Summary of responses to the PRI reporting and assessment tool 2008

Aviva Investors

Organisational Overview
1. What were your organisation's total assets under management as of 31 December 2007 (in millions)?164840
Please select currencyBritish pound (GBP)
1a. If 'Other' was selected, please specify the other currency here
2. What category would best describe your organisation?
3. What proportion (in %) of your fund is defined benefit and what proportion (in %) is defined contribution? (please only answer this question if you answered  Pension or superannuation or retirement or provident fund or plan to Q2)
Defined benefit
Defined contribution
4. Please provide an overview of your asset mix as of 31 December 2007 (in %):
Listed equity (developed market, active)8.5
Listed equity (developed market, passive)8.5
Listed equity (emerging market, active)8.5
Listed equity (emerging market, passive)8.5
Fixed income - developed markets17
Fixed income - emerging markets17
Real estate or property19
Private equity0.5
Hedge fund0
Infrastructure0
Currency0
Commodities0
Cash10
Other (Please specify): Includes Alternative Investments and unallocated above 2.5
Includes Alternative Investments and unallocated above
5. Please indicate what percentage of your assets are managed internally and what percentage are managed externally (in %):
 
Internal
External
Listed equity (developed market, active)1000
Listed equity (developed market, passive)1000
Listed equity (emerging market, active)1000
Listed equity (emerging market, passive)1000
Fixed income - developed markets1000
Fixed income - emerging markets1000
Real estate or property1000
Private equity1000
Hedge fund00
Infrastructure00
Currency00
Commodities00
Cash1000
Other (Please specify): Includes Alternative Investments and unallocated above 1000
Includes Alternative Investments and unallocated above
Principle 1
7. Do you have a formal investment policy statement that makes specific reference to the integration of responsible investment (RI) or environmental, social and governance (ESG) issues within investment decision making and ownership practices?
8. Do you have a statement that makes specific reference to the integration of responsible investment (RI) or environmental, social and governance (ESG) issues within investment decision making and ownership practices?Yes, it is an independent RI/ESG statement
9. In what year were RI/ESG issues first formally addressed in a policy statement (integrated or independent)?2001
10. Has your statement that makes specific reference to the integration of RI or ESG issues been disclosed publicly?Yes
11. Please indicate how this statement that makes specific reference to the integration of RI or ESG issues can be obtained (a URL would be sufficient):http://www.morleyfm.co.uk/morley/groups/internet/ documents/salessupportmaterial/pdf_002896.pdf
12. For what percentage of your internal assets under management do you integrate RI/ESG issues into your internal investment decision-making processes? (in %)
Listed equity (developed market, active)6.25
Listed equity (developed market, passive)6.25
Listed equity (emerging market, active)6.25
Listed equity (emerging market, passive)6.25
Fixed income - developed markets0
Fixed income - emerging markets0
Real estate or property0
Private equity0
Hedge fund
Infrastructure
Currency
Commodities
Cash0
{inst1}0
13. To what extent have you integrated RI/ESG issues into your internal investment decision-making processes?
Listed equity (developed market, active)To a large extent
Listed equity (developed market, passive)To a large extent
Listed equity (emerging market, active)To a moderate extent
Listed equity (emerging market, passive)To a moderate extent
Fixed income - developed marketsNo Answer
Fixed income - emerging marketsNo Answer
Real estate or propertyNo Answer
Private equityNo Answer
Hedge fundNo Answer
InfrastructureNo Answer
CurrencyNo Answer
CommoditiesNo Answer
CashNo Answer
{inst1}No Answer
14. 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 %)
Listed equity (developed market, active)
Listed equity (developed market, passive)
Listed equity (emerging market, active)
Listed equity (emerging market, passive)
Fixed income - developed markets
Fixed income - emerging markets
Real estate or property
Private equity
Hedge fund
Infrastructure
Currency
Commodities
Cash
{inst}
15. To what extent have RI/ESG issues been integrated into the investment decision-making processes of your external investment managers?
Listed equity (developed market, active)No Answer
Listed equity (developed market, passive)No Answer
Listed equity (emerging market, active)No Answer
Listed equity (emerging market, passive)No Answer
Fixed income - developed marketsNo Answer
Fixed income - emerging marketsNo Answer
Real estate or propertyNo Answer
Private equityNo Answer
Hedge fundNo Answer
InfrastructureNo Answer
CurrencyNo Answer
CommoditiesNo Answer
CashNo Answer
{inst}No Answer
16. What proportion of your assets involve screening out or excluding stocks or sectors based on ethical (rather than long-term financial) criteria? (in %)0.01
17. Do you have any staff dedicated to RI/ESG issue analysis and/or implementation?
 
Dedicated
Combined full-time equivalents
Investment analyst20
Research analyst00
RI/ESG issue policy advisor00
(proxy) Voting specialist30
Engagement specialist30
Portfolio manager50
Other (Please specify)00
18. Which Board committee or other executive body has overall responsibility for RI/ESG issues?The Socially Responsible Investment Advisory Committee and the Aviva Board.
