Souls Funds Management Limited

Organisational Overview
Organisational Overview This section captures information that helps determine if some of the subsequent questions are required and also plays a role in benchmarking. Please make sure you provide accurate answers. This is also one of the more challenging sections as it may require gathering information from multiple sources. We suggest you collect all this information before progressing to other parts of the questionnaire.
1. What were your organisation's total assets under management as of the most recent count (in millions)? (Estimating to the nearest hundred million as of December 31 2008 would be preferable - although the most recent available count would be sufficient. If your currency is not listed, please select 'other' and indicate your currency or convert to United States dollars.)			254
Please select currency			Australian dollar (AUD)
1a. If 'other' was selected, please specify the other currency here			No Answer
2. Please pick the one category and level of complexity that best describes your organisation (if your organisation is a pension fund, please also select your pension type). This information may be used to provide you with the best possible benchmarking. Complexity Highly complex:- (>20 investment strategies, multiple offices in different countries) Moderately complex:- (5-20 investment strategies, a few offices) Simple:- (<5 investment strategies, one office)
Category			Complexity
Mainstream investment manager			Simple
2a. If 'other' was selected, please specify the other category here			No answer
3. Please provide an approximation of your average asset mix for 2008 or your asset mix as of the most recent count (in percent): (+/- 5% is sufficient. The sum of all the fields must be 100%)
	Internal Active	Internal Passive	External Active	External Passive
Listed equity (developed markets)	100	0	0	0
Listed equity (emerging markets)	0	0	0	0
Fixed income (not including corporate issuers)	0	0	0	0
Fixed income (corporate issuers)	0	0	0	0
Private equity	0	0	0	0
Listed real estate or property	0	0	0	0
Non-listed real estate or property	0	0	0	0
Hedge funds	0	0	0	0
Commodities	0	0	0	0
Infrastructure	0	0	0	0
Cash	0	0	0	0
Other (Please specify):	0	0	0	0
Governance, Policy and Strategy
Governance, Policy and Strategy Questions 5 through 15 are about the governance and oversight of your organisation's responsible investment activities and the associated policies and strategy. This section will be scored separately from the six Principles. "Policy" in this section may refer to one overall RI policy or multiple policies that address various elements of RI.
5. Do you have a policy that makes specific reference to responsible investment (RI) or environmental, social, and governance (ESG) issues?			Yes
6. If you have a policy that makes specific reference to RI/ESG issues, which of the following Principles does it address? (Please check all that apply.)			Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.,Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.,Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.,Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.,Principle 5: We will work together to enhance our effectiveness in implementing the Principles.,Principle 6: We will each report on our activities and progress towards implementing the Principles.
7. If you have a policy that makes specific reference to RI/ESG issues, which of the following asset classes does it apply to? (Please check all that apply.)			Listed equity (developed markets)
8. If you have a policy that makes specific reference to RI/ESG issues, when was your policy last reviewed?			Within the last 3 years
9. If you have a policy that makes specific reference to RI/ESG issues, has it been disclosed publicly? (If answering yes, please indicate how this statement can be obtained - a URL would be sufficient. If answering no, please explain why not.)			Planning to in 2009
10. To what extent has your approach to responsible investment been translated into a plan of action as reflected in business planning, strategic planning, or similar internal management processes? Large extent: you have both long and short term RI objectives relating to various aspects of your RI program across asset classes and regions that are regularly updated or reviewed. Larger organisational objectives have been reduced to individual objectives for which staff members are held accountable on a regular basis. There are key performance indicators related to responsible investment and resources have been allocated. You feel you have invested considerably in RI implementation and processes. Moderate extent: you have a plan for some aspects of your RI program but not others. Some staff members have specific RI objectives. High level goals may be understood but not documented. You feel you are progressing in RI implementation but have some way to go. Small extent: you have developed a list of actions when you first adopted responsible investment or your approach to RI is ad hoc with new initiatives being implemented as time allows. You are at an early stage in your RI implementation.			To a moderate extent
11. Who within your organisation has responsibilities related to RI implementation? (Please check all that apply.)			Chief Executive Officer or Chief Investment Officer or equivalent,Other senior management,Middle management,Non RI or ESG investment professional
12. Do you have a policy or approach/process that requires screening out or excluding stocks or sectors from your investment universe?			Stocks
13. What are your reasons for screening out or excluding stocks or sectors from your investment universe? (Please check all that apply.)			Other (please specify): 'We only screen on debt related factors/consideration'
14. Please describe how your organisation assesses if there is a link between your RI activities and the performance (risk and return) of your investments:			At present Souls Funds Management does not have a formal process of doing so. We also believe this will be difficult to achieve in a definitive quantitative way in future. However, Souls Funds Management believes there is sufficient empirical evidence to suggest that such a link exists.
15. Please add any overall comments and clarifications related to Governance, Policy, and Strategy here.			With regard to question 9, we intend to upgrade our website in 2009 and as part of this we will publish our Responsible Investment Policy on our website.
Principle 1
Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes. For the purposes of this questionnaire, integration is the consideration of ESG issues alongside traditional financial measures, based on the belief that ESG issues can affect the performance (risk and/or return) of investment portfolios (to varying degrees across companies, sectors, regions, asset classes and through time). Please note that the view that ESG issues can influence investment returns may be based either on the premise that performance on these issues will eventually be reflected in financial and operational outcomes (revenue growth, margins, etc.) or the premise that the way in which the market rates or prices the stock will be affected even in the absence of an impact on financial or operational performance. However, exclusion of stocks from portfolios or downweighting them based on the possibility that an association with the stocks may adversely affect the owners profile or brand amongst stakeholders is not regarded as integration.
16. Please provide a one to two paragraph description of your approach to this Principle. This question and similar questions relating to each of the other Principles are being asked for three reasons. The first reason is to gather details regarding signatory implementation for inclusion in the PRI annual report on progress. The second reason is to capture activities not captured directly by questions in the Reporting and Assessment Tool. The third reason is to provide context and details to support verification calls.			Souls Funds Management believes that environmental, social and corporate governance (ESG) issues impact on investment valuations and can affect the performance of portfolios. Managed poorly, ESG practices have the potential to destroy shareholder value. As an active investment manager we therefore have a duty to consider in our investment decision making the potential financial impacts of companies' exposure to, and management of these issues.
