Strategies vary. See fund information for further detail.
Illegal deforestation exclusion policy
Find funds that have policies in place explaining that they avoid companies involved in illegal and/or unsustainable deforestation. This may relate to palm oil, cattle farming or other concerns. Strategies vary. See fund information for further detail.
Responsible palm oil policy
Fund has a responsible palm oil policy which is likely to focus on the producers of palm oil and deforestation issues with a view to informing investment decisions (and / or engagement) to support and encourage high standards.
Avoids genetically modified seeds/crop production
Find funds that aim to avoid investing in companies that produce genetically modified seeds or crops. (This does not typically include avoiding companies such as supermarkets). See fund literature for further information. Climate Change & Energy
Climate change / greenhouse gas emissions policy
Funds that have policies (documented strategies that explain their position on) climate change related issues such as greenhouse gas/carbon emissions, net zero, transitioning to lower carbon. Strategies vary. Read fund details for further information.
Coal, oil & / or gas majors excluded
Funds that avoid investing in major coal, oil and/or gas (extraction) companies. Funds vary: some may exclude all companies that extract oil. Others may have exposure to oil extraction via more diversified energy companies. See fund literature to confirm details.
Fracking and tar sands excluded
Funds that avoid companies involved in fracking and tar sands - which are widely regarded as controversial methods of oil and gas extraction. Strategies vary. See fund information for further information.
Arctic drilling exclusion
Funds that avoid companies that are involved in extracting oil from the Arctic regions. See fund literature for further details.
Fossil fuel reserves exclusion
Funds that avoid investing in companies with coal, oil and gas reserves. See fund information for further details.
Encourage transition to low carbon through stewardship activity
A core element of these funds will aim to encourage the transition to lower carbon activities through responsible ownership / stewardship / engagement / voting activity
Invests in clean energy / renewables
Funds that hold companies in the clean energy and renewable energy sectors (at the time research was supplied). Fund strategies vary, in particular the proportion of investment in these areas may vary significantly. Check fund literature for details.
Nuclear exclusion policy
Find funds that have policies which say they avoid or limit their investment in the nuclear industry. Strategies vary. See fund information for further detail.
Fossil fuel exploration exclusion - direct involvement
The fund manager excludes companies with direct involvement in fossil fuel exploration (eg coal, oil and gas companies)
Paris aligned fund strategy
This fund has a strategy that aims ensure its holdings will gradually reduce their greenhouse gas emissions in line with targets set at COP21 in Paris. The ultimate aim is to achieve ‘net zero emissions by 2050’ and a ‘maximum global temperature increase of +1.5 to +2 degrees above preindustrial levels’. Strategies and opinions vary. Read fund information.
TCFD reporting requirement (Becoming IFRS)
Will only invest in companies that report greenhouse gas emissions reduction strategies in line with the framework set out the by the Taskforce for Climate Related Financial Disclosure, which is increasingly becoming mandatory. See https://www.fsb-tcfd.org/ https ://www.ifrs.org/sustainability/tcfd/ Social / Employment
Social policy
Find funds that have policies which set out their approach to social issues (e.g. human rights, labour standards, equal opportunities, child labour and adherence to internationally recognised codes such as the UN Global Compact). Funds with social policies typically avoid companies with low standards or work to encourage higher standards. See fund information for detail.
Labour standards policy
Find funds that have a labour standards policy - which can be expected to mean that the fund will invest in / favour companies that have higher standards in this area - although fund strategies can vary significantly (as with all policy areas). See eg https://www.ilo.org/international-labour-standards
Favours companies with strong social policies
Find funds that invest in line with positive strategies that relate to 'people' issues - such as having strong human rights, labour standards and equal opportunities practices. Such funds are likely to invest in companies that have market leading standards with regard to employee and supplier practices. Read fund literature for further information.
Mining exclusion
All mining companies excluded Ethical Values Led Exclusions
Ethical policies
Find funds that have policies that set out their position on ethical or 'personal values' based issues. Strategies vary. See fund information for further detail.
Tobacco and related product manufacturers excluded
Companies are excluded if they are involved in any aspect of the production chain for tobacco products, including cigarettes, vaping, e-cigarettes, chewing tobacco and cigars.
Armaments manufacturers avoided
Find funds that avoid companies that manufacture products intended specifically for military use. Fund strategies vary - particularly with regard to non-strategic military products. See fund literature for fund specific details.
Civilian firearms production exclusion
Find funds with a written civilian firearms exclusion policy - meaning that they will not invest in companies that make (or perhaps also sell) handguns made for non-military users.
Alcohol production excluded
Find funds that avoid investment in companies involved in the production of alcohol. Strategies vary; some funds allow a small proportion of profits to come from this area. See fund literature for further information.
Gambling avoidance policy
Find funds that avoid companies with significant involvement in the gambling industry. Some funds may allow a small proportion of profits to come from this area. See fund policy for further details.
Pornography avoidance policy
Find funds that avoid companies that derive significant income from pornography and related areas. Strategies vary. See fund details for further information.
Animal welfare policy
Find funds with policies that require specific animal welfare standards to be met. These may reference well-known welfare standards (3Rs - Replace, Reduce, Refine) or certification schemes. Strategies vary. See fund information for further detail. Human Rights
Human rights policy
Find funds that have policies relating to human rights issues. Funds of this kind typically require companies to demonstrate higher standards, although some fund managers work to encourage improvements. Investee companies are often judged against internationally agreed norms or standards. Strategies vary. See fund information for further detail.
Child labour exclusion
Find funds that have policies in place to ensure they do not invest in companies that employ children. Banking & Financials
Predatory lending exclusion
Fund excludes financial services companies with widely criticised, aggressive lending practices where interest rates are typically very high, includes ‘doorstep lending’) Governance & Management
Governance policy
Find fund options that have policies that relate to corporate governance issues such as board structure, executive remuneration, bribery and/or corporate corruption. These funds will typically avoid companies with poor practices. Strategies vary. See fund literature for further information.