19. Do you assess the capabilities of internal investment staff to incorporate RI/ESG issues?Yes
20. Do you assess the capabilities of external investment managers to incorporate RI/ESG issues?No Answer
21. Approximately what percentage of your internal non-ESG-specialist investment management staff received RI/ESG training in 2007? (in %)25
22. What forms of RI/ESG training or awareness raising have been invested in, encouraged or provided for internal staff (investment and other)?Informal internal training,Conferences,Other (please specify): 'Periodic briefings'
23. Did you support the development of nonproprietary RI/ESG issue-related tools, metrics, analysis or academic research in 2007?To a large extent
24. Please indicate how the results of nonproprietary RI/ESG issue-related tools, metrics, analysis or academic research development you supported can be obtained if they have been disclosed publicly (a URL would be sufficient):http://www.cdproject.net/ http://www.unepfi.org/
25. Have you advocated/supported/ encouraged/participated in RI/ESG issue-related industry-wide training for investment professionals during 2007?Sponsored industry events,Advocated RI/ESG coverage in professional training programs (CFA, MBA, etc.),Spoke at or attended conferences,Had dialogue or exchanges with peers,Instructed at universities or colleges,Other (please specify): 'Morley also has a Trustee Tutor, which includes sections on ESG issues and sustainable and responsible investment.'
26. What was your most significant achievement in 2007 in relation to your implementation of Principle 1?The performance of our SRI funds.
27. What was your biggest barrier in 2007 with relation to your implementation of Principle 1?placeholder
28. Please add any overall comments and clarifications related to Principle 1 here.placeholder
Principle 2
29. To what extent did you employ the following approaches in your 2007 active ownership strategy for listed equities?
(Proxy) votingTo a large extent
Direct engagement conducted privatelyTo a large extent
Direct engagement conducted publiclyTo a moderate extent
Collaborative engagementTo a large extent
Filing shareholder resolutionsNot at all
Co-filing shareholder resolutionsTo a large extent
Other (Please specify):No Answer
30. To what extent did you employ the following approaches in your 2007 active ownership strategy for all asset classes other than listed equity?
(Proxy) votingNot at all
Direct engagement conducted privatelyNot at all
Direct engagement conducted publiclyNot at all
Collaborative engagementNot at all
Other (Please specify):No Answer
31. Do you have a (proxy) voting policy?Yes - disclosed publicly
32. To what extent does your (proxy) voting policy direct action on ESG issues? For each issue, please indicate the extent of direction.
EnvironmentalTo a large extent
SocialTo a large extent
GovernanceTo a large extent
33. Does your (proxy) voting policy apply to all voting regions (where possible)?Some (please specify regional differences): 'Some - Main voting and engagement focus is UK, large cap stocks in Continental Europe. Our voting also covers all US holdings using a Taft-Hartley policy. Emerging Markets are ad hoc with no formal guidelines.'
34. Please indicate how your (proxy) voting policy can be obtained (a URL would be sufficient):http://www.morleyfm.co.uk/morley/groups/internet/ documents/salessupportmaterial/pdf_002896.pdf
35. Do you ensure that voting is done in accordance with your (proxy) voting policy?Yes for all
36. What percentage of total votes cast were against management? (in %)17.5
37. What percentage of shareholder resolutions relating to environmental, social or governance issues was supported? (in %)
Environmental33
Social33
Governance33
38. Do you conduct (proxy) voting on behalf of your clients?Yes - According to our own policy or client-specific policies
39. How many shareholder resolutions related to RI/ESG issues did you participate in during 2007?
As lead filer0
As co-filer5
Planning to be lead filer in 20080
Planning to be co-filer in 20080
40. How were portfolio companies engaged with in 2007? Please check all that apply.Internal staff engaged portfolio companies directly,Internal staff engaged portfolio companies collaboratively
41. Do you systematically bring RI/ESG issue-related engagement opportunities to your clients?To a large extent
42. Do you systematically ask your external investment managers to bring RI/ESG issue-related engagement opportunities to you?