Integration of ESG issues into investment analysis and decision-making processes of internally managed assets
17. For what percentage of your internal assets under active management do you integrate RI/ESG issues into your internal investment decision-making processes (in percent)? (+/- 5% is sufficient.)
Listed equity (developed markets)			100
18. To what extent have you integrated RI/ESG issues into your internal active investment decision-making processes? (Applies only to investments that include integration of RI/ESG issues as indicated in Q17.) Large extent: you employ a systematic process to integrate RI/ESG issue consideration. RI/ESG issues may be considered in security valuation, security selection, and/or portfolio construction. Moderate extent: for some RI/ESG issues you may have a systematic integration approach while for other issues you approach them in an ad hoc manner or not at all. Small extent: for a few RI/ESG issues you may integrate consideration some of the time.
Listed equity (developed markets)			To a moderate extent
19. When forming investment views, to what extent does your organisation gather and analyse ESG information, including, where applicable, information obtained from engagement activities? (Applies only to investments that include integration of RI/ESG issues as indicated in Q17.) Large extent: you gather and analyse information across a comprehensive range of ESG issues and across a large proportion of the markets and assets in your investment universe. Furthermore, the information is updated regularly. This research and analysis may be undertaken internally or may be purchased from an external party. In the latter case, internal resources are nevertheless applied to interpreting the information. Alternatively, one or more ESG issues may be the key driver for your overall investment strategy and process. Moderate extent: you gather and analyse information across a moderate range of ESG issues and across a significant part of your investment universe. There remain some gaps in coverage, either in terms of the issues and asset markets covered, or the frequency with which analysis is refreshed, as well as some gaps in internal capacity to analyse the information. Small extent: you gather and analyse some information on ESG issues. This research is ad hoc in nature, however, and considerable gaps exist in coverage and timeliness. You feel that you are in the early stages of developing capacity to gather and analyse information on ESG issues. Not applicable: only a possible answer if you don't manage assets internally.			To a moderate extent
20. To what extent do portfolio managers or others making investment decisions in your organisation apply the ESG information and analysis available to them when constructing and managing portfolios? (Applies only to investments that include integration of RI/ESG issues as indicated in Q17.) Large extent: you have a systematic approach towards assessing the implications of all ESG research and analysis which is gathered by your organisation and incorporating it into your assessment of the investment outlook for all investments which are potentially affected and, hence, into portfolio holdings. Moderate extent: you regularly consider the implications of ESG research for investments where the case for doing so is clear-cut. In other cases, however, ESG research is not thoroughly assessed and applied in formulating views on all investments where it may be relevant. Small extent: ESG research is used on an  as-needed basis. Generally, ESG research may be used as part of a qualitative overlay and to decide between investments where the investment case, judged on traditional analysis, is marginal. Alternatively, ESG research may be applied in portfolios only in respect of a relatively small number of sectors where one or more ESG issues are of most obvious relevance e.g. major corporate governance failings, high exposure to heavy polluters. Not applicable: only a possible answer if you don't manage assets internally.			To a moderate extent
21. To what extent do you have a process for improving the effectiveness of research and portfolio management processes with regards to ESG factors? (Applies only to investments that include integration of RI/ESG issues as indicated in Q17.) Large extent: on a continuous basis, you review both the quality and relevance of ESG research and the effectiveness with which it is applied in your day-to-day portfolio management, with a view to optimising your overall investment process through identifying opportunities or risks. Moderate extent: you review ESG research regularly (at least annually) with a view to enhancing its coverage and relevance and/or the way it is used in portfolio management. The focus is both on identifying investment opportunities and avoiding risks. Small extent: you occasionally review the integration of ESG research.			To a moderate extent
22. To what extent do you have a process for assessing and improving internal investment staff competency to incorporate RI/ESG issues into investment analysis and decision-making processes? (Applies only to investments that include integration of RI/ESG issues as indicated in Q17.) Large extent: all relevant staff members undergo a regular assessment of their RI competency, resulting in an individual plan for ongoing professional development. In addition, the overall skill mix within the team is regularly reviewed to identify any gaps. RI-competency may be integral to recruitment decisions. Moderate extent: relevant staff members are encouraged to undertake relevant external RI-related training and some in-house sessions are provided. RI-competency may be an element in recruitment decisions. Small extent: relevant staff members are permitted, at the organisation's cost, to attend external RI-related training courses, conferences etc.			To a small extent
Integration of ESG issues into investment analysis and decision-making processes of externally managed assets
23. This question is not applicable to you due to your response to Q3 regarding the use of active external investment management. For what percentage of your external assets under management are RI/ESG issues integrated into the investment decision-making processes of your external investment managers (in percent, +/- 5% is sufficient)?
Listed equity (developed markets)
Listed equity (emerging markets)
Fixed income (not including corporate issuers)
Fixed income (corporate issuers)
Private equity
Listed real estate or property
Non-listed real estate or property
Hedge funds
Infrastructure
24. This question is not applicable to you due to your response to Q3 regarding the use of active external investment management. To what extent have RI/ESG issues been integrated into the investment decision-making processes of your external investment managers? (Applies only to investments that include integration of RI/ESG issues as indicated in Q23.) Large extent: your investment manager employs a systematic process to integrate RI/ESG issue consideration. RI/ESG issues may be considered in security valuation, security selection, and/or portfolio construction. Moderate extent: for some RI/ESG issues your investment manager may have a systematic integration approach while for other issues they approach them in an ad hoc manner or not at all. Small extent: for a few RI/ESG issues your investment manager may integrate consideration some of the time.
