Our position on harmful and controversial products, services or practices

Issue

Our approach

We will not invest in companies that have a material exposure to the exploration, production or generation of fossil fuel energy.

We define fossil fuels as coal, unconventional oil & gas (arctic drilling, oil sands, shale energy), and conventional oil & gas. The Funds consider exploration, extraction, power generation, transportation, distribution, refining or providing dedicated equipment or services as part of the value chain.

We do not invest in companies materially involved in nuclear energy.

We will not invest in companies that we reasonably believe wilfully or persistently neglect their environmental obligations, including their obligations under applicable laws, and the principles outlined in the UN Global Compact and other standards and independent assessments that we adopt from time to time. No materiality threshold applies to this item.

We do not invest in companies materially involved in the production of alcohol products.

We do not invest in companies involved in the production of Tobacco Products (this includes any company that owns a 50% or more interest in companies that any revenue directly from the manufacture of Tobacco Products (defined below)). This activity has 0% of revenue threshold. However, for wholesaling, distribution and provision of dedicated equipment and services to companies that produce Tobacco Products, we apply a 5% revenue threshold.

We define Tobacco Products to mean traditional cigarettes and other tobacco products, such as cigars, chewing tobacco, vaping and e-cigarette products.

We do not invest in companies materially involved in gambling operations or the provision of gambling opportunities.

We do not invest in companies involved in the production of pornography or materially involved in the distribution of pornography. Production of pornography has a 0% revenue threshold and distribution of pornography has a 5% revenue threshold.

We do not invest in companies that are materially involved in:

• the export of live animals;
• cruel production practices (e.g. revenue derived from factory farming); or
• the trade of controversial animal products, such as ivory.

We do not invest in companies that are involved in animal testing during the production of some consumer, medical, chemical and home and personal care products other than in the following circumstances:  

• animal testing is done in accordance with ethical principles, policies, protocols and standards for the responsible treatment and welfare of animals; 
• animal testing is required by regulatory agencies to limit risks to human lives and health; 
• products require ingredients for which no suitable alternative methods of testing are available.

We will not invest in companies that discriminate against or seek to impinge on abortion rights for women. No materiality threshold applies  to this item.

We will not invest in companies that are involved in research for the reproductive cloning of human beings or animals. No materiality threshold applies to this item.

We do not invest in companies with poor records in relation to globally accepted human rights norms and standards, including modern slavery, child labour, capital punishment, indigenous rights and community impacts. No materiality threshold applies to this item.

We do not invest in companies where we have formed a view that they undertake unethical or discriminatory employment practices. In forming a view on this, indicators such as employee compensation, gender equity and diversity, employee turnover rates and safety records can be particularly insightful when evaluating people-related risks. No materiality threshold applies to this item.

We do not invest in companies that are materially involved in the manufacture of armaments. This includes both Controversial Weapons and other armaments such as handguns. A 0% revenue threshold applies to Controversial Weapons (this includes any company that owns a 50% or more interest in companies that derive any revenue directly from the manufacture of such weapons).

Controversial Weapons mean anti-personnel mines, cluster weapons, biological and chemical weapons, depleted uranium, nuclear weapons and white phosphorus munitions.

We do not invest in companies where we have formed the view that they may be compromised as a result of their dealing with such governments we consider to be oppressive regimes. No materiality threshold applies to this item.

We do not invest in companies where we have formed the view that there appears to be cultural or systemic weaknesses that we believe can lead to bribery and corruption being perpetrated. No materiality threshold applies to this item.

We do not invest in companies where we have formed the view that tax practices are persistently and systematically designed to undermine the integrity of tax systems.  No materiality threshold applies to this item.

We will not invest in companies where we have formed the view that 

the company abuses its relationships with its customers, suppliers and competitors, as we believe that such companies are equally likely to treat minority shareholders poorly, as well as carry with them significant risks of regulatory and consumer responses or compromising the sustainability of their supply chains. No materiality threshold applies to this item.