The connection between investors and policymakers is not working as it should if the recovery is to be sustainable and inclusive with concrete reforms. As policymakers consider policy interventions to support the recovery, investors should be engaging policymakers by providing technical expertise and allocating capital to sustainable investments. This report identifies indicative policy options, which PRI will root in our ESG and climate programmes.
As communities and businesses around the world grapple with the ramifications of the COVID-19 pandemic, we owe it to our clients and beneficiaries to recover better, which means creating a recovery that is sustainable, inclusive and delivers concrete reforms. For responsible investors, that means they need to raise their games on policy engagement.
A recent Oxford Smith School paper concluded that “progress on climate change will depend significantly on policy choices in the coming 6 months”.1 Critically, “the right choices could drive a long-term downward trend in greenhouse gas emissions”. The PRI agrees with these sentiments. However, there is a significant task at hand to turn ambition into reality. Research for this report finds that investors significantly underestimate the positive role that the responsible investment industry can play in encouraging policy change. Alongside climate-related issues, there is an imperative to recover in a way that enables a more just and fair society. UN Secretary General, António Guterres said in April that, “People — and their rights — must be front and centre”.2 This applies to states, companies and investors. Respect for, and enforcement of, human rights are a precondition of a fairer, more inclusive and resilient future.
This report presents a series of recommendations for investor policy engagement and indicative proposals for action. The PRI intends to develop these proposals over the months ahead, informed by our programmes across environmental, social and governance issues, our signatories’ sustainability objectives, and our implementation objectives.
Our recommendations are based on a seven-part framework that should support investors in pursuing their policy objectives:
- Undertake policy engagement, aligning your engagement and investment objectives.
- Work to policymakers’ timetables, not your own.
- Leverage arguments based on technical expertise.
- Engage at all levels of the policy process, as well as through the media.
- As far as possible, work together and speak with a coherent voice, especially where there is consensus.
- Better understand the relevant dynamics of policy decision-making across committees and groups.
- Be clear about who you represent and how policies impact your investor base.
Responsible investors need to send the right messages, to the right people, at the right time, and in the right way. That means undertaking detailed stakeholder mapping to assess who makes decisions and who has the influence to accelerate change – in short, backing up statements with actions that will encourage policy implementation.
This report sets out three themes as a starting point for PRI signatories in their policy engagement in the post-COVID-19 period:
- The case for a sustainable recovery is overwhelming – but requires concerted investor action. International coordination and cooperation will be essential ingredients of a successful recovery. Policymakers need to move decisively to put in place policies and funding to support an acceleration in investment where solutions are at hand, and to invest in getting more solutions to market and at scale. Implementation will be key, and investors have a major role to play, working with governments and other stakeholders to design policies that are transparent, effective and aligned with sustainability goals.
- Climate policy fundamentals are unchanged – but there is opportunity to accelerate policy commitments, and ensure they are inclusive. As the United Nations Framework Convention on Climate Change (UNFCCC) has stated, the COVID-19 pandemic has put many aspects of our economy and lives on hold, but it has not stopped the climate emergency and will not prevent the risks from extreme weather events and other climate-related shocks that threaten us now and in future. Policy makers need to seize the opportunities created by shifts in markets and behaviour to accelerate change, focusing on areas in which the COVID-19 recovery and decarbonisation priorities are best aligned. In order to create a decisive green transition, targeted government stimulus spending must be backed up by accelerated measures to build markets that can deliver for people and the planet.
- Investors and companies will likely be subject to a heightened degree of scrutiny. They should contribute in ways that are effective and fair. The pandemic has brought the multiple dimensions of poverty and vulnerability experienced by millions of people into sharp focus. For these people, decades of economic growth and development have not delivered prosperity and security. COVID-19 has exacerbated those vulnerabilities, created new ones and reduced people’s ability to cope with shocks.3 To maintain public support and deliver a sustainable, equitable, inclusive and resilient recovery, governments, investors and companies should contribute in ways that are (and are seen to be) both effective and fair.
With these themes in mind, redefining corporate purpose should be at the top of decision makers’ agendas. We need a step change in the role that the responsible investment industry can play in achieving sustainable development objectives through policy change. We see opportunities for investors to make a difference in tax reform, executive pay and accountability, human rights in the companies in which they invest (and their supply chains), as well as in ensuring that capital markets operate in the interests of all stakeholders. By focusing on these, based on the recommendations set out in the seven-part policy engagement framework, we hope the investment community can step up in the post-COVID-19 environment and help create a fairer and more sustainable financial system.
Policy engagement in recovery – a seven part framework
Action 1: Undertake policy engagement, aligning your engagement and investment objectives. Public policy critically impacts the sustainability and stability of financial markets, as well as social, environmental and economic systems. Engagement is therefore a natural and necessary extension of investors’ responsibilities. In recent years, there has been a dramatic increase in the attention paid by policymakers to sustainability issues– including sustainable finance.4 In some regions, and particularly the EU, policymakers have articulated a vision for sustainable finance that encompasses not just risks to the financial system, but the role the financial system has to play in financing the real economy.5 Investors – and investor associations – will be key enablers of this change, helping demystify the policymaking process, offering investment expertise and experience, and working collaboratively to marshal disparate voices behind shared goals.