43. How many portfolio companies did you engage directly/were engaged on your behalf on ESG issues in 2007?
 
Extensive engagement
Moderate engagement
Basic engagement
Environmental21100
Social000
Governance0990
44. What RI/ESG-related issues were addressed in your shareowner engagement initiatives? Please check all that apply.Activities in conflict zones,Benefits and compensation,Bribery/corruption,Climate change,Distribution of fair trade products,Environment,Governance,HIV/AIDS,Health,Health and safety,Human rights,Labour issues,Nanotechnology / novel technology
45. How were RI/ESG issue-related engagement targets and topics identified? Please check all that apply.Client directive,Sector exposure,Risk profile,Focus issue,Ad hoc/reactive,NGO or union campaign
46. Do you set RI/ESG issue-related engagement objectives and attempt to evaluate success?To a large extent
47. Have you sought evidence relating to the effectiveness of your active ownership strategy? Please check all that apply.Governance practices changed,(Written) commitment to improve a particular ESG issue,Improved disclosure,Collaborative work with a company on a specific ESG issue,Other evidence of improvement in investee company RI/ESG performance due to our activities,Other (please specify): 'Engagement is only one of a wide variety of impacts on share price performance. Given the range of such influences share price is an unreliable stand alone measure. Instead we focus on direct and observable changes in company behaviour following a request for change.'
48. What was your most significant achievement in 2007 in relation to your implementation of Principle 2?Enter text response here.
49. What was your biggest barrier in 2007 with relation to your implementation of Principle 2?Enter text response here.
50. Please add any overall comments and clarifications related to Principle 2 here.Enter text response here.
Principle 3
51. Have you asked that investee companies (or other investment entities) produce standardized reporting on their RI/ESG issue policies, practices or performance (within annual financial reports or other formats)?To a large extent
52. What format of standardized reporting on RI/ESG issue policies, practices or performance have you requested?Integrated with regular financial reports,Standalone corporate social responsibility or sustainability reporting,Carbon Disclosure Project (CDP),Other (please specify): 'Global Compact and in line with our policy'
53. Have you provided feedback to investee companies (or other investment entities) on their reporting on RI/ESG issues?To a large extent
54. Have you sought information from companies regarding their adoption of/adherence to norms, standards, codes of conduct or international initiatives related to RI/ESG issues?
AdoptionTo a large extent
AdherenceTo a large extent
55. Which norms, standards, codes of conduct or international initiatives related to RI/ESG issues have you sought information about from companies, with regard to their adoption of/adherence to?UN Global Compact,Equator Principles,International Labour Organization standards,OECD guidelines for multinational enterprises,World Economic Forum Principles for Countering Bribery,Universal Declaration of Human Rights,Other (please specify): 'EITI, The ILO Fundamental Principles and Rights at Work, Regarding standards, where appropriate, we also seek assurances that environmental management systems, and health and safety management systems are certified top the appropriate international standards.'
56. What was your most significant achievement in 2007 in relation to your implementation of Principle 3?placeholder
57. What was your biggest barrier in 2007 with relation to your implementation of Principle 3?A lack of generally recognised and utilised Key Performance Indicators.
58. Please add any overall comments and clarifications related to Principle 3 here.placeholder
Principle 4
59. Are you considering RI/ESG requirements when searching for and selecting the following?
External investment managerNot applicable
Investment consultantYes
Proxy votingYes
Engagement overlayYes
Investment researchYes
Internal operations (for example, purchasing, travel, office space etc.)No
60. Have you linked the following to performance on RI/ESG issues?
Investment monitoringNo
Incentive structure (internal investments)Yes
Incentive structure (external investments)Not applicable
Contractual relationships with external investment managersNot applicable
61. Are the default pension funds or retirement plans offered to your employees also signatories to the PRI?No
62. To what extent do you encourage your service providers to become PRI signatories?To a small extent
63. To what extent do you encourage your clients to become PRI signatories?To a moderate extent
64. To what extent do you encourage peer organisations to become PRI signatories?To a moderate extent
65. Do you have evidence that you have played a role in the improved integration of RI/ESG issues by external investment managers?No Answer
66. Does your broker evaluation process include an ESG component or do you have a budget to pay cash for ESG broker research?Yes
67. Have you revisited any relationships with service providers in light of RI/ESG issue-related capabilities?Yes
68. Have you engaged in dialogue, lobbying or initiatives pertaining to government policy and/or industry regulations (for example, stock exchanges, accounting standards) related to RI/ESG issues in 2007?To a large extent
69. What was your most significant achievement in 2007 in relation to your implementation of Principle 4?Enter text response here.