Avoids companies with poor governance
Find funds that aim to avoid investing in companies with poor governance practices.(e.g. board structure, management practices etc.) Views may however vary on what counts as 'poor' practices - and funds may not immediately divest as they may prefer to work to encourage higher standards. See fund literature for further information.
Encourage board diversity e.g. gender
Fund managers encourage the companies they invest in to have more diverse board structures (e.g. more women on boards)
Encourage higher ESG standards through stewardship activity
A core element of these funds will aim to encourage higher ESG standards through responsible ownership / stewardship / engagement /voting activity Fund Governance
Employ external (fund) oversight or advisory committee
Find funds that have an external committee that helps steer or advise fund managers on SRI policy or strategy related issues. These people may be paid for their time but are not employees of the fund manager.
ESG integration strategy
Find funds that factor in 'environmental, social and governance' issues as part of their investment decision making process. A focus on 'ESG' typically means a fund is carrying out additional research to help reduce ESG related risks. It does not necessarily mean a focus on sustainability. Strategies vary. See fund literature. Asset Size
Over 50% large cap companies
Find funds that invests more than half of their money into what are commonly regarded as 'large companies'. This will typically mean that the market capitalisation (or value) of the companies they hold is in excess of £5 to £10 billion.
Invests in small, mid and large cap companies / assets
Find a fund that invests in a combination of small, medium and larger (potentially multinational)companies.
Invests mostly in large cap companies / assets
Find funds that have SRI strategies and focus their investment stock selection on larger companies. (e.g. over circa £5-£10bn) Impact Methodologies
Aims to generate positive impacts (or 'outcomes')
Funds that aim to help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Measures positive impacts
Funds that aim to measure the positive real world environmental and / or social benefits that are associated with their investment strategy. Funds that aim to deliver positive impacts and measure those impacts may be referred to as 'impact funds' - although impact measurement is not restricted to impact funds. Strategies vary. See fund information.
Positive environmental impact theme
Find funds that specifically set out to help deliver positive environmental impacts, benefits or 'real world' outcomes.
Positive social impact theme
Find funds that specifically state that they aim to deliver positive social (i.e. people related) impacts and/or outcomes.
Aim to deliver positive impacts through engagement
Fund aims to deliver positive environmental and or social impacts (real world benefits) through its engagement with investee assets How The Fund Works
Positive selection bias
Find funds that focus on finding and investing in companies with positive / beneficial attributes. This strategy can be applied in addition to exclusion criteria and engagement/stewardship activity.
Negative selection bias
Find funds where their main 'ethical approach' is to avoid companies by using negative screening criteria. Read fund literature for further information.
Strictly screened ethical fund
Find funds where their main approach is to apply positive or negative ethical, social and / or environmental screens. Strictly screened funds are likely to exclude more companies than other related fund options. See fund literature for further information.
ESG weighted / tilt
Find funds that invest more heavily in those that have higher ESG ratings/standards or scores and less heavily in companies with lower ESG ratings. Where this is central to a fund's strategy you should expect it to invest in most sectors. Strategies vary.
Significant harm exclusion
Aims to avoid companies that do significant harm. This originates from the EU’s sustainable finance ‘DNSH’ (do no significant harm) work, which is not necessarily used by UK investors.
Assets mapped to SDGs
Find funds that have 'mapped' (reviewed) their investment selection and management strategies to identify which of the UN Sustainable Development Goals (SDGs) the fund is helping to address.
Combines ESG strategy with other SRI criteria
Find funds that have an ESG strategy (which is typically focused on avoiding companies that pose environmental, social or governance related risks) with additional criteria such as positive and/or negative screens, themes and stewardship strategies.
Balances company 'pros and cons' / best in sector
Find funds that consider both the 'positive' and 'negative' aspects of company behaviour and make balanced, considered decisions as part of their investment approach. May apply to a range of different issues and policy areas.
Focus on ESG risk mitigation
A major focus of these funds is the careful management of environmental, social and governance (ESG) related risks - typically by avoiding or being underweight in companies seen as posing major risks in these areas (i.e. not necessarily by using themes, exclusions etc).
SRI / ESG / Ethical policies explained on website
Find funds that have published explanations of their ethical, social and/or environmental policies online (i.e. fund decision making strategies/ buy/sell &/or asset management strategies). Unscreened Assets & Cash
All assets (except cash) meet published sustainability criteria
All assets held in the fund - except cash - meet the sustainability criteria published in fund documentation. Intended Clients & Product Options
Intended for investors interested in sustainability
Finds funds designed to meet the needs of individual investors with an interest in sustainability issues.
Intended for clients who want to have a positive impact
Finds funds designed to meet the needs of individual investors with an interest in ‘Impact investment funds’ which help or support the delivery of positive social or environmental impacts (or societal/real world outcomes) by investing in companies they regard as beneficial to people and / or the planet. Strategies vary. See fund literature for further information.
Available via an ISA (OEIC only)
Find funds that are available via a tax efficient ISA product wrapper. Fund Management Company InformationAbout The Business
Responsible ownership / stewardship policy or strategy (AFM company wide)
Finds fund management companies that have a published company wide stewardship, engagement and / or responsible ownership policy or strategy that covers all investments. Stewardship typically involves encouraging higher ESG standards through voting and dialogue.
ESG / SRI engagement (AFM company wide)
Find fund management companies that actively encourage higher 'environmental, social and governance' and/or 'sustainable and responsible investment' practices across investee companies - typically where the aim is to encourage positive change that is aligned with the best interests of investors. Strategies vary. See additional information and options.