Listed equity (developed markets)			No Answer
Listed equity (emerging markets)			No Answer
Fixed income (not including corporate issuers)			No Answer
Fixed income (corporate issuers)			No Answer
Private equity			No Answer
Listed real estate or property			No Answer
Non-listed real estate or property			No Answer
Hedge funds			No Answer
Infrastructure			No Answer
25. This question is not applicable to you due to your response to Q3 regarding the use of active external investment management. To what extent do you consider the capabilities of external investment managers to incorporate RI/ESG issues when searching for, selecting and retaining your external investment managers? (Applies only to investments that include integration of RI/ESG issues as indicated in Q23.) Large extent: ESG integration is integral to your views on all of your investment managers and, hence, on your hire, fire and retain decisions. You look at the ESG information available to your managers, the way that they integrate it into their investment decisions and the competence of their staff in ESG areas. Where you believe that managers are not developing their capabilities to your satisfaction, you raise your concerns with them and ensure that they recognise the importance of RI capability in determining the awarding of future mandates. Moderate extent: ESG integration is part of your assessment of all managers and there have been cases where your degree of comfort with a manager has been affected by their performance in the area. You may have made hire/fire decisions on this basis on rare occasions. You monitor the resources which the managers devote to the area and encourage them to develop their capability. You do not, however, tend to investigate the way that ESG research is reflected in portfolios. Small extent: you observe that your existing and potential managers have differing degrees of commitment to RI/ESG integration and, at the margin, favour those with higher commitment. This issue could be a factor in hire and fire decisions in the future. You have not, however, made a detailed assessment of the RI-related resources applied by all of your managers, nor of the way that such resources are integrated into the investment process.			No Answer
Integration - final comments
26. Please add any overall comments and clarifications related to Principle 1 here. Please also describe any significant activities relating to Principle 1 that have not been captured by the questions above.			No Answer
Principle 2
Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.
27. Please provide a one to two paragraph description of your approach to this Principle.			Souls Funds Management has established an "Engagement and Proxy Voting Policy" that provides a guideline for our engagement on ESG issues with companies that we invest in. In essence the policy states that where a material ESG issue is not addressed to the analyst's satisfaction, Souls Funds Management will inform management of our intention to vote against or abstain from relevant AGM resolutions. At this stage there has been limited "road testing" of this policy (especially with respect to "E" and "S" issues). A key component of this policy is our "Engagement and Proxy Voting Register" which captures details relating to these activities. Over time this provides the ability to track and further improve our ESG performance.
(Proxy) voting - applies only to listed equity (developed markets), listed equity (emerging markets) and listed real estate or property.
28. Do you have a (proxy) voting policy? (If 'Yes - disclosed publicly', please indicate how your (proxy) voting policy can be obtained- a URL would be sufficient. If answering no, please explain why not.)			Yes - internal document
29. Does your (proxy) voting policy address environmental, social, and governance issues?
Environmental			Yes
Social			Yes
Governance			Yes
30. Who decided how to vote on ballot items on behalf of your organisation in 2008? (Please check all that apply.)			Internal investment manager
31. To what extent is information related to ballot items gathered and analysed before voting decisions are made? Large extent: you might buy external voting research and recommendations and supplement it with your own research. Alternatively, you may undertake the research largely in-house. You review each ballot item before casting your votes and undertake whatever analysis is necessary to make an informed judgement. Moderate extent: you might either buy external voting research and recommendations or perform your own research. You review most ballot items before casting your votes and undertake whatever analysis is necessary in most cases to make an informed judgement. Small extent: You generally rely on your research provider to gather and analyse ballot items. You might perform some very limited research on a small number of issues. You might only review some ballot items before your votes are cast and don't usually undertake additional analysis to make an informed judgement.			To a large extent
32. Do you ensure that voting is done in accordance with your voting instructions?			We make no effort to ensure
33. Do you inform companies of your rationale when you abstain or vote against management recommendations?			Yes for all
34. Please indicate how many resolutions you could have voted on and how many resolutions you did vote on in 2008: (include abstentions as votes where votes against are not possible, use the last available one year period if information for 2008 is not available or too difficult to gather, approximate numbers are acceptable. If you are unable to provide the exact number please provide an approximation of the percentage by entering 10 in the 'Resolutions could have voted on' column and your estimate in the 'Resolutions voted on' column. So if you voted on about 70% of the possible resolutions you would enter 7 in the 'Resolutions voted on' column. If you are not sure, please enter a 1 in all four fields.)
		Resolutions could have voted on	Resolutions voted on
Domestic		1	1
Foreign		1	1
35. For the listed equities that you manage, do you provide (proxy) voting services for your clients if they request them?			Yes - According to our own policy or client-specific policies
36. How does your securities lending program address voting?			We do not have a securities lending program
37. How many shareholder resolutions related to ESG issues did you file or co-file during 2008?
As lead filer			0
As co-filer			0
Planning to be lead filer in 2009			0
Planning to be co-filer in 2009			0
38. Please explain why you did or did not file or co-file any shareholder resolutions related to RI/ESG issues during 2008:			No ESG issue was identified that did not receive a satisfactory response from the company to warrant calling for a shareholder resolution.
Engagement - general
39. Who engaged with companies to seek ESG improvements in 2008? Please rank who engaged with companies according to their importance within your overall active ownership activities. You can only select Most, Second, Third and Fourth most important once each. Only the method you rank as 'Most important' will be scored for benchmarking purposes. If you wish to request that your other methods of engagement also be scored, please complete all the relevant sections and email the PRI at assessment@unpri.org when you submit your response.
