In 2018, the PRI implemented minimum requirements for PRI membership for investors. Existing and future asset owner and investment manager signatories who fail to meet these requirements over a two-year period, following extensive engagement with the PRI, will be delisted.

The minimum requirements

These are the three minimum requirements existing and future asset owner and investment manager signatories must meet:

Minimum requirementStrategy and Governance (SG) 2020 module indicatorInvestment & Stewardship Policy (ISP) 2021 module indicator
RI policy, setting out:
  • overall approach or guidelines on E, S, or G factors, and
  • covers >50% of AUM
SG 01 ISP 1
ISP 1.1
ISP 3
Senior-level oversight of RI SG 07 ISP 6
Internal/external staff implementing RI SG 07 ISP 7

Why these requirements were introduced

The PRI’s consultation on strengthening signatory accountability in September 2017 showed strong signatory support for using reporting and assessment data to delist signatories whose progress in implementing the Principles is not sufficient. View an overview of the consultation responses.

The increased accountability of the PRI as an organisation is one of the focus areas of our 10-year Blueprint for responsible investment

When signatories do not meet these requirements

The PRI has committed to extensively engage with signatories identified as not meeting the minimum requirements, and to provide them with the support needed to implement necessary changes to meet them within a two-year engagement period. Signatories that do not meet the criteria based on their PRI reporting will be informed privately and delisting will only be as a last resort following unsuccessful engagement over the two-year period.

Delisting process

Signatory Accountability Rules 

The Signatory Accountability Rules support the integrity of the PRI membership by setting out measures for minimum requirements. The purpose of the rules is to inform signatories of the minimum requirement criteria and the formal process for engagement and, as a last resort, delisting. The rules were approved by the board in December 2017. 

2020 minimum requirements review

The current requirements are the first implemented by the PRI to increase accountability of our signatories. To ensure they remain fit for purpose, where practices are improving and evolving, we have committed to gradually strengthening the minimum requirements for signatories over time. We are reviewing both the current minimum requirements and the process, with the aim of announcing the strengthened minimum requirements in April 2021 and implementing these in the 2022 Reporting Framework.

1. A shorter timeline, of one year engagement, before delisting 

From the announcement in April 2021, signatories would have until the reporting cycle in 2023 to implement necessary changes to meet the minimum requirements, equivalent to two reporting opportunities. Support would be provided during the one-year engagement period. 

Current timeline

Current timeline

 

Proposed timeline

Proposed timeline

2. Increased minimum requirements 

We propose to increase the current minimum requirements, see below left, to further increase accountability of our signatory base. Potential increased or additional requirements are presented below to the right.

Current and new requirements

Signatories are encouraged to provide feedback on the proposed changes to the minimum requirements, as part of the signatory consultation on PRI’s next 3-year strategy. The strengthened minimum requirements will be approved by the PRI Board and announced in April 2021.

Frequently asked questions 

Who the requirements apply to

Do the requirements apply to all signatories?

The requirements apply to asset owner and investment manager signatories only. Service provider signatories reported for the first time on a mandatory basis in 2018 – another important step forwards for the PRI’s accountability.

I am reporting voluntarily – do the requirements apply to me?

Signatories that complete their reporting during the first voluntary cycle and do not meet the minimum requirements of membership will be identified and informed. However, they will be given an additional year to meet the requirements, the equivalent to two mandatory reporting cycles.

Understanding the requirements

Why has the PRI introduced accountability measures?

In 2016, the PRI conducted an extensive stakeholder consultation on accountability and recognising diversity. It showed a strong endorsement of the PRI’s ambition to increase transparency, accountability and leadership among its signatories.

The Blueprint for responsible investment lays out the PRI’s ambitions and goals for the 10 years ahead; strengthening accountability and showcasing leadership are at its core.

What are the aims of the minimum requirements initiative?

The main objectives are:

  • engaging signatories that have been failing to implement the Principles;
  • delisting, as a last resort, signatories who are not committed to the Principles;
  • helping signatories committed to the Principles but not highly engaged with the PRI.