Vote all* shares at AGMs / EGMs (AFM company wide)
Find fund managers that vote all* the shares they own at Annual General Meetings and Extraordinary General Meetings. A commitment to voting shares is a key indicator of 'responsible share ownership' demonstrating their support for or disagreement with management policy. (*situations can legitimately, occasionally occur where voting proves impossible, but in principle all shares should be voted.)
SDG aligned aims / objectives (AFM company wide)
Find fund management companies that aim to align all their investments (across all funds) to help meet the aims of the UN Sustainable Development Goals.
Responsible ownership policy for non SRI funds (AFM company wide)
Find funds run by fund managers that apply Responsible ownership or 'Stewardship' policies to all or most of their investment assets. This means active involvement (e.g. voting, dialogue) with the companies they invest in across funds (not normally limited to ethical or SRI options.) Read fund literature for further information.
Integrates ESG factors into all / most (AFM) fund research
Find fund management companies that consider environmental, social and governance (ESG) issues when deciding whether or not to invest in a company for all / almost all of their funds and other assets. This is increasingly seen as part of sound risk management.
In-house diversity improvement programme (AFM company wide)
Finds organisations / fund managers that have an in-house (company wide) diversity improvement programme - meaning that they are working to ensure that within their own businesses they employ people from diverse backgrounds - often typically focused on ethnicity and/or sex.
Diversity, equality & inclusion engagement policy (AFM company wide)
Find fund management companies that encourage the companies they invest in to have strong diversity, race, gender and other equality policies across all assets held, not simply screened or themed SRI/ESG funds. (ie Asset Management company wide). Collaborations & Affiliations
PRI signatory
Find fund management companies that have signed up to the UN backed 'Principles of Responsible Investment'.
UKSIF member
Find fund management companies that are members of UKSIF - the UK Sustainable Investment and Finance association
Fund EcoMarket partner
Find fund management companies that have partnered with Fund EcoMarket - meaning that they are helping to improve access to information on sustainable and responsible investment by paying an annual fee to us which enables us to publish information for free. Partner funds are listed ahead of other funds and have their logos displayed.
TNFD forum member (AFM company wide)
A member of the Taskforce for Nature Related Financial Disclosures group which aims to aid risk management and shift money towards nature-positive outcomes.
Investment Association (IA) member
Fund management entity is a member of the Investment Association https://www.theia.org/ Resources
In-house responsible ownership / voting expertise
Find fund management companies that employ people to steer and support fund managers in voting shares at company AGM's and EGMs in ways that are consistent with encouraging higher ESG/sustainability standards.
Employ specialist ESG / SRI / sustainability researchers
Find a fund management company that directly employs specialist ESG/SRI/sustainability researchers or analysts. This allows asset managers to discuss environmental, social and governance risks and opportunities directly with companies.
Use specialist ESG / SRI / sustainability research companies
Find fund management companies that makes use of expert external research companies. This can help deliver specialist expertise and means resources are pooled with other investors.
ESG specialists on all investment desks (AFM company wide)
Finds organisations / fund managers that have one or more ESG/sustainability experts on all investment teams or 'desks' (all asset types) Accreditations
PRI A+ rated (AFM company wide)
Finds organisations / fund managers that have an A+ PRI rating - meaning they are highly rated according to the 'Principles of Responsible Investment'
UK Stewardship Code signatory (AFM company wide)
Find fund managers that are signatories to the FRC UK Stewardship Code, which sets out a framework for constructive investor / investee relations where fund managers are encouraged to behave like responsible, typically longer term 'company owners'. Engagement Approach
Regularly lead collaborative ESG initiatives (AFM company wide)
Find fund management companies that regularly initiate or run industry wide (collaborative) investor projects aimed at raising environmental, social and governance standards amongst investee companies.
Encourage responsible corporate taxation (AFM company wide)
Find fund management companies that are working with the companies they invest in to encourage more responsible corporate taxation.
Engaging on climate change issues
Fund manager has stewardship /responsible ownership strategy that is focused on addressing climate change with investee assets.
Engaging with fossil fuel companies on climate change
Asset manager has a stewardship /responsible ownership strategy that involves working with fossil fuel companies on climate change related issues. See fund manager website for details.
Engaging to reduce plastics pollution / waste
Asset manager has stewardship /responsible ownership strategy with involves encouraging investee asset to reduce plastic waste and pollution.
Engaging to encourage responsible mining practices
Asset manager has a stewardship / responsible ownership policy that means they are working to encourage more responsible mining practices - where environmental and social issues are properly dealt with by the companies they invest in.
Engaging on biodiversity / nature issues
The asset manager has a responsible ownership / stewardship strategy that focuses on biodiversity and nature issues relating to the assets they invest the aim of which will be to reduce harm and or deliver improvement. Strategies vary. https://tnfd.global
Engaging to encourage a Just Transition
Asset manager has a responsible ownership / stewardship strategy which means they are working to encourage the shift to more sustainable business practices in ways that respect and are sensitive to social issues and the impact change has on people effected by the changes that are taking place. https://www.transitionpathwayinitiative.org/ https://transitiontaskforce.net/
Engaging on human rights issues
Asset manager has responsible ownership / stewardship strategy in place which aims to address human rights issues in investee companies (and potentially their suppliers) with the aim of raising standards
Engaging on labour / employment issues
Asset manager has responsible ownership / stewardship strategy in place that aims to improve labour standards for the benefit of employees in investee companies (and potentially their suppliers)
Engaging on diversity, equality and / or inclusion issues
Asset management company has a stewardship strategy in place which involves working to raise diversity, equality and inclusion standards across investee assets
Engaging on governance issues
Fund managers have stewardship strategies in place that focus on improving governance standards across investee assets
Engaging on mental health issues
Asset manager has stewardship strategy in place which involves discussing mental health issues with investee companies - with the aim of raising standards
Engaging on responsible supply chain issues
Has a stewardship / responsible ownership strategy that encourages responsible supply chain - ie the managers will discuss environmental, social and governance issues with investee companies with the aim of raising standards Company Wide Exclusions
Controversial weapons avoidance policy (AFM company wide)
Find fund management companies (not funds) that avoid investment in 'controversial weapons' across all of their funds and other investment vehicles. Climate & Net Zero Transition
Net Zero commitment (AFM company wide)
Fund management organisations that have pledged to reduce their greenhouse gas emissions to ‘net zero’. Strategies vary - this area is changing rapidly.