Internal staff			Most important
External engagement service provider(s)			Second most important
Other (Please specify):			No Answer
40. Do you have a written engagement policy or other documents that direct engagement? (If 'Yes - disclosed publicly', please indicate how your policy can be obtained- a URL would be sufficient.)			Yes - internal document
41. If you have an engagement policy or other documents that direct engagement, what do they include? (Please check all that apply.)			General high level policy to support direction of agents to engage with companies,Expectations of companies with regards to environmental issues,Expectations of companies with regards to social issues,Expectations of companies with regards to governance issues,Approach to monitoring companies,Approach to selecting companies for engagement
42. How many companies are you invested in?			70
Engagement - internal staff
43. To what extent do you have a process for identifying and prioritising ESG related engagement opportunities? Large extent: you gather and analyse information across a comprehensive range of ESG issues and across a large proportion of the markets in your investment universe. Furthermore, the information is updated regularly. This research and analysis may be entirely undertaken internally or may be purchased from an external party. In the latter case, however, it is understood that some internal resource would be required to interpret the information. Your research may include an analysis of the impacts of various issues on specific companies and prioritisation of engagement opportunities. Moderate extent: you gather and analyse information across a moderate range of ESG issues and across a significant part of your investment universe. There are some gaps in your coverage however, either in terms of the issues and markets covered, or the frequency with which analysis is refreshed. Small extent: you gather and analyse some information on ESG issues. This research is ad hoc in nature, however, and considerable gaps exist in coverage and timeliness. The process may be largely reactive rather than proactive.			Not applicable
44. How many portfolio companies did you engage with on ESG issues in 2008? Extensive engagement: you may have had multiple instances of focused interaction with a company on issues identified by you and with a view to changing the company's behaviour. You were predominantly engaging with people at the company with the authority to change corporate behaviour. The engagements were systematic and you began them with a clear goal in mind. Extensive engagement includes more than writing letters and includes bilateral meetings in person or on the phone. You may have identified other investors to work with to address the issues you have identified. Moderate engagement: you had more than one interaction with a company on issues identified by you or others. The engagement was somewhat systematic but the specific desired outcome may not have been clear at the outset. You may have responded to requests to engage with other investors on issues identified by them. Basic engagement: you directly contacted companies but your engagements tended to be ad hoc and reactive. At the commencement of the engagement, you may not have had clear goals in mind regarding the desired changes to the company's behaviour and you may not have pursued the issue beyond your initial contact with the company. You may have signed on to letters authored by others. Your engagements might be more about gathering information than seeking ESG related improvements.
Extensive engagement			3
Moderate engagement			0
Basic engagement			2
45. What proportion of your engagements addressed environmental, social or governance issues (in percent)? (One engagement may address more than one issue, so the three percentages need not add to 100%. For example, if you only had one engagement and it addressed environmental and governance issues then the answer would be 100% for environmental and 100% for governance.)
Environmental			40
Social			0
Governance			60
46. To what extent do you set ESG engagement objectives and attempt to evaluate your engagement success? Large extent: you may have developed a clear and systematic process (either through internal efforts or in partnership with an academic or other group) to regularly measure the impact of your engagement efforts. You set engagement objectives before engaging with companies and track outcomes against those objectives. Moderate extent: you may have developed a process to measure the impact of your engagement efforts but may not always apply it. You might set engagement objectives sometimes before engaging with companies. Small extent: you tend not to set engagement objectives before engaging with companies and may only keep track of your successful engagements.			Planning to in 2009
47. What percentage of engagements that ended in 2008 were deemed successful (in percent)? (Engagement success: a considerable part of objectives or milestones that were set when the engagement commenced were achieved.)			100
48. To what extent do you have a process for assessing and improving staff competency to act as active owners and incorporate ESG issues into ownership practices? Large extent: all relevant staff members undergo a regular assessment of their competency in the area of active ownership, resulting in an individual plan for ongoing professional development. In addition, the overall skill mix within the team is regularly reviewed to identify gaps. Competency in the skills required to implement active ownership practices is integral to recruitment decisions. Moderate extent: relevant staff members are encouraged to undertake relevant external training and some in-house sessions are provided. Competency in active ownership activities is an element in recruitment decisions. Small extent: relevant staff members are permitted to attend external training courses, conferences etc, paid for by the organisation, where the events will enhance active ownership competencies.			To a small extent
Engagement - external engagement service provider(s)
49. How many portfolio companies did your external engagement service provider(s) engage with on ESG issues on your behalf in 2008? Extensive engagement: your external engagement service provider(s) may have had multiple instances of focused interaction with a company on issues identified by you or them and with a view to changing the company's behaviour. Your external engagement service provider(s) was predominantly engaging with people at the company with the authority to change corporate behaviour. The engagements were systematic and they began them with a clear goal in mind. Extensive engagement includes more than writing letters and includes bilateral meetings in person or on the phone. They may have identified other investors to work with to address the issues you or they have identified. Moderate engagement: your external engagement service provider(s) had more than one interaction with a company on issues identified by you, them or others. The engagement was somewhat systematic but the specific desired outcome may not have been clear at the outset. Your external engagement service provider(s) may have responded to requests to engage with other investors on issues identified by them. Basic engagement: your external engagement service provider(s) directly contacted companies but their engagements tended to be ad hoc and reactive. At the commencement of the engagement, they may not have had clear goals in mind regarding the desired changes to the company's behaviour and they may not have pursued the issue beyond their initial contact with the company. Your external engagement service provider(s) may have signed on to letters authored by others. Their engagements might be more about gathering information than seeking ESG related improvements.
Extensive engagement			0
Moderate engagement			0
Basic engagement			0
50. What proportion of your external engagement service provider(s)'s engagements on your behalf addressed environmental, social or governance issues (in percent)? (One engagement may address more than one issue, so the three percentages need not add to 100%. For example, if you only had one engagement and it addressed environmental and governance issues then the answer would be 100% for environmental and 100% for governance.)
