Sustainability-Related Disclosures
Date of Publication: 23 December 2022
To comply with the Sustainable Finance Disclosure Regulation (Regulation EU/2019/2088) as amended (“SFDR”), Fisher Investments Ireland Limited (“FII”) has provided the below sustainability-related disclosures that describe various policies related to sustainability and environmental, social and governance (“ESG”) factors, as well as information on ESG orientated strategies FII has available to high net worth private clients (“private clients”). Because FII delegates its portfolio management services to its parent company, Fisher Asset Management, LLC, trading as Fisher Investments (“FI”), subject to FII’s oversight, such policies and strategies are implemented by FI, but apply to FII’s services provided to FII’s private clients.
If you are an institutional client of FII, please go to the following website to find FII’s SFDR and Taxonomy Regulation disclosures relevant to you: https://www.fisherinvestments.com/en-ie/institutional-investing/responsible-investing.
Information about FI’s Policies on the Integration of Sustainability Risks in its Investment Decision-making Process
FI generally evaluates and integrates Sustainability Risks and ESG factors at multiple stages throughout the investment process. “Sustainability Risk” is defined by SFDR as an environmental, social or governance event or condition that, if it occurs, could cause a negative material impact on the value of the investment.
Top-Down Investment Process
Sustainability Risks and ESG factors are among the many drivers considered by FI’s Capital Markets Analysts and FI’s Investment Policy Committee (“IPC”) when developing country, sector and thematic preferences. Environmental regulation, social policy, economic and market reforms, labour, and human rights are among the ESG factors assessed when determining country and sector/industry allocations and shaping an initial prospect list of portfolio positions.
FI’s IPC, with the assistance of FI’s Securities and Capital Markets Analysts, determines the materiality of the ESG considerations based on the exposure among publicly-traded companies in these categories. Higher materiality could imply larger ESG-related risks or opportunities, and may influence sector and country weight preferences as well as individual stock selection. The investment strategy and positioning reflects FI’s outlook over a 12-18 month horizon.
Bottom-Up Investment Process
FI’s Securities Analysts perform fundamental research on prospective investments to identify securities with strategic attributes consistent with FI’s top-down views and competitive advantages relative to their defined peer group. The fundamental research process involves reviewing and evaluating a comprehensive set of qualitative and quantitative data, including ESG factors, prior to purchasing a security. Factors considered in portfolios include, but are not limited to: shareholder concentration, corporate stewardship, environmental opportunities & liabilities, and human or labour rights controversies. FI would choose not to invest in companies when, in its opinion, security level ESG issues: (i) violate a client mandated ESG policy, (ii) present an inordinate risk to a company’s operational or financial performance or (iii) appear to present undue headline risk to share price performance.
Information on Integration of Sustainability Risk in FII’s Remuneration Policy
Given that FII outsources the portfolio management function to FI, it is not currently envisaged that the consideration of Sustainability Risks will be of primary relevance to the functions performed by FII staff. Accordingly, FII does not currently anticipate consideration of Sustainability Risks as being a significant factor in the assessment of FII’s staff members’ variable remuneration.
No Consideration of Adverse Impacts of Investment Decisions on Sustainability Factors
Notwithstanding that the consideration of Sustainability Risks is integrated into FI’s investment decision-making process, by virtue of FII’s size, FII is not required and currently elects not to consider the adverse impacts of its investment decisions on environmental, social or employee matters, respect for human rights, or anti-corruption or anti-bribery matters (“Sustainability Factors”) in respect of all portfolios it manages. However, with respect to strategies that promote environmental or social characteristics or have a sustainable investment objective (an “ESG Strategy”), the sustainability-related disclosures provided below for each ESG Strategy describes how principal adverse impacts on Sustainability Factors are considered by FI, including to what extent the indicators listed in Table 1 of Annex I of the Commission Delegated Regulation (EU) 2022/1288 (the “SFDR RTS”) are taken into consideration by FI. Furthermore, for private clients who have one or more ESG Strategies implemented in their investment portfolio, such private clients will receive pre-contractual disclosures related to their investment portfolio that will describe how principal adverse impacts on Sustainability Factors are considered by FI in their investment portfolio.
Sustainability-Related Disclosures
FII makes available to its private clients certain ESG Strategies that can be implemented in a private client’s investment portfolio. By implementing an ESG Strategy in a private client’s investment portfolio, such portfolio is considered to be an Article 8 or Article 9 financial product under SFDR, which requires certain portfolio-specific disclosures to be provided on FII’s website. However, FII considers the management of its private client’s investment portfolio to be confidential, and will not publish portfolio-specific sustainability disclosures on its website. Instead, FII publishes the below information about the ESG Strategies at the model level, which will include SFDR periodic reporting on the performance of such ESG Strategies from a sustainability perspective.
Amendments to this Disclosure
Should any changes be made to this disclosure in the future, a clear explanation of such changes will be published here.
Implemented Changes
In January 2022, this disclosure was updated to reflect:
- the postponement of the SFDR RTS effective date to January 2023;
- SFDR Article 11 disclosures provided for the ESG Strategies;
- adding disclosures regarding the Taxonomy Regulation; and
- a change in FII’s SFDR categorization methodology for private client portfolios.
In December 2022, this disclosure was updated to:
- update the sustainability-related disclosures for the ESG Strategies to comply with the SFDR RTS;
- remove the principal adverse impact statement that was originally posted to comply with SFDR on a high level, principles basis; and
- remove disclosures not required under SFDR or the Taxonomy Regulation (Regulation EU/2020/852).