Voting policy includes net zero targets (AFM company wide)
Fund manager AGM / EGM voting strategy has processes in place that mean they will normally be expected to vote in a way that will encourage the transition to net zero greenhouse gas emissions.
Net Zero - have set a Net Zero target date (AFM company wide)
This asset management company has set a date by which they plan to achieve net zero greenhouse gas / CO2e emissions.
Encourage carbon / greenhouse gas reduction (AFM company wide)
Find fund management companies that are working with the companies they invest in to encourage reductions in carbon dioxide and other greenhouse gas emissions.
Carbon transition plan published (AFM company wide)
Finds organisations / fund managers that have a company wide carbon transition plan - meaning that they have plotted a path to how they will move away from activities that produce or use carbon based energy sources (that emit greenhouse gases) towards clean, alternative, renewable energy sources.
‘Forward Looking Climate Metrics’ published / ITR (AFM company wide)
Finds organisations / fund managers that have published ‘forward looking climate metrics’ e.g. 'implied temperature rise' data that are a total of the asset management company's share (% owned) of all the investee company emissions of the assets they manage, as well as their own direct and other indirect emissions.
Carbon offsetting - offset carbon as part of our net zero plan (AFM company wide)
This asset management company plans to achieve net zero greenhouse gas (CO2e) emissions with the help of a scheme that will lock away an amount of carbon that is equivalent to the company’s own emissions – so that the end result is ‘net zero’. Calculations and scope vary.
In-house carbon / GHG reduction policy (AFM company wide)
Find fund management companies that are working to reduce their own (fund management company) carbon/greenhouse gas emissions.
Working towards a ‘Net Zero’ commitment (AFM company wide)
Finds organisations / fund management companies that are in the process of working out how to make a ‘net zero commitment’ - meaning that when that is finalised they will have started the process of reducing their total greenhouse gas emissions to'zero'.
Committed to SBTi / Science Based Targets Initiative
See https://sciencebasedtargets.org/ Transparency
Publish responsible ownership / stewardship report (AFM company wide)
Find fund management companies that publish a report detailing their responsible investment ownership - also known as 'Stewardship' - activity.
Full SRI / responsible ownership policy information on company website
Find companies that publish information about their sustainable and responsible investment strategies on their company website.
Full SRI / responsible ownership policy information available on request
Find fund management companies that will supply information about their sustainable and responsible investment activity on request.
Publish full voting record (AFM company wide)
Fund management companies that publish a full record of how they vote their shares at AGMs (annual general meetings) and EGMs (extraordinary general meetings). Voting strategies have an important role to play encouraging higher environmental, social and governance standards.
Sustainability transition plan publicly available (AFM company wide)
This asset management company has published a plan that explains how they are to become a sustainable business - without significant negative environmental or social impacts.
Paris Alignment plan publicly available (AFM company wide)
This asset management company has published a plan that explains how they will align to the climate change commitments made at the Paris Climate Talks, COP21.
Net Zero transition plan publicly available (AFM company wide)
This asset management company has published a plan that explains how they are going to achieve net zero greenhouse gas / CO2e emissions.
Dialshifter statement
Find fund management companies that have supplied Dialshifter information. See Dialshifter tab within record for more information. Sustainable, Responsible &/or ESG Policy:Investment Philosophy Our responsible investment philosophy is based on three pillars:
This philosophy underlies the process that is applied to define the investable universe through screening, the subsequent investment analysis, stock selection and active ownership. Our company selection approach is broadly summarised below:
High quality business
Strong management
Attractive price
Process:Investment Process There is a five-step investment process led by the Global Equities team:
Step 1: Idea generation (Global Equities team) The process starts with idea generation on the investment team. We find a rich source of ideas comes from considering long term social and environmental themes, looking across industries and along value chains. We believe companies that are contributing to solutions to key sustainability challenges, and building successful business models around this will see a long-term tailwind to their growth opportunities. The identification of themes helps to focus our analytical efforts rather than imposing a strict thematic structure on the portfolio, our themes are outlined below:
We additionally try to look for companies who are leaders, or have the potential to show meaningful improvement, in how they manage key ESG issues, whether or not their business fits a particular theme. Additional input into idea generation comes from the experience available through other internal equity teams. Research and company meetings are shared across all equity desks. External input includes sell-side research, conferences, industry experts and macro considerations. Any companies not already in the acceptable universe are then put forward to the Responsible Investment team for screening against the strategy’s acceptability criteria.
Step 2: Ethical and sustainability screening (Responsible Investment team) All stocks considered for investment first undergo screening by members of the Responsible Investment team, to determine if they meet the criteria for inclusion in the portfolio’s investable universe. The Responsible Investment team has created a thorough and robust process to analyse companies to determine whether they meet the strategy criteria:
The independent Responsible Investment Advisory Council is also involved in reviewing the approvability ratings of companies as well as in developing the screening criteria for the strategy and targeting engagement activity. Input is also frequently sought from a range of stakeholders.