Environmental			100
Social			0
Governance			0
51. To what extent do you contribute to and assess the ESG engagement activities of your external engagement service provider(s)? Large extent: you probably have a regular dialogue with your service provider to identify and prioritise engagement issues. You may also collaborate with them to set engagement objectives. You require and review regular reporting on engagement activities performed on your behalf. You question why companies have or have not been engaged, the success of the engagements, and the background and experience of staff performing engagement for you, with a view to assessing the value of the service on an ongoing basis. Moderate extent: you keep up-to-date with issues being pursued by your provider but do not generally participate in determining the issues or the objectives. You require and review regular reporting on engagement activities performed on your behalf. You evaluate the merit of the service regularly (say, annually) but do not undertake in-depth analysis in doing so. Small extent: you receive reporting on engagement activities performed on your behalf but have minimal dialogue with your service provider. You do not evaluate the merit of the service regularly.			To a small extent
Engagement - external investment manager(s)
52. This question is not applicable to you due to your response to Q39 regarding who engages with companies. How many portfolio companies did your external investment manager(s)'s engage with on ESG issues on your behalf in 2008? Extensive engagement: your external investment manager(s) may have had multiple instances of focused interaction with a company on issues identified by you or them and with a view to changing the company's behaviour. Your external investment manager(s) was predominantly engaging with people at the company with the authority to change corporate behaviour. The engagements were systematic and they began them with a clear goal in mind. Extensive engagement includes more than writing letters and includes bilateral meetings in person or on the phone. They may have identified other investors to work with to address the issues you or they have identified. Moderate engagement: your external investment manager(s) had more than one interaction with a company on issues identified by you, them or others. The engagement was somewhat systematic but the specific desired outcome may not have been clear at the outset. Your external investment manager(s) may have responded to requests to engage with other investors on issues identified by them. Basic engagement: your external investment manager(s) directly contacted companies but their engagements tended to be ad hoc and reactive. At the commencement of the engagement, they may not have had clear goals in mind regarding the desired changes to the company's behaviour and they may not have pursued the issue beyond their initial contact with the company. Your external investment manager(s) may have signed on to letters authored by others. Their engagements might be more about gathering information than seeking ESG related improvements.
Extensive engagement
Moderate engagement
Basic engagement
53. This question is not applicable to you due to your response to Q39 regarding who engages with companies. What proportion of your external investment manager(s)'s engagements on your behalf addressed environmental, social or governance issues (in percent)? (One engagement may address more than one issue, so the three percentages need not add to 100%. For example, if you only had one engagement and it addressed environmental and governance issues then the answer would be 100% for environmental and 100% for governance.)
Environmental
Social
Governance
54. This question is not applicable to you due to your response to Q39 regarding who engages with companies. To what extent do you contribute to and assess the ESG engagement activities of your external investment manager(s)? Large extent: you require and review regular reporting on engagement activities performed on your behalf. You have regular discussions with your external managers on the issues to be pursued through engagement and the engagement objectives. You also have a dialogue on why companies have or have not been engaged, the success of engagements, and the background and experience of staff performing engagement for you. You regularly evaluate the managers' engagement activity based on these dialogues and other analysis. Moderate extent: you take an active interest in the managers' engagement activities but do not have regular dialogue with the manager. You require and review regular reporting on engagement activities performed on your behalf. You evaluate the managers' engagement activity regularly (say annually) but do not undertake additional analysis in doing so. Small extent: you receive reporting on engagement activities performed on your behalf where provided but do not actively seek to discuss engagement activities with your managers. You do not evaluate the managers' engagement activities regularly.			No Answer
55. This question is not applicable to you due to your response to Q39 regarding who engages with companies. Did you consider the capabilities of external investment managers to engage with companies on ESG issues on your behalf when searching for, selecting and retaining your investment managers?			No Answer
Engagement - final comments
56. What ESG issues were addressed in your or your service providers'engagement initiatives? (Please check all that apply.)			Benefits and compensation,Climate change,Governance,Other (please specify): 'Water'
57. What measures do you or your external service provider(s) use to assess the impact and success of engagement?			Although Souls Funds Management is member of a number of organisations that concern themselves with ESG issues, they are not specific ESG engagement service providers, and their work deals as much with government and policy as it does with direct company engagement. The IGCC has a particular focus on environmental engagement through the CDP, for which its efforts have improved the quality and quantity of responses in 2008.
58. Please add any overall comments and clarifications related to Principle 2 here. Please also describe any significant activities relating to Principle 2 that have not been captured by the questions above.			The reason for our  not sure response in question 34 is due to our  Engagement and Proxy Voting Register only formally being implemented in November 2008. While we previously voted and engaged (mostly on  G issues), this had not been documented until this point in time. Our expectation is that in 2009 we ought to be able to provide more definitive responses to some of the questions in this section. For question 49 we responded "0". However, we note that through the engagement effort by the IGCC, the number of companies that responded to the CDP increased significantly to 72% for ASX100 companies and 50% for NZX50 companies.
Principle 3
Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.
59. Please provide a one to two paragraph description of your approach to this Principle.			Souls Funds Management is cognisant of the fact that standardised ESG reporting is essential for benchmarking of corporate performance. We support collaborative initiatives that work towards achieving more transparent and consistent ESG disclosure. Souls Funds Management will take an active role where it is not satisfied with the response it obtains to any ESG issue it has raised with a company. All Souls Funds Management initiatives with respect to the above are captured in the  Engagement and Proxy Voting Register .
60. Who asked investee companies (or other investment entities) to provide information about their ESG policies, practices or performance in 2008? (Please check all that apply.)			Internal staff,External engagement service provider(s) collaboratively with other investors
61. To what extent did you or your external engagement service provider(s) or your external investment manager(s) have a dialogue with investee companies (or other investment entities) regarding the production of standardized reporting about their ESG policies, practices or performance in 2008? ('Standardized' could also include systematic reporting in areas where standardized reporting has not yet emerged.) Large extent: you or your agents have direct contact with companies and regularly encourage systematic ESG reporting by them. You or your agents have a systematic approach to assessing the quality of reporting across a range of issues which are judged to be important and ask for standardised reporting where appropriate. You or your agents have taken a leading role in investor collaborations seeking systematic reporting by companies. You or your agents may also regularly provide feedback to companies on their reporting. Moderate extent: you or your agents have direct contact with companies. You or your agents ask them to provide standardised reporting on key ESG issues from time to time, but you do not have a systematic approach to identifying cases where scope exists for improved reporting. You or your agents may also occasionally provide feedback to companies on their reporting. Small extent: you or your agents have signed on to one or more collaborative initiatives regarding standardised reporting. You or your agents may also have occasionally asked companies for standardised reporting and /or provided feedback on their reporting.
