Responsible Investment Policy

Responsible Investment is an approach to investing which considers a range of behavioural factors in addition to financial factors used in investment decision making. These factors typically cover a wide range of Environmental, Social and Governance (ESG) issues.
The Investment Manager, from a responsible investment perspective and in recognition of the beliefs and sensitivities of some investors, has determined that the following guidelines will be adhered to:
The Investment Manager will avoid investments that have primary and significant involvement in adult entertainment, alcohol, gambling, pork products, tobacco, or weapons.

Interpretation for Transparency

For the avoidance of doubt, the Investment Manager considers that the following are not inconsistent with these guidelines:

Long or short positions in broad equity market index derivatives e.g. US S&P 500, where it is recognised that direct investment in certain constituents of the index would be avoided.
Long or short positions in commodities (agricultural, energy, metals), except alcohol, pork, and tobacco products.
Long or short positions in currencies.
Bonds and loans paying interest, or instruments e.g. Exchange Traded Products which are based on such bonds or loans.
Property investment is subject to tenant screening to ensure that their businesses are not inconsistent with the guidelines.


Products managed by external specialist investment managers may be long or short investments where direct investment would be avoided.
Properties that are owned partially, and not controlled, could accept a new tenant in a business where direct investment would be avoided.
On balance, the advantages of allocation to external managers and investment in part-owned properties are deemed to out-weigh the potential for modest second-order exposures where direct investment would be avoided.