The Responsible Investment team has a quarterly monitoring system to identify:
Step 3: Fundamental analysis (Global Equities and Responsible Investment teams) Stocks that enter the investment universe undergo a process of fundamental investment analysis by the Global Equities team. Sector research responsibilities are allocated across the team. This ensures that there is a ‘centre of excellence’ for each sector and theme within the team, with a thorough understanding of the drivers affecting each sector and theme as well as the relative position of the constituent companies within them. However, this is not an exclusive process and individuals can champion ideas in any sectors.
We believe the key to superior investment performance lies in investing over the long term in high-quality companies that are attractively valued. For any potential investment we will:
The RI team and the Global Equities team work together to fully incorporate ESG risks and opportunities into the fundamental valuation of each company. To flag key Environmental, Social, and Governance risks and opportunities, the Global Equities team works with the RI team and an important data source that we use is Morgan Stanley Capital International (MSCI) ESG Research ratings and analysis. The MSCI ESG approach identifies key issues by industry for each company and rates companies on social, environmental and governance performance both in absolute terms and relative to their specific industry. We also review a list of what we consider to be 20 key governance indicators and also any significant controversies a company may have been involved in.
However, whilst ESG data quality has improved over time, it is still not perfect. We therefore also make our own assessments through the RI team’s own analysis of ESG considerations and engagement efforts, in order to establish our own views of all material ESG risks and opportunities facing a company. Our RI team therefore leverages their experience across different ESG issues and ‘scrubs’ the MSCI data where we see deficiencies, in order to arrive at cleaner ESG data points that leverage the breadth of the MSCI coverage, but yet the depth of ESG knowledge within our RI team.
With increasing rhetoric from both the fund management industry and within the investee corporate landscape regarding sustainability, we look to stay true to what our investors expect of us; that we are clearly, deliberately and diligently investing in companies that are truly delivering upon sustainability challenges. With that in mind, the A.I.M. framework was established:
When it comes to valuation, we place particular emphasis on cash flows as we believe these provide the most rigorous base for analysis of the underlying financial strength, and therefore quality, of any company. Discounted cash flow models (DCFs) are a key component of our valuation work to determine a ‘conservative assessment of the intrinsic value’ of a share price (CAIV). DCFs are also an important tool to help us determine the margin of safety in a stock by looking at what is implied in the current share price.
Here, ESG factors are considered directly in the analysis of the business model and the assessment of management quality. We factor them into the valuation by flexing assumptions and discount rates as appropriate. For example, we may flex revenue or profitability assumptions across different outcomes reflecting ESG risks and opportunities.
The inputs into our proprietary “alternate weighted average cost of capital” (ALT-WACC) used as a discount rate within our DCF analysis also incorporate our views on ESG risks/opportunities as well as our sustainability assessment as depicted above.
At the end of this process, a formal investment research note is produced by the analyst and discussed with the wider team. Stocks researched by the team are rated 1 (most positive), 2 (neutral), or 3 (most negative). The ratings are active with no neutral rating, determined by the combination of margin of safety and upside to their ‘intrinsic value’ and the level of confidence we have in the quality of the business. The forum for discussing research is our twice weekly research meetings. These are rigorous and thorough meetings during which an analyst will present their research on a stock which must stand up to detailed scrutiny by the team.
Step 4: Portfolio construction (Global Equities team) The output of the fundamental analysis forms the basis of portfolio construction. We consider that higher quality companies will justify a larger active position on the portfolio. Timing, regional, sector and aggregate risk considerations are taken into account. Analytical responsibilities are divided between the team by sector or theme specialisation. Daily desk discussion of ideas exchange and news-flow monitoring is supplemented by a more formal weekly Stock Review Meeting and Portfolio Construction Meeting; ensuring that monitoring and review at team level takes place.
The Strategy observes the following self-imposed limits:
The biggest constraint that applies to our portfolio construction is the ethical and sustainable screening process that defines the investable universe and will result in certain structural biases, such as an underweight position relative to the benchmark in extractive industries. The Strategy has a predictable style bias to mid-cap and growth companies that results partly from the screening process and partly from the investment style of the portfolio managers. The approved list is hard-coded into the dealing system to avoid inadvertently investing in unacceptable securities. The risk profile of the overall portfolio is reviewed on a regular basis in which we ensure:
Individual weightings are initially determined by the strength of conviction of each idea on a risk adjusted return basis, taking into account the quality of the investment thesis.
Sell discipline Our sell discipline is not rules based, but a sale would likely be triggered by a fundamental breach of the investment case, or a stock becoming fully valued with no further upside foreseen over the medium term.
Step 5: Engagement and proxy voting (Global Equities and Responsible Investment teams) We operate an active ownership policy, and seek to influence positive change and support best practice through engagement and voting. After meeting the ethical and sustainability screening standards, we will engage companies and encourage them to meet or set emerging best practice in the management of key ESG issues. We engage on company specific issues, sector and broader thematic issues and at public policy level. Our aim is to reduce risk to enhance long term performance, and to encourage a positive contribution to broader social and environmental issues. We use constructive confidential dialogue, typically working one to one with companies, but taking a collaborative approach where this has more impact. We will vote at all shareholder meetings of companies under the strategy, based on its detailed proxy voting guidelines.