Listed equity (developed market)			To a small extent
62. What formats of reporting on ESG issue policies, practices or performance have been requested? Please check all that apply.			Carbon Disclosure Project (CDP),Global Framework for Climate Risk Disclosure
63. To what extent did you or your external engagement service provider(s) or your external investment manager(s) seek information from companies regarding their practices related to norms, standards, codes of conduct or international initiatives related to ESG issues in 2008? Large extent: you or your agents have made a substantial and systematic effort to seek information from companies regarding their participation in and compliance with a number of relevant norms, standards and codes. Moderate extent: you or your agents have made a significant effort to seek information from companies regarding their participation in and compliance with at least some relevant norms, standards and codes. Small extent: you or your agents have requested information from some companies but this has been undertaken in an ad hoc manner.			To a small extent
64. Please add any overall comments and clarifications related to Principle 3 here. Please also describe any significant activities relating to Principle 3 that have not been captured by the questions above.			No Answer
Principle 4
Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.
65. Please provide a one to two paragraph description of your approach to this Principle.			Souls Funds Management's enthusiasm to promote the acceptance and implementation of the UN-PRI principles is tempered by the fact that we have only just begun our journey on the ESG road. We will feel more comfortable to be more assertive once we have made more meaningful progress internally with respect to their implementation across our own operations.
66. Did you consider RI/ESG requirements when searching for and selecting service providers in 2008 when applicable?
Investment consultant			Not applicable
Proxy voting service provider			Not applicable
External overlay service provider			Not applicable
Investment research provider			Yes, some of the time
67. Have you included RI/ESG elements in the following?
Investment monitoring			Yes, some of the time
Incentive structure (internally managed)			Yes, some of the time
Incentive structure (externally managed)			Not applicable
Contractual relationships with external investment managers			Not applicable
Contractual relationships with other investment related service providers			No
68. To what extent did you encourage your eligible service providers to become PRI signatories or consider RI/ESG factors in 2008? (Service providers include but are not limited to: external investment managers, investment consultants, proxy voting service providers, external engagement service providers, and investment research providers.) Large extent: in 2008 you asked all of your service providers that are not yet PRI signatories if they would sign the PRI or develop RI/ESG capability. Moderate extent: in 2008 you asked some (greater than 40%) of your service providers that are not yet PRI signatories if they would sign the PRI or develop RI/ESG capability. Small extent: in 2008 you asked a few (less than 40%) of your service providers that are not yet PRI signatories if they would sign the PRI or develop RI/ESG capability. Not applicable: only an available option if you have no service providers or if all of your service providers are already PRI signatories or already consider RI/ESG factors.			Not at all
69. To what extent did you encourage your institutional clients to become PRI signatories or consider RI/ESG factors in 2008? Large extent: in 2008 you asked all of your institutional clients that are not yet PRI signatories or don't yet consider RI if they would become PRI signatories or consider RI. Moderate extent: in 2008 you asked some (greater than 40%) of your institutional clients that are not yet PRI signatories or don't yet consider RI if they would become PRI signatories or consider RI factors. Small extent: in 2008 you asked a few (less than 40%) of your institutional clients that are not yet PRI signatories or don't yet consider RI if they would become PRI signatories or consider RI. Not applicable: only an available option if you have no institutional clients or if all of your institutional clients are already PRI signatories or already consider RI/ESG factors.			Not at all
70. To what extent did you encourage peer organisations to become PRI signatories or consider RI/ESG factors in 2008? Large extent: in 2008 you were an active advocate for RI and the PRI. You may have actively sought to promote RI or the PRI in industry forums or when speaking with the media. Moderate extent: in 2008 when approached, you were an advocate for RI and the PRI. When asked, you may have sought to promote RI or the PRI in industry forums or when asked about RI when speaking with the media. Small extent: in 2008 when approached, you were sometimes an advocate for RI and the PRI. When asked, you might have sought to promote RI or the PRI in industry forums or when asked about RI when speaking with the media, but you many not have encouraged your peers to become PRI signatories or consider RI/ESG factors very often.			Not at all
71. Have you revisited any relationships with service providers in light of RI/ESG issue-related capabilities?			No
72. Does your broker evaluation process (which determines how you allocate commissions to brokers) include an ESG component and/or do you have a budget to pay for ESG broker research?			No
73A. What is your total investment research budget (including brokerage commissions intended to recognize research, in the same currency used in Q1)			1110028
73B. what proportion of your total investment research budget is allocated to ESG research (in percent)?			4
74. To what extent do you identify ESG issues and suggest them to brokers or other investment research providers for research? Large extent: you have identified specific environmental, social, or governance issues that you would like more research on from your brokers or other research providers. You may have identified specific companies, sectors or themes for research. You may have contacted multiple research sources to indicate your desire to receive this sort of research. You may have asked for mainstream research that incorporates ESG issues. Moderate extent: you may have identified some research providers that can provide you with ESG research and suggested future research ideas. You may not have contacted all of your research providers to request this research. Small extent: you have indicated to your brokers or other investment research providers that you are interested in receiving ESG research.			Not at all
75. To what extent did you engage in dialogue, lobbying or initiatives pertaining to government policy and/or industry regulations (for example, stock exchanges or accounting standards) related to RI/ESG issues in 2008? Large extent: you may have initiated dialogue on policy initiatives relating to RI/ESG issues or participated extensively in dialogues initiated by others. You may have commented on issues relevant to your domestic market as well as issues relevant to foreign markets. Moderate extent: you participated in some policy initiatives relating to RI/ESG issues. Your engagement may be focused on domestic markets. Small extent: you participated in a few policy initiatives relating to RI/ESG issues when asked to.			To a small extent
76. Please add any overall comments and clarifications related to Principle 4 here. Please also describe any significant activities relating to Principle 4 that have not been captured by the questions above.			No Answer
Principle 5
Principle 5: We will work together to enhance our effectiveness in implementing the Principles.
77. Please provide a one to two paragraph description of your approach to this Principle.			Through membership of the IGCC and RIAA and in fact through being a signatory to the UN-PRI, SFM is committed to collaboration to further enhance the implementation process of the Principles. While SFM faces some limitation as to how active it can be in this collaboration effort due to its size, it will endeavour to participate in collaborative efforts where appropriate and indeed initiate collaboration where this is deemed necessary. All such collaboration is recorded in the  Engagement and Proxy Voting Register and reviewed annually.
