From our experience of working with numerous charities, we have seen the task of drafting a responsible investment policy being carried out in a number of different ways. Some charities have a separate policy, covering their objectives and thresholds in relation to responsible investment, whilst others include their responsible investment objectives in their broader investment policy. Some charities leave it to the sole discretion of the Board and its Trustees, whilst others have consulted stakeholders across their organisation, to ensure the finalised document reflects the views of the entire charity.
Whatever your approach, we can suggest the following five steps as a way to get you in the right mind-set to draft your charity’s responsible investment policy.
Ethical, Responsible, Sustainable, ESG (Environmental, Social and Governance), the terminology can be off putting. It really doesn’t matter too much what you call it – the important thing is deciding what kind of policy is relevant and appropriate for your charity.
Start by asking yourself a few straightforward questions: ‘why do we need this policy?’, ‘how is it central to our mission as a charity?’, ‘how do we see ourselves as an organisation?’, ‘what themes are important to us?’ and, importantly, ‘how will our reputation be affected if we don’t do this?’ (Trustees who give discretionary powers to an investment manager are legally required to have a written investment policy).
This will help you to take a step back and think about the bigger picture of what you want to achieve, rather than diving headfirst into the finer details. It will also ensure your policy is appropriately aligned with your mission and you are not applying an unnecessarily stringent approach.
Think about your charity’s key objectives and what your specific requirements are. It is important to acknowledge the type of responsible investor you are as an organisation, rather than letting personal preferences dictate. For example, it shouldn’t be up to one Trustee or Board member to decide whether the charity avoids fossil fuels. It should be a choice that the Board makes to reflect the mission of the charity as a whole.
Consider your policy in respect of your overall investment objectives. Do you have positive intentions that can be reflected in your portfolio? Or are you more interested in exclusionary screening, removing investments that are conflicted with your mission as a charity?
Ensure your responsible investment policy meets good practice as recommended by the Charity Commission. Consult CC14: charities and investment matters, to ensure your charity’s specific objectives and purposes are appropriately reflected.
Ethical investment means investing in a way that reflects a charity’s values and ethos and does not run counter to its aims.
– CC14: charities and investment matters.
Creating ‘red areas’ and ‘grey areas’ can often help. ‘Red areas’ are no-go zones that you as a charity will simply not tolerate. These may include tobacco, alcohol, or animal testing, for example. ‘Grey areas’ include investments which the charity would rather have limited exposure to, but needn’t wholly divest from.
Think about the end goal. Finalising and publishing your responsible investment policy will have implications on the way you, or your investment manager, invests. What you set in stone initially will have ramifications later down the line and so being pragmatic, realistic and true to your charity’s purpose is crucial.
Trustees might find it helpful to prepare it [the policy] in consultation with the proposed investment manager to ensure its terms are workable and achievable.
– CC14: charities and investment matters.
Ensuring your chosen manager adheres to your finalised responsible investment policy is key to fulfilling your mission through your investments. Remember that this is a very specialist area, one that everybody will now tell you they are a specialist in. A first question might be to ask your manager to define ethical / responsible / sustainable investing and what it means to them.
Other questions to ask include:
How will you communicate your policy internally and externally? This can be a good opportunity to energise your employees and stakeholders by demonstrating the impact you are having as a charity, through your investments.
Here are a few ‘top-tips’ from our Head of Responsible Investment Policy & Research Neville White:
When considering expectations and exclusions, it is important to remember the difference between concepts e.g., ‘avoid child labour’, where your investment manager can avoid risks and engage with companies and activities e.g., fossil fuel exploration, which your investment manager can exclude.
The Trustees of ABC Foundation have considered and adopted a policy in relation to socially responsible investment and sustainability for the Charity in the context of its aims and objectives. The Foundation expects the Manager to take ESG considerations into account in order to align the investments with the values and principles that underpin the Foundation’s broader purpose.
Our intention is for the investments of the Foundation to have a positive impact on society and the planet by avoiding harm through ESG integration and exclusions, benefiting stakeholders through responsible business activities, and contributing to solutions through influence and investing for positive outcomes.
The Foundation therefore makes the following commitments and expects the Manager to:
‘Concepts’
As part of the Foundation’s approach, the Trustees have decided to exclude the following areas:
‘Activities’
For your charity’s investment policy to be implementable, and adhered to, it is important to be clear about your expectations and intentions.
In this sample policy, for example, it is not entirely clear whether fossil fuels points to exploration or also includes coal-driven generation.
For tobacco and alcohol does the charity consider retail and production or just the former?
If you yourselves are unclear, do consult your investment manager or independent adviser who can support your charity to be more explicit.
The Foundation expects the Manager to report on how ESG considerations have been applied in the selection of investments as well as ongoing engagement and voting activity.
NB: Please note that the above sample policy is for illustrative purposes only.
Past performance should not be seen as a guide to future performance. The value of an investment and the income from it can fall as well as rise as a result of market and currency fluctuations, you may not get back the amount originally invested. EdenTree Investment Management Limited (EdenTree) Reg. No. 2519319. Registered in England at Benefact House, 2000, Pioneer Avenue, Gloucester Business Park, Brockworth, Gloucester, GL3 4AW, United Kingdom. EdenTree is authorised and regulated by the Financial Conduct Authority and is a member of the Investment Association. Firm Reference Number 527473
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