Action 2: Work to policymakers’ timetables, not your own. The policymaking process tends to play out in fits and spurts. Periods of intense reform, often seen during a crisis, may be followed by years of calm and consolidation. Thus, the window for change closes fast, and perhaps now, in an age of social media, faster than ever. In response, investors must engage with policymakers on political timelines rather than their own.
The COVID-19 crisis has highlighted stark inequities in our economic system, leading some policymakers to focus on how financial markets can become more sustainable and inclusive. Now is the moment for investors to engage, offering ideas (including those that may have been written off in the past) that reflect the priorities of the moment, before the debate fades and the bandwagon moves on.
Similarly, raising issues at the beginning of a new administration or head of state’s term in office may help shape the agenda for the rest of that term, rather than waiting until later when other priorities may have taken precedence.
Action 3: Leverage arguments based on technical expertise. Investors habitually leverage sophisticated data analysis for their day-to-day work and should use this evidence-based approach to engage policymakers and highlight the benefits or otherwise of specific proposals. In the US, the Administrative Procedure Act requires that rules have a solid evidentiary basis.6 Moreover, there is often a statutory obligation to analyse costs and benefits. At time of writing, there are multiple
European Commission-led consultations on a range of sustainability-related topics.7 Indeed, there is a manifest opportunity to act in multiple jurisdictions around the world.
Policymaker resources are often stretched thin, limiting their ability to conduct in-depth analysis. If investors can help regulators understand the potential impact of proposals, providing quantitative evidence and relevant technical expertise, they should do so.
Action 4: Engage at all levels of the policy process, as well as through the media. Legislative and regulatory processes are part of a larger political and policy ecosystem. This has implications for investors, which should engage at multiple branches of government. For example, if investors are concerned about a rule being written by a regulator, they should notify the regulator as well as policymakers responsible for oversight. In addition, when engaging with the legislature or regulators, it is important to try to shape the public debate. Investors should consider media engagement and collaboration with academic researchers as part of their advocacy. It will also be valuable to develop relationships with reporters, so that you can serve as a source of expertise and analysis for their stories.
Action 5: As much as possible, work together and speak with a coherent voice, especially where there is consensus. Policymakers are generally hard-pressed for resources and can struggle to collect the full range of opinions in the markets they regulate. With that in mind, investors can make a powerful and effective case where there is strong consensus. The fact of consensus will show policymakers that a policy change is likely to be welcomed. While achieving a consensus can be challenging, early collaboration between signatories, trade associations and trade bodies can facilitate positive engagement. For all investors, but particularly smaller investors, joining together can be an important way to amplify their voices and communicate a coherent message.
Action 6: Better understand the relevant dynamics of policy decision-making across committees and groups. It is important for investors to understand which legislative committees and regulators have jurisdiction – and therefore expertise – over the issues they care about. For example, policymaking in the US begins with congressional committees. The Senate Banking Committee and House Financial Services Committee have jurisdiction over the investment management industry and relevant financial regulators. 8 9 When an issue deserves more attention, these committees hold hearings, which can eventually form the basis for legislation. The fragmented nature of the regulatory system in the US means no single financial regulator is responsible for everything. Therefore, if an investor is concerned about issuer ESG disclosure, for example, it should work with the SEC.10 If it is focused on a bank’s financing of fossil fuel companies, it should raise its concerns with banking regulators such as the Federal Reserve.11
Action 7: Be clear about who you represent and how policies impact your investor base. When engaging, it is important to state who you represent in terms of your investor base and be as specific as possible about how a law will impact your stakeholders. This could be as simple as concisely describing, at the beginning of any engagement with elected representatives or regulators, your organisation, your total assets under management, and your end investors.
Climate-related policy tools and priorities
Establishing standards, benchmarks and tools for measuring and managing climate-related commitments, risks and outcomes.
Key policymakers: central banks, financial regulators, standards setters
Risk disclosure and management
Outcomes/Impact disclosure and management
Sustainable Taxonomies (e.g. EU Taxonomy) to enable spending and investment decisions to be aligned with climate and sustainability outcomes.
Sector priorities and stimulus focus
Policy action and stimulus spending targeted at priority sector transformations to reach net-zero emissions by 2050; focusing in the short term on areas with the highest job creation and economic multipliers.
Key policymakers: governments, central banks
Coordination and cooperation
Policy priorities for purpose, fairness and human rights
Redefining corporate purpose
Fairness rooted in human rights, decent work and just transition
Capital market functions and behaviour
- PDF, Size 0.87 mb
1 Hepburn, C., O’Callaghan, B., Stern, N., Stiglitz, J. and Zenghelis, D., 2020. Will COVID-19 fiscal recovery packages accelerate or retard progress on climate change?. Oxford Review of Economic Policy, 36
2 We are all in this Together: Human Rights and COVID-19 Response and Recovery, United Nations, April 2020
3 Ahmed, F., Ahmed, N.E., Pissarides, C. and Stiglitz, J., 2020. Why inequality could spread COVID-19. The Lancet Public Health, 5(5), p.e240
4 Responsible investment regulation map
5 EU Sustainable Action Plan
6 Administrative Procedure Act: Public Law 404
7 European Commission: Consultations
8 US Senate Committee on Banking, Housing, and Urban Affairs
9 US House Committee on Financial Services
10 US Securities and Exchange Commission
11 Federal Reserve Board