78. To what extent did you collaborate with other investors to improve your effectiveness in implementing each of the following Principles? Large extent: you may have initiated one or more collaborative initiatives or industry associations relevant to the principle and adopted a leadership position within established initiatives or associations. You may also have worked actively with a number of other investors on specific issues of relevance to the principle. Moderate extent: you have been an active participant in a number of relevant collaborative initiatives. You may also have undertaken some work with other investors on specific issues of relevance to the principle. Small extent: you may have joined a small number of relevant collaborative initiatives but have not been an active participant in their activities.
Principle 1			To a small extent
Principle 2			To a small extent
Principle 3			To a small extent
Principle 4			To a small extent
79. How did you use the PRI Engagement Clearinghouse in 2008? (Please check all that apply.)			Logged in during 2008 to use the Clearinghouse as a learning tool or to keep up to date on ongoing engagements,Planning to log in in 2009
80. Did you participate in any of the following RI/ESG issue-related collaborations and/or associations? For those not listed, please use the "other" field: (Please check all that apply.)			Carbon Disclosure Project,Investor Group on Climate Change, Australia/New Zealand (IGCC),Other (please specify): 'Souls Funds Management is also a member of the Responsible Investment Association of Australia'
81. Please indicate the three RI/ESG issue-related collaborative engagement initiatives and/or industry associations that you participated in most extensively and indicate how you did so: Large extent: you may have participated actively in the leadership of the initiative and in the preparation of position papers, joint statements or meetings. You also acted as a spokesperson for the initiative and actively promoted the initiative. You may participate in working groups on specific issues and contribute to the organisation or content of events organised by the group. You may have provided financial support for the initiative. Moderate extent: you may have participated to some degree in leadership of the initiative and/or in preparation of position papers and joint statements. You also provided general support for the initiative in various non-public forums. Small extent: You joined the initiative or association, attended some meetings and paid a membership fee but were not actively involved in the leadership or work program of the initiative.
Carbon Disclosure Project		To a small extent	Via IGCC membership and being signatory to information request letter
PRI		To a small extent	Souls Funds Management signed a collaborative engagement letter on the CEO Water Mandate
1st Other specify from Q80		To a small extent	1) Responsible Investment Academy – Souls Funds Management sent Andreas Stephens (ESG co-ordinator) to a function at the Australian parliament house in support of establishment of the world’s first Responsible Investment Academy. The initiative was successful with the Federal Government pledging $2.5m in funding for the academy.
82. Please add any overall comments and clarifications related to Principle 5 here. Please also describe any significant activities relating to Principle 5 that have not been captured by the questions above.			Souls Funds Management has become a signatory to the UN-PRI in mid-2008. We are therefore still on a steep learning curve with respect to ESG matters.
Principle 6
Principle 6: We will each report on our activities and progress towards implementing the Principles.
83. Please provide a one to two paragraph description of your approach to this Principle.			As mentioned above, Souls Funds Management only became a UN-PRI signatory in mid 2008. It was only in November 2008 that Souls Funds Management formulated its formal  Responsible Investment Framework Document", from which other policies such as our  Engagement and Proxy Voting Policy flowed. This policy also resulted in the creation of an "Engagement and Proxy Voting Register" in which all ESG activities are being recorded. In future this register will allow Souls Funds Management to report and review its ESG performance using this register.
84. To what extent did you disclose (privately and/or publicly) your approach to incorporating ESG issues into investment analysis and decision-making processes in 2008? (If you disclose publicly, please indicate how this disclosure can be obtained - a URL would be sufficient. If answering not at all, please explain why not.) Large extent: you provided a review of your investment process, highlighting the way in which analysis of ESG issues is integrated into investment decisions. This review was comprehensive (e.g. covered multiple asset classes where relevant) and detailed, subject to the necessity to protect information on proprietary techniques. This review was disclosed publicly and is readily accessible via your website. Moderate extent: you may have prepared a comprehensive and detailed review of your investment process highlighting ESG integration. However, it was not necessarily distributed publicly. Alternatively, your review may have contained gaps either in coverage or in detail. Small extent: you provided only a relatively brief overview of your investment approach and the integration of ESG analysis into decisions.			To a small extent: 'Given that our  Responsible Investment Framework Document was only developed in late 2008, at this stage we have only provided disclosure to a limited extent.'
85. How did you disclose your (proxy) voting record in 2008? (Please select all that apply. If you disclose publicly, please indicate how this disclosure can be obtained - a URL would be sufficient. If answering not at all, please explain why not.)			Not at all: 'Our  Engagement and Proxy Voting Register was only established in November 2008. Prior to establishing this register, we did not keep a formal record of our proxy voting, even though we did do it. In future years, as we collect more precise data on our voting record, our level of disclosure will improve. We also note that for wholesale clients we provide data that is requested by our clients, and so far we have not received any request to provide proxy voting records.'
86. To what extent did you disclose (privately and/or publicly) your RI/ESG issue-related engagement activities, results and progress in 2008? (If you disclose publicly, please indicate how this disclosure can be obtained - a URL would be sufficient. If answering not at all, please explain why not.) Large extent: your reporting provided background on the issues at hand, the nature of the engagement and the outcomes. You may have reported the companies that you engaged with and the issues covered with the companies. You may have also covered emerging issues on which you intend to pursue engagement in future. You may have reported publicly on all of your key RI/ESG engagement activities. Moderate extent: you reported on some of your key RI/ESG engagement activities. Your reporting may not have been disclosed publicly. Small extent: you provided an overview of your RI/ESG engagement activities, possibly including some examples.			Not at all: 'Our  Responsible Investment Framework Document was developed during 2008 and only got documented in November 2008. We did not deem it appropriate to disclose ESG information while we were still developing and  road testing our ESG implementation approach. We also note that often our disclosure on various aspects of our investment process is client driven, and at this stage clients have not been seeking specific detail on how exactly we dealt with engagement issues.'
87. Did you disclose (privately and/or publicly) RI/ESG activities, results and progress related to Principle 3, Principle 4 or Principle 5 in 2008? (If you disclose publicly, please indicate how this disclosure can be obtained - a URL would be sufficient. If answering not at all, please explain why not.)
