Exclusion policy

We define ourselves as long-term, quality-focused investors. Binding all of our investment decisions is a commitment that we will not pursue risk-adjusted returns to the extent that our actions will knowingly harm others. This means that there are certain people we would not invest with and some businesses that we would not own. In particular, this includes people with histories of corporate misdemeanours or businesses materially exposed to harmful products and services.

A key part of our approach to responsible investment incudes commitments to:

  • Support and uphold the fundamental principles of human rights;
  • Support international norms and standards enshrined in widely adopted treaties, conventions and codes of practice; and
  • Uphold the highest standards of environmental stewardship

Our determination of whether to invest is based on a holistic view of a company’s quality. This includes the businesses’ social license to operate, weighing if their business model and their products or services are fundamentally purposeful to society. We also consider if the consumption of one unit of the product or use of the service provided by the business can be deemed harmful to human health or society. Effectively, this rules out two areas entirely, including companies that manufacture certain types of controversial weapons1 (anti-personnel mines, cluster weapons, biological and chemical weapons, depleted uranium, nuclear weapons and white phosphorus munitions), and companies whose primary business is the manufacture of cigarettes or tobacco products2.

Apart from these two hard exclusions, there are countless grey areas where our clients expect further clarity on what exposure we might permit. This is a delicate topic and one we discuss at length among the team. Tobacco, defence, and gambling are easy sectors to exclude, but a blanket exclusion on fossil fuels is harder to validate, especially where a company might play an important role in the transition to renewable energy.

Over and above these exclusions, we assess the quality of management and their means of addressing environmental, social and governance (ESG) issues. In our research, we look for evidence that the management operates the business effectively and in the interests of all stakeholders – both now and for the longer term. We believe that companies that do not look after their customers, employees, suppliers, and the larger community are unlikely to be rewarding long-term investments.

For companies that do not meet our quality criteria, there is no obligation for us to invest in them. This same consideration applies for companies we own but where the quality has deteriorated over time. We monitor companies and engage with management teams on a regular basis to evaluate whether their direction of travel on ESG matters remains positive. 

Environmental issues

Climate change

We will not invest in companies that we believe do not take their environmental impact seriously, as determined through our engagement with management and the monitoring of targets on an ongoing basis. Companies that do not make progress will be excluded.


We do not invest in companies with direct exposure to coal mining or processing where it is a key part of the business. We impose a 10% revenue threshold measured on a rolling three-year average. 

Deforestation and biodiversity

We expect companies that source or use palm oil to adhere to the policies of the Roundtable on Sustainable Palm Oil (RSPO) and No Deforestation, No Peat, No Exploitation (NDPE). In particular, we strongly encourage consumer companies to adhere to these policies and consider aspects of their operations for alignment to these policies. We will divest in companies that do not prioritise or willfully neglect the preservation of forests and biodiversity. 

Social issues


We do not invest in companies involved in the production of tobacco products. As an extension of our responsibility, we will continue to encourage the ceasing of tobacco industry relations in our banking exposure.  


We do not invest in companies whose primary business is gambling. We impose a 10% revenue threshold calculated on a three-year rolling average. 


We do not invest in companies involved in the production or development of cluster munitions, anti-personnel mines, small arms, biological weapons, chemical weapons or uranium munitions.


We do not invest in companies involved in the production or distribution of pornography.

Governance issues


We do not invest in companies where systemic bribery is believed to be taking place. We expect companies to adhere to Principle 10 of the UN Global Compact.


We believe all companies should adhere to local tax legislation in both the letter and the spirit of those laws. Those that do not are likely to face a regulatory or consumer backlash, or both. We will not invest in companies that persistently flout local tax legislation. 

1 This includes all companies that manufacture controversial weapons and entities that own more than 50% of controversial weapons manufacturers, with an effective 0% revenue threshold. This does not extend to minority investments, where a parent company owns less than 50% of a company.

2 This includes all companies that are involved in the production of tobacco and tobacco-based products, with an effective 0% revenue threshold. This does not extend to minority investments, where a parent company owns less than 50% of a company.