How have signatories been involved in developing the measures?

In 2016, we received five hundred signatory responses to our consultation on accountability and recognising diversity. We then conducted a more detailed consultation on minimum requirements and showcasing leadership between August and October 2017 and held an interactive workshop at PRI In Person in Berlin to enable signatory input. In total, the PRI received input from over three hundred different organisations.

Why were these three minimum requirements chosen?

These requirements and indicators were selected because they are applicable to all types of signatories. Feedback also indicated that these were achievable within the two-year engagement period and an appropriate place to start for newer and less advanced signatories. The process is intended to help signatories progress through use of PRI resources and network.

Why will signatories have two years to meet the requirements?

Following consultation, a two-year engagement period felt an appropriate time for signatories to implement the requirements and have sufficient opportunity to meet them. As signatories do not have to report in their first year, this will mean that organisations will have been signatories for a minimum of three years before they have to meet the requirements.

Meeting the minimum requirements

How will the PRI support signatories who do not meet the requirements?

The PRI will confidentially inform all signatories that do not meet the requirements. Following this, an engagement plan will be agreed for the two-year period and signatories will be supported through the process with the appropriate resources.

How can I meet the first minimum requirement – Investment policy that covers the firm’s RI approach (ISP 1, ISP 1.1 and ISP 3)?

To meet the policy requirement, signatories must have an RI policy setting out the firm’s overall approach and/or formalised guidelines on E, S and G factors. The policy must cover more than 50% of AUM. Information on how we define an RI policy will be available in the explanatory notes of the indicators in the 2021 Reporting Framework (until the launch, this information can be found in the explanatory notes of the Strategy & Governance module in the 2020 Reporting Framework) . Guidance on how to draft RI policies and a list of publicly available ones can be found at the following links:

How can I meet the second minimum requirement – Oversight of RI implementation (ISP 6)?

To meet the oversight requirement, signatories must have senior-level oversight and accountability for RI implementation. Individuals with oversight roles are those with management or governance responsibility for ensuring that the organisation implements its policies and achieves its objectives and targets in relation to RI performance. “Senior level” includes the roles: chief level staff, head of department, CEO, CIO, investment committee and board members or trustees.

How can I meet the third minimum requirement – RI implementation (ISP 7)?

To meet the implementation requirement, signatories must have staff implementing RI in their organisations – for example, through conducting ESG-related research, incorporating ESG issues into investment strategies and voting shareholdings, and engaging with companies and policy makers. This role can be covered by internal or external staff, does not have to be dedicated RI/ESG investment staff; and the person responsible does not have to allocate the majority of their time to RI/ESG activities

Does our RI policy have to be publicly available?

The first minimum requirement states that signatories must have an RI policy in place, but it does not require it to be publicly available. Nonetheless, many PRI signatories choose to disclose their RI policies.

Will the PRI publish a list of signatories that do not meet the requirements?

The PRI does not name the signatories that do not meet the minimum requirements during the two-year confidential engagement period. Signatories that are delisted at the end of the engagement period will be publicly disclosed on our website following board approval. It should be noted that the minimum requirements are based on responses to indicators that are made public as part of an organisation’s Transparency Report.

Will I be delisted if I do not meet the requirements?

Delisting will be a last resort if the two-year engagement period is unsuccessful and if there are deemed no extenuating circumstances. Signatories will be able to appeal the delisting decision.

Can I be relisted after not meeting the minimum requirements?

Signatories that have been delisted and wish to relist will be required to wait one calendar year and then provide evidence that they meet the minimum requirements in place at that time. The grace year will not apply to relisting signatories. These signatories will be required to report in the next reporting cycle.

What happens if I revert to not meeting the minimum requirements?

Signatories that revert to not meeting the minimum requirements (including after any relisting) will be required to address the requirements in a one-year timeline. If the requirements have changed in the interim period, the usual two-year period will apply.