Resources, Affiliations & Corporate Strategies:Responsible Investment Team We have a dedicated in-house Responsible Investment (RI) team, one of the most experienced and established teams of its kind. The award-winning 40+ member team supports our clients, our investment teams and our overall business through expertise across ESG thematic research, ESG integration, ESG policy, client reporting and thought leadership content. Beyond these core activities, the team also supports a plethora of activity from representation on responsible investment industry groups, public policy contribution, ESG thought leadership, ESG product development, portfolio level ESG analytics, screening for specialist ESG portfolios and reporting on active ownership activities. Active ownership is a key aspect of our RI work, and within the team there are more than 20 professionals focused on engagement and voting activity. The RI team works hand in hand with our research and investment professionals to enrich their understanding of key sustainability trends as they relate to specific sectors and issuers, collaborating to highlight risks and opportunities within industries and sectors, informing investment decisions across asset classes. The RI team was awarded ‘Best ESG Research Team’ at the 2018, 2019 and 2020 Investment Week Sustainable & ESG Investment Awards, ‘Best ESG Reporting – Asset Manager: Large’ at the 2019 Environmental Finance Awards, and ‘Best ESG Research: Fixed Income’ at the 2020 Environmental Finance Awards. We were also awarded ‘Best ESG Fund House’ at the 2022 ESG Clarity Awards.
Responsible Investment Advisory Council The Council is a six-member committee of experts, who are leaders in their fields and bring international experience across responsible investment, ethical, environmental, and social issues. Their primary role is to provide advice on the ethical criteria for our specialist Responsible strategy range. The Responsible Investment team is also able to draw on their expertise in informing our broader engagement and responsible investment approach. The Council’s president is the Most Reverend Justin Welby, Archbishop of Canterbury. The Chair, who heads the quarterly meetings, is Howard Pearce, formerly Head of Environmental Finance and Pension Fund Management at the UK’s Environment Agency Pension Fund (EAPF). More detail on the Council can be found here.
Affiliations & Memberships We make efforts to promote responsible investment in multiple ways, including participation in speaking engagements, industry working groups, responsible investment conferences and collaborative initiatives. A list of key responsible investment memberships and affiliations for Columbia Threadneedle Investments is shown below.
Climate Action 100+ Climate Action 100+ is an investor initiative launched in 2017 to ensure the world’s largest corporate greenhouse gas emitters take necessary action on climate change. We are a member of the investor coalition, leading 8 and supporting 38 engagements. Date of joining: CTML: 2017, TAML: 2021
Transition Pathway Initiative (TPI) A PRI sponsored initiative; this is an asset-owner led initiative which assesses companies' preparedness for the transition to a low carbon economy. It is supported by London School of Economics, a research driven initiative on high emitting sectors carbon transition and strategic/management commitment to address climate transition. Date of joining: CTML: 2020, TAML: 2021
Net Zero Asset Managers Initiative Founder signatory of this international group of asset managers committed to supporting the goal of net zero greenhouse gas emissions by 2050 or sooner, in line with global efforts to limit warming to 1.5 degrees Celsius; and to supporting investing aligned with net zero emissions by 2050 or sooner. Date of joining: CTML: 2020, TAML: 2021
Carbon Disclosure Project (CDP) Non-profit organisation that runs the global disclosure system for investors, companies, cities, states and regions to manage their environmental impacts. We are member of the investor coalition, leading and supporting several engagements. Date of joining: CTML: 2000, TAML: 2005
Carbon Trust We partner this organisation that supports companies to accelerate towards Net Zero. From target setting, Net Zero pathways, assurance and footprinting, to policy advice, strategy setting and programme delivery. Date of joining: 2010
Task Force on Climate-related Financial Disclosures (TCFD) We have committed to producing reporting as part of TCFD, an organisation that was established in December 2015 with the goal of developing a set of voluntary climate-related financial risk disclosures. Date of joining: CTML: 2020, TAML: 2022
Sustainability Accounting Standards Board (SASB) ESG standard setter (Member Standards Advisory Group & sub-groups). SASB guides the disclosure of financially material sustainability information by companies to their investors. Date of joining: 2018
Science Based Targets initiative (SBTi) The SBTi is a partnership between CDP, the United Nations Global Compact, World Resources Institute (WRI) and the Worldwide Fund for Nature (WWF). Guides companies to set science-based targets to mobilize the private sector to take urgent climate action. Date of joining: 2020
Impact Investing Institute Focuses on the development of outcome related investment, to encourage more investment made with the intention to generate positive, measurable social and environmental impact alongside a financial return. TAML is a Founding supporter and member of the Advisory Council and working group for the Green+ Gilts Date of joining: 2020
Institutional Investor Group on Climate Change (IIGCC) IIGCC works with business, policy makers and investors to help define the investment practices, policies and corporate behaviours required to address climate change. A member of the RI team serves on the Board. We lead and support several engagements. Date of joining: 2001
IIGCC's Global Investor Statement A joint statement coordinated by the seven Founding Partners of The Investor Agenda to all world governments urging a global race-to-the-top on climate policy and warns that laggards will miss out on trillions of dollars in investment if they aim too low and move too slow. Date of joining: 2009
IIGCC’s Investor Position Statement on Transition Planning Signatory of this investor statement by 56 leading investors calling for the implementation of new corporate governance measures to ensure shareholders can hold companies to account in achieving net zero emissions commitments. Date of joining: 2021
Ceres Land Use and Climate WG (Biodiversity) Ceres works with the most influential capital market leaders to advance innovative solutions to the climate crisis and achieve a zero emissions future where people and the planet can prosper. Date of joining: 2020
Cerrado Manifesto SoS Public statement committing to halt deforestation in the Cerrado, adopt sustainable land management practices and mitigate financial risks associated with deforestation and climate change. It is endorsed by global FMCG companies and institutional investors. Date of joining: 2021