70. What was your biggest barrier in 2007 with relation to your implementation of Principle 4?Prioritising these initiative against others
71. Please add any overall comments and clarifications related to Principle 4 here.Care should be taken by the PRI to ensure to great an emphasis is not placed on Principle 4. Although important & useful we believe focus should remain on Principles 1, 2 & 3 .
Principle 5
72. Did you use the PRI Engagement Clearinghouse in 2007?Both used and posted to it
73. Did your use of the clearinghouse result in subsequent action or collaboration with other signatories?Yes
74. Please elaborate on how the PRI Engagement Clearinghouse could be made more useful:We welcome the considerable developments during the year in particular the increase in resources for facilitating collaboration. There is considerable scope for more resources here, and we would strongly support such change. Increase collaborative engagement on global corporate governance issues such as cross border voting, one share one vote & audit quality Continue steps towards quality control for the postings Discussion forum for non financial reporting, and the development of more standardised key performance indicators for company reporting; Promoting policies on various norms Arguably the Clearing House should also consider looking to publish its own public report of activities. Morley's Head of SRI Engagement is an active member of the PRI Engagement Working Group, and routinely feeds in development suggestions via this forum.
75. To what extent do you participate in the following RI/ESG issue-related collaborative engagement initiatives and/or industry associations? For those not listed, please use the "other" field:Carbon Disclosure Project,CFA Institute Centre for Financial Market Integrity,Extractive Industries Transparency Initiative (EITI),Institutional Investors Group on Climate Change (IIGCC),International Corporate Governance Network (ICGN),Marathon Club,Regional social investment organisation (for example SIF or UKSIF),Social Investment Research Analyst (SIRAN),United Nations Environmental Program Finance Initiative (UNEP FI),Other (please specify): ''
77. What was your most significant achievement in 2007 in relation to your implementation of Principle 5?Development of Global Compact Programme
78. What was your biggest barrier in 2007 with relation to your implementation of Principle 5?placeholder
79. Please add any overall comments and clarifications related to Principle 5 here.placeholder
Principle 6
80. Have you disclosed how RI/ESG issues are integrated into your investment processes?Yes - to clients or beneficiaries
81. Please indicated how this disclosure of how RI/ESG issues are integrated into your investment processes can be obtained (a URL would be sufficient):http://www.morleyfm.co.uk/products/social_responsible_investing/index.htm
82. To what extent do you disclose your annual (proxy) voting record?Disclose votes and guidance explaining votes
83. Please indicated how your (proxy) voting record can be obtained (a URL would be sufficient):http://www.morleylibrary.co.uk/index.php?se_id=88 We make our quarterly summary voting reports available on the Morley internet site in respect of the Morley aggregate voting (i.e we do not make available client specific reports but we do publish our voting levels and directions on an aggregated basis).
84. Do you systematically report (privately and/or publicly) on your RI/ESG issue-related engagement activities, results and progress?To a large extent
85. Please indicate how your reporting on RI/ESG issue-related engagement activities, results and progress can be obtained (if it is publicly available, a URL would be sufficient):Not publicly available. Section in quarterly client reports.
86. Did you communicate on RI/ESG issues and the PRI to beneficiaries or plan participants in 2007?
87. Please indicate how your communication on RI/ESG issues and the PRI to beneficiaries or plan participants can be obtained (if it is publicly available, a URL would be sufficient):
88. Are you undertaking any additional efforts to raise awareness of the PRI and RI/ESG issues amongst stakeholders?To a large extent
89. What evidence do you have of the impact on external investment manager practices? Please check those that apply.No Answer
90. Have you sought to determine what impact your overall RI/ESG issue-related efforts (voting and engagement, investment decision making, disclosure, etc.) have had on corporate behavior or performance?To a large extent
91. Have you sought to determine what impact your RI/ESG issue-related approach has had on the performance of your portfolio?To a small extent
92. Have you sought to determine what impact your RI/ESG issue-related efforts, requests and guidance have had on the consideration of RI/ESG issues by your external service providers excluding external investment managers (for example: research providers, consultants, etc.)?To a moderate extent
93. Do you report on progress and/or achievements relating to the PRI or RI, and how would you like to publish your response to this assessment?We will send a URL to the PRI Secretariat which will link to the responsible investment section of our website (which will include your partial response to this reporting and assessment tool)
94. What was your most significant achievement in 2007 in relation to your implementation of Principle 6?Fair Pension: #2 of top 20 UK asset managers.
