
Exclusion policy
A key part of our approach to responsible investment incudes commitments to:
Below are a number of industries that we either exclude in their entirety or where we apply thresholds. Applying thresholds affords us the opportunity to engage with the company on parts of their business that are less sustainable than others.
We are finding that there are countless grey areas where our clients expect further clarity on what exposure we might permit. This is a delicate topic and one the team discusses at length regularly.
Tobacco, defence and gambling were relatively easy for us to exclude but areas such as fossil fuels we find more challenging, where a company might be playing an important role in transitioning to renewable energy. Over the years our views have hardened and we fully expect this to be the case in the future and therefore we will continue to develop our process around some of these grey areas.

Environmental issues
Climate change
We will not invest in companies that do not take their environmental impact seriously, and those that we believe do take them seriously, we monitor their progress on an ongoing basis. Companies that do not make progress will be excluded.
Coal
We do not invest in companies with a materially large exposure to coal mining and impose a 10% revenue threshold.
Deforestation and biodiversity
We expect palm oil companies to adhere to the policies of the Roundtable on Sustainable Palm Oil (RSPO) and No Deforestation, No Peat, No Exploitation (NDPE). In addition, we strongly encourage our consumer companies to adhere to these policies and if our engagement is unsuccessful we will sell our holding.
Nuclear energy
We do not invest in companies that derive revenue from the production of nuclear energy.

Social issues
Gambling
We do not invest in companies whose primary business is gambling. We impose a 10% revenue threshold.
Weapons
We do not invest in companies that are involved in the production or development of cluster munitions, anti-personnel mines, small arms, biological weapons, chemical weapons or uranium munitions.
Pornography
We do not invest in companies involved in the production of pornography.
Tobacco
We do not invest in companies that are involved in the production of tobacco products. We are engaged with our banking exposure to encourage them to cease doing business with the tobacco industry.

Governance issues
Bribery
We do not invest in companies where there is believed to be systemic bribery. At a minimum, we expect companies to adhere to Principle 10 of the UN Global Compact.
Tax
We believe that all companies should adhere to local taxes legislation in both the letter and the spirit of those laws. Those that do not are likely to face either a regulatory or a consumer backlash or both. We will not invest in companies that persistently do not adhere to local tax legislation.