ChemScore Benchmark created by NGO International Chemical Secretariat (ChemSec). It ranks the world’s top 50 chemical producers on their work to reduce their chemical footprint. Date of joining: 2021
Nature Action 100 Founding member of investor-led collaborative engagement programme to engage with companies and policymakers on nature. Date of joining: 2022
Taskforce for Nature-related Financial Disclosures As a forum member, we support the taskforce aiming to develop and deliver a risk management and disclosure framework for organisations to report and act on evolving nature-related risks. Date of joining: 2020
Sustainability Policy Transparency Toolkit (SPOTT) SPOTT scores palm oil, tropical forestry, and natural rubber companies annually against over 100 sector specific ESG indicators to benchmark their progress over time. As an investor supporter we express need for enhanced transparency. Date of joining: 2019
Investor Policy Dialogue on Deforestation Collaborative investor initiative set up to engage with public agencies and industry associations on the issue of deforestation. The goal is to coordinate a public policy dialogue on halting deforestation. We are a member of the Advisory Council, leading/supporting engagements going forward. Date of joining: 2021
ShareAction Chemicals Working Group Investor group focused on engagement with the chemicals sector on decarbonisation. Date of joining: 2021
Global Network Initiative (GNI) Member of this initiative seeking to safeguard freedom of expression and personal privacy against government restrictions. The protections are facilitated by a coalition of companies, investors, civil society organisations, academics, and other stakeholders. Date of joining: CTML: 2008, TAML: 2002
Interfaith Centre on Corporate Responsibility (ICCR) Coalition of over 300 global faith- and values-based institutional investors. We are members of the Food Justice and Racial Equity workstream. Date of joining: 2020
ICCR's Investor Alliance on Human Rights (IAHR) Part of the ICCR, IAHR provides a collective action platform to facilitate investor advocacy on a full spectrum of human rights and labour rights issues. Date of joining: 2020
ICCR's Investors for Opioid and Pharmaceutical Accountability (IOPA) Part of the ICCR, IOPA addresses the fallout of the opioid crisis and other business risks by seeking accountability and mitigating further risk at pharmaceutical companies through comprehensive shareholder reforms. Date of joining: 2021
ShareAction Good Work Coalition Investor engagement initiative aimed at driving up standards in the workplace. Engagement focus on labour standards, living wage standards, accreditation, transparency of the FTSE350, extension to DEI with a focus on ethnic diversity. Date of joining: 2021
ShareAction Healthier Markets Investor initiative aimed at improving children's health by increasing access to affordable, healthy food. Date of joining: 2021
Access to Medicine Foundation Member of the investor coalition, leading and supporting several engagements. Independent, non-profit organisation working to stimulate and guide the pharmaceutical industry. Produces the Access to Medicine Index, Antimicrobial Resistance Benchmark, Access to Vaccines Index. Date of joining: 2021
Investor Action on Antimicrobial Resistance (AMR) A coalition between the Access to Medicine Foundation, the FAIRR Initiative, the Principles for Responsible Investment and the UK Government Department of Health and Social Care to galvanise investor efforts to address global AMR. We are leading and supporting engagements. Date of joining: 2021
Investor Initiative for Responsible Care Collaborative engagement group coordinated by UNI Global Union focused on working standards and quality of care in the listed nursing care sector. Date of joining: 2022
Workforce Disclosure Initiative (WDI) Disclosure body. We are Signatory, member of the Advisory Group; leading/supporting several engagements. Investor initiative aimed at improving corporate transparency and accountability on workforce issues. Provide companies and investors with comprehensive and comparable data. Date of joining: CTML: 2021, TAML: 2020
Global Investor Collaboration on Farm Animal Welfare & Global Investor Statement on Farm Animal Welfare Engagement collaboration with BBFAW (Business Benchmark on Farm Animal Welfare), member of the investor coalition, supporting and leading several engagements. Date of joining: 2021
Platform Living wage Financials Coalition of financial institutions that encourages and monitors investee companies to address the non-payment of living wage in global supply chains. We are chair of the Platform's Garment Working Group; member of the Food, Retail and Agri working group. Date of joining: 2020
Find it, fix it, prevent it Engagement collaboration. Member, leading on engagements. Investor led initiative targeting UK-listed companies to demonstrate commitment to eradicating modern slavery from their supply chains. Date of joining: CTML: 2020, TAML: 2021
KnowTheChain Engagement collaboration. Member of the investor coalition, supporting several engagements. KnowTheChain is a resource for companies and investors to understand and address forced labour risks within their global supply chains. Date of joining: 2021
Access to Nutrition Index Engagement collaboration. Member of the investor coalition, supporting several engagements. Independent, non-profit organisation producing the Access to Nutrition Index. Benchmark evaluates the world's largest food and beverage manufacturers' policies and performance related to the world's most pressing nutrition challenges: obesity and undernutrition. Date of joining: 2021
Human Capital Management Coalition (US) Engagement collaboration. Member of the coalition of investors to elevate human capital management. Engages companies and other market participants with the aim of understanding and improving how human capital management contributes to the creation of long-term shareholder value. Date of joining: 2021
Investors for Racial Justice Member of this information sharing network and engagement collaboration. Date of joining: 2020
Votes Against Slavery 2022 Member of this investor collaboration engaging with FTSE 350 companies on their compliance with the Modern Slavery Act 2015. We joined the collaboration for the 2021 campaign. Date of joining: 2021
International Corporate Governance Network (ICGN) Member of investor led organisation advancing the highest standards of corporate governance and investor stewardship worldwide in pursuit of long-term value creation. Date of joining: CTML: 2007, TAML: 2017
Investment Association (IA) Member of UK industry body; facilitates the monitoring and responding to ESG policy and regulatory changes impacting our activities. Date of joining: CTML: 2000, TAML: 1998
Corporate Governance Forum European focus - UK based asset management governance teams. Informal discussion on companies and industry issues. Date of joining: 2012
Global Institutional Governance Network (GIGN) US/Global focus - Global asset management governance teams. Discussions on companies and industry issues. Date of joining: 2012