95. What was your biggest barrier in 2007 with relation to your implementation of Principle 6?Balancing the public interest with client confidentiality
96. Please add any overall comments and clarifications related to Principle 6 here.placeholder
Emerging Markets
97. To what extent have you actively thought about how to integrate RI/ESG issues within investment decision making and ownership practices with regards to emerging markets investments?To a moderate extent
98. Please describe your activities with regards to integrating RI/ESG issues within investment decision making and ownership practices with regards to emerging markets investments.
99. To what extent do you believe the integration of ESG issues in emerging markets is as relevant as the integration of ESG issues in other markets?To a greater extent
100. To what extent did you employ the following approaches in your 2007 active ownership strategy in emerging markets?
(Proxy) votingTo a small extent
Direct engagement conducted privatelyTo a small extent
Direct engagement conducted publiclyTo a small extent
Collaborative engagementTo a small extent
Filing shareholder resolutionsNot at all
Co-filing shareholder resolutionsNot at all
Other (Please specify): placeholder Not at all
placeholder
101. To what extent have you developed a comprehensive RI/ESG engagement capability regarding business activities in emerging markets?To a moderate extent
102. Please list the three most often addressed RI/ESG-related issues in your shareholder engagement initiatives in emerging markets?
1.Governance & ownership
2.Global Compact
3.CSR Reporting
103. Have you sought information from companies regarding their adoption of/adherence to norms, standards, codes of conduct or international initiatives related to RI/ESG issues in emerging markets?
AdoptionTo a moderate extent
AdherenceTo a moderate extent
104. Do you take RI/ESG considerations into account when selecting and approving emerging markets external investment managers?No Answer
105. Do your consultants factor RI/ESG issues into their short listing of emerging markets external investment managers?No Answer
106. Do you have evidence that you have played a role in the improved integration of RI/ESG issues by external investment managers investing in emerging markets?No Answer
107. To what extent have you worked together with other investors to improve the effectiveness of implementing the PRI in emerging markets?To a moderate extent
108. Are you undertaking any additional efforts to raise awareness of RI/ESG issues in emerging markets?To a large extent
109. Have you sought to determine what impact your RI/ESG issue-related efforts (voting and engagement, investment decision making, disclosure, etc.) have had on corporate behaviour or performance in emerging markets?To a small extent
110. Please add any overall comments and clarifications related to the PRI in emerging markets here.
111. What is your top PRI-related goal/priority for emerging markets in 2008?
Closing Comments
112. Why did your organisation join the PRI?Historically, Investor efforts have been weakened by the absence of an overarching global framework of institutional action. Morley Fund Management supported the Principles because they provide investors with this framework, and with it, the legitimacy and credibility offered by the UN for investor efforts in this area. The principles also offered us an opportunity to showcase our efforts to help promote high standards of corporate governance and corporate responsibility.
113. Please describe the benefits you have enjoyed as a result of signing the PRI:The most important practical benefit that we have gained through signing up to the UN PRI is the Clearing House, which has been incredibly useful tool. The collaborative engagement on the UN Global Compact involved working very closely with the Clearing House in both the development and the coordination of twenty investors representing approximately US$2.13 trillion in assets. The Clearing House were able to help garner collaborative support for the initiative, track which signatories wanted to sign which letters, and help to keep all the group participants in touch with developments. More generally, we have welcomed the opportunity to develop our ideas in conjunction with other signatories at UN PRI events. Finally, there is no doubt that the convening ability of the UN has created a step change in the credibility of and demand for sustainable and responsible investment.
114. To what extent do you believe the PRI has succeeded in changing investor behaviour and/or raising awareness or capacity on RI/ESG issues? Do you have any examples you could share?A dramatic increase in public interest. Significant increase in global investor collaboration. More questions on these issues from clients that are signatories.
115. 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.We would like to see much more UN outreach beyond UNEP and the Global Compact to other key UN agencies that have a bearing on the policy framework for multinational enterprises, including ILO, WHO, UNDP & OHCHR. There is significant policy expertise in this area, which could be harnessed to promote enhanced corporate ESG performance in very interesting ways.
2.pleaceholder
3.placeholder
116. What are your top three PRI-related goals/priorities for 2008?
1.To continue to develop thematic research around sustainable investment themes
2.To continue to encourage managers of all of Morley s funds to incorporate ESG issues into investment decisions.
3.To further improve both the measurement of the effectiveness of our engagement programmes and the communication of our engagement activity.
117. Please rank the six principles from most difficult to implement to least difficult to implement:
Most difficult
1
Principle 1
2Principle 2
3Principle 3
4Principle 4
5Principle 6
Least difficult
6
Principle 5