Principle 3		Not at all	As mentioned above, our  Engagement and Proxy Voting Register was only established in November 2008. Prior to establishing this register, we did not keep a formal record of our proxy voting, even though we did do it. In future years, as we collect more precise data on our voting record, our level of disclosure will improve. We also note that for wholesale clients we provide data that is requested by our clients, and so far we have not received any request to provide proxy voting records.
Principle 4		Not at all	See above
Principle 5		Not at all	See above
88. How would you like to publish your responses to this PRI Reporting and Assessment tool? (Please check all that apply.)			Please automatically publish our responses to the reporting and assessment tool in full on the PRI website
89. Please add any overall comments and clarifications related to Principle 6 here. Please also describe any significant activities relating to Principle 6 that have not been captured by the questions above.			No Answer
Closing Comments
90. Please describe the benefits you have enjoyed as a result of signing the PRI:			UN-PRI organised webinars and presentations have provided us with a better understanding of ESG relevant issues. As our response to questions on Principle 5 indicate, membership has resulted in some collaborations that are in support of the Principles. Without being a signatory to the UN-PRI these type of initiatives would be far less likely to get off the ground. The UN-PRI provides an excellent platform from which small and large players in the finance industry can further develop the ESG agenda.
91. What has your organisation changed as a direct result of becoming a PRI signatory?			Souls Funds Management recognised the importance of becoming a UN-PRI signatory early on in our ESG integration process. We therefore built our  Responsible Investment Framework around the UN-PRI principles. Hence our overall ESG agenda is more or less aligned with the UN-PRI principles. While the decision to integrate ESG into our investment process had been taken prior to signing onto the UN-PRI, a lot of the activities we are doing in terms of engagement, collaboration and reporting are a direct result of being a UN-PRI signatory.
92. Did the financial market turmoil of 2008 cause you to change your approach to the consideration of ESG factors or active ownership? If it did, please explain how.			The financial market turmoil did not affect our approach to ESG issues, but further increased our conviction that our previously implemented  G assessment is a critically important factor in valuation of potential investments
93. What are the top three activities the PRI Secretariat could undertake to enhance and encourage further implementation of the PRI by current and prospective signatories?
1.			All the PRI Secretariat needs to do is to ensure the integrity of the UN-PRI which it can do by ensuring that the verification process of the reporting continues. This keeps signatories on their toes and Souls Funds Management believes this will generate further momentum in spreading the word about the UN-PRI.
2.			From our own experience, the entire ESG issue can be a bit confusing until an organisation knows which course to chart with respect to implementing ESG considerations into its investment process. Perhaps a system whereby the UN-PRI puts new signatories in touch with organisations that are well down the road with respect to ESG implementation might assist in speeding up the early part of the learning curve for new signatories. It is probably at the very early stage that our organisation made the least progress despite our best intentions.
3.			Consideration should be given by the Secretariat for the UN-PRI to, in its own right, adopt a more activist role in raising ESG awareness within corporations by, for example, lobbying relevant agencies - stock exchanges, industry bodies, governments, and regulators - for improved ESG practices. Until now, the UN-PRI's has role has been seen largely as a co-ordinating function, whereas its newly-launched global ESG database will provide the UN-PRI with best-in-class practices which could be utilised to great effect if combined with a more activist role.
94. What are your top three PRI-related goals/priorities for 2009?
1.			Expand the application of Principle 1 across a broader range of stocks in our various portfolios
2.			Improve on the Principles we are currently underscoring, and where we can have impact, namely Principles 3 to 6.
3.			Increase exposure of our investment professionals to ESG activities eg. RIAA, IGCC
95. What were your most significant achievements in 2008 in relation to your implementation of Principles?
Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.			To get the entire Investment Team to agree on how we are to implement ESG issues into our investment process  i.e. how we addressed Principle 1. This is the foundation on which everything else will build.
Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.			Although Souls Funds Management always did proxy voting for some small cap mandates, the development of our  Engagement and Proxy Voting Policy and the  Engagement and Proxy Voting Register ensured that we now cast proxy votes for both small and large cap portfolios across all funds and mandates.
Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.			Maintaining the  Engagement and Proxy Voting Register will also assist in the eventual disclosure and reporting of our ESG activities to the UN-PRI and Souls Funds Management clients.
Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.			Souls Funds Management only played a peripheral role in lobbying the Australian federal government to provide funding for a  Responsible Investment Academy . However, it was extremely pleasing to see this initiative to get off the ground and for the government to provide the funding.
Principle 5: We will work together to enhance our effectiveness in implementing the Principles.			While having no false illusions about the significance of our organisation in the above process, Souls Funds Management's presence highlighted the strong industry support for this initiative, which ultimately was necessary to get the funding. It further highlights how powerful Principle 5 is, as collaboration ensures that the ESG issues are taken more seriously than if there was only the occasional voice in the desert calling for action on ESG issues.
Principle 6: We will each report on our activities and progress towards implementing the Principles.			This report to the UN-PRI is our first report on progress in our ESG implementation. It will serve as a reference point to identify opportunities for further improvement of our overall ESG implementation.
96. What were your biggest barriers in 2008 with relation to your implementation of the Principles?
Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.			In 2008 our main focus was on developing our process with respect to Principle 1. As this required all of the Investment Team to have the same understanding, this was a very time intensive undertaking.
Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.			It was only in November 2008 that we articulated our  Engagement and Proxy Voting Policy which deals with Principle 2.
Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.			Souls Funds Management only just started activities in relation to Principles 3 to 6. Being a small boutique fund manger, Souls Funds Management is somewhat time constrained in its ability to lead the way on issues such as collaboration. On the other hand, Souls Funds Management is committed to the philosophy of continuous improvement, and we intend to build on our efforts in 2008.
Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.			See comment on Principle 3 above
Principle 5: We will work together to enhance our effectiveness in implementing the Principles.			See comment on Principle 3 above
Principle 6: We will each report on our activities and progress towards implementing the Principles.			See comment on Principle 3 above
97. Please indicate which principle you find the most difficult to implement and the principle you find the least difficult to implement:
Most difficult			Principle 6
Least difficult			Principle 2