Council of Institutional Investors (CII) Member of this non-profit organisation promoting effective corporate governance policies. Date of joining: 1996
Investor Forum Member and proactive collaborator with the Forum, which helps investors to work collectively to escalate material issues with the Boards of UK-listed companies. Date of joining: 2005
Asia Corporate Governance Association Member of independent, non-profit membership organisation dedicated to working with investors, companies and regulators in the implementation of effective corporate governance practices throughout Asia. Date of joining: CTML: 2004, TAML: 2010
Asia Research & Engagement (ARE) Engagement collaboration. Organisation that structures, implements and assembles investor collaborative engagement programmes across Asia. Performs in-depth industry and company research that provides strategic insight into key ESG issues to underpin engagement work. Date of joining: 2021
Pre-Emption Group (PEG) Members of the UK Capital markets group that sets guidelines on the application/dis-application of pre-emption rights in UK capital issuance. Date of joining: 2016
30% Club UK Investor Group Campaign for greater representation of women on company boards. Member of the investor coalition, leading and supporting several engagements. Date of joining: 2021
30% Club France Investor Group Member of this investor-led group aiming to boost the number of women in board seats and executive leadership of companies in the SBF 120 index. Date of joining: 2021
30% Coalition (US) Campaign for greater diversity on company boards. Member of the investor coalition, leading and supporting several engagements. Date of joining: 2021
Women in Finance Charter First asset manager signatory to the UK charter committing to support the progression of women into senior roles in the financial services sector, set targets and publicly report on progress against these targets to support transparency and accountability. Date of joining: 2016
Eumedion Member of this non-profit organisation aiming to promote good corporate governance and sustainability policies at Dutch listed companies and to promote engaged and responsible shareholding by its members. Date of joining: 2009
Principles for Responsible Investment (PRI) Global responsible investment association, membership is a pre-requisite for many clients. TAML & BMO GAM are Founding Signatories to the UN supported PRI. CTML, formerly known as BMO GAM EMEA, was part of BMO GAM at the time of becoming a signatory. BMO GAM EMEA business was acquired by Ameriprise Financial, Inc. in 2021. CMIA became a signatory in 2014. Date of joining: CTML & TAML: 2006, CMIA: 2014
UK Stewardship Code Set of principles for asset owners and managers. We are signatories of the 2020 code. Date of joining: 2012
Investor Stewardship Group (ISG) Members of the network of investors and asset managers formed to promote good practice in stewardship and corporate governance, specific to the US. Date of joining: 2018
Investment Company Institute (ICI) US Industry body; facilitates the monitoring and responding to ESG policy and regulatory changes impacting our activities. Date of joining: 2019
UK Sustainable Investment and Finance Association (UKSIF) Network focused on the UK sustainable investment market, pre-requisite for FNG certification. A member of the RI team chairs the Policy Committee. Date of joining: CTML: 2000, TAML: 2020
Taiwan Stewardship Code Signatory to the Taiwan Stewardship Code, which is based on a ‘comply or explain’ approach. Date of joining: 2022
Japan’s Stewardship Code Signatory to Japan’s Stewardship Code, which is maintained by Japanese Financial Services Agency, based on a ‘comply-or-explain’ approach where signatories comply with the principles of the code or explain why they do not comply. Date of joining: 2022
Global Real Estate Benchmark (GRESB) Member of this organization whose data facilitates our ability to track trends in corporate environmental and social risk management performance as it relates to property. Date of joining: 2013
London Stock Exchange Members of the LSE’s Primary Markets Group, advising on primary market issues. Date of joining: 2012
The Big Exchange TAML is a founding partner and members of the Impact Committee. Date of joining: 2019
Global Impact Investing Network (GIIN) Member of this leading non-profit dedicated to increasing the scale and effectiveness of impact investing Date of joining: 2020
FAIRR Collaborative investor network that focuses on ESG risks and opportunities around animal agriculture. Date of joining: 2021
Investor Tailings Safety Initiative & Investor 2030 Mining Agenda We are the founding supporter of this initiative and will co-lead on some of the corporate engagements. Date of joining: 2021
Centre for Audit Committee and Investor Dialogue Network initiative that enables investors, audit committee members and auditors to discuss issues of common interest. Date of joining: 2013
International Capital Markets Association (ICMA) The development of green, social and sustainability bond principles relevant to our fixed income investments in an RI context. Members of the Social Bond Working Group and members of working groups on the SDGs and on impact reporting. Date of joining: 2016
Source: Columbia Threadneedle Investments, as at March 2023. Includes memberships held by CMIA, TAML, CTML and other group affiliates. CMIA = Columbia Management Investment Advisors, LLC; TAML = Threadneedle Asset Management Limited; CTML = Columbia Threadneedle Management Limited.
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CONTRACTUAL AGREEMENT This document is issued by Columbia Threadneedle Management Limited. Should you decide or wish to receive the services detailed within this document, your contractual agreement will be with Columbia Threadneedle Management Limited. This entity is a wholly owned subsidiary of Columbia Threadneedle Investments UK International Limited, whose direct parent is Ameriprise Inc., a company incorporated in the United States. Past performance should not be seen as an indication of future performance. The value of investments and income derived from them can go down as well as up as a result of market or currency movements and investors may not get back the original amount invested. The information, opinions, estimates or forecasts contained in this document were obtained from sources reasonably believed to be reliable and are subject to change at any time. The “Firm” referred to herein is part of the group of legal entities acquired by Ameriprise Financial Inc. on 8th November 2021. On 4th July 2022, we reached a significant milestone in the integration of our businesses being rebranded as Columbia Threadneedle Investments. We have made significant progress with the integration of our businesses, and while we now present ourselves externally as a single brand, there may be instances where the Firm’s legacy functions, systems, teams or policies remain in place until further integration milestones are reached. Where applicable, this document may make reference to such functions, systems, teams or policies, with any such references being subject to change as the integration work continues. |