December 2021

1. Introduction and Business Principles

This policy sets out Coupland Cardiff Asset Management LLP (“CCAM” or the “Firm”)’s commitment and approach to integrating Environmental, Social and Governance (“ESG”) factors into the investment process as well as across the culture and operations of the firm.

2. ESG Oversight and Responsibilities

CCAM’s ESG culture has been developed by its senior management and the partnership, who maintain oversight and accountability of CCAM’s approach to ESG. CCAM’s members consist of senior individuals representing a range of business areas:

  • Chief Investment Officer - Asia
  • Chief Investment Officer - Japan
  • Chief Executive Officer
  • Chief Operating Officer
  • Fund Manager – India
  • Fund Manager - Japan

CCAM’s General Counsel / Chief Compliance Officer is also in attendance for partnership meetings.

The Partnership meets monthly and is responsible for the following aspects of ESG at CCAM: 

  • Formal responsibility for CCAM’s ESG strategy, and for implementing ESG initiatives at a firm and fund level.
  • Oversight of ESG integration within the investment process, including:
    • Evaluation of ESG factors in the research process by the investment team.
    • Oversight of engagement activities with portfolio companies.
    • Oversight of proxy voting (specifically votes against or abstentions).
    • Oversight of exclusion list.
    • Acting as a point of escalation for ESG investment decisions.
  • Annual assessment of internal responsible investment capabilities and training requirements.
  • Annual suitability assessment and development of the overall ESG integration framework.
  • Setting of ESG goals and objectives and ensuring they are met.
  • Where opportunities present, representation of CCAM on ESG industry bodies and working groups.
  • Arrangement of ESG training and education across the firm.
  • Remaining up to date on latest ESG trends and developments, regulatory requirements and investor preferences.
  • Communication of ESG initiatives to CCAM’s stakeholders.
  • Diversity and Inclusion – responsibility for considering appropriate action and shaping CCAM’s strategy and progress on diversity and inclusion matters.
  • Oversight of philanthropic initiatives including opportunities for external engagement with local communities, volunteering or charitable donations at a firm level.
  • Oversight of environmental initiatives at a firm level.

All members and employees of CCAM are required to conduct their duties in a responsible manner and in accordance with the following objectives:

  • To aim to grow the assets under our management for the benefit of the Firm’s clients
  • To act as a responsible steward of our clients’ capital
  • To integrate Environmental, Social and Governance considerations into the investment decision making process in a cohesive and considered manner in line with the 6 Principles of Responsible Investment (
  • To provide transparency to our clients where requested

3. ESG Integration Approach

This ESG Policy covers the approach to responsible investing for all assets under management of CCAM.

CCAM is an asset management company that specialises in the management of Asian and Japanese equity portfolios. The primary aim of CCAM is to protect and grow the real value of its clients’ capital over the long term. CCAM’s investment philosophy emphasises fundamental and proprietary research to identify sustainable companies, supported, where possible, by direct engagement conducted by its own experienced Asian and Japanese teams.

We believe that environmental, social, and governance (ESG) related issues can affect both the performance and sustainability of an investment portfolio and that ESG factors can be potential indicators of management quality and operational performance; companies with strong, sustainable profiles will, we believe, have greater potential to grow and survive in all market conditions. The primary objective of incorporating ESG factors into investment analysis and decisions is to manage potential risks and opportunities which may have a financial impact and maximise returns.

CCAM has a structured yet flexible approach to incorporating ESG into the investment process. Our fundamental, hands-on research approach allows us to seamlessly integrate our responsible investing efforts alongside with our investment strategies in an effective manner, which we believe will achieve the best long term outcomes for our clients.

CCAM uses the PRI’s definition of environmental, social and governance issues that are identified or assessed in responsible investment processes:

  • Environmental factors are issues relating to the quality and functioning of the natural environment and natural systems.
  • Social factors are issues relating to the rights, well-being and interests of people and communities.
  • Governance factors are issues relating to the governance of companies and other investee entities.

Using both ESG screening and integration techniques, the investment team seeks to consider how ESG risks and opportunities may have a financial impact on investment opportunities.

This aligns with the overall investment objective of the funds that CCAM manages as well as our objective to maximise returns for clients. In addition, considering ESG factors helps CCAM to develop a deeper understanding of sustainability issues and potentially reduces detrimental sustainability outcomes.

3.1  Negative Exclusion List (Screening)

We do not exclude any particular investment or industry based on standardised ESG factors, ESG indices or a “one size fits all” approach. We invest in multiple countries (many developing), and our assessment will take into account ESG best practice whilst acknowledging sector and individual company differences due to local laws and regulations, cultural differences and stage of national integration of ESG when making investment decisions.

However, we also believe that it is considered better practice to extend negative exclusions beyond legal requirements (such as those required by domestic/international law, bans, treaties or embargoes). In addition to observing legally required exclusions, CCAM avoids investments in companies that manufacture controversial weapons such as biological and chemical weapons, cluster bombs, anti-personnel mines or nuclear weapons.

The exclusion list is implemented as a pre-trade compliance check which prevents trades in excluded names.

3.2  ESG Research Process

CCAM is a fundamentally research-driven investment house with a focus on investing in stocks for an average holding period of 3-5 years.The product range offers Long Only strategies to investors around the world, with strategies focused on large, mid and small caps, in both Asia and Japan. We also offer a specialist Japanese equity closed ended income product and an Asian consumer focussed fund.

Environmental Social and Governance factors are integrated into the firm’s bottom up investment process and these issues are considered alongside financial and strategic issues during assessment and engagement with companies. ESG risks are qualitative factors rather than quantitative inputs on a financial model.

In relation to ESG factors, we invest in multiple countries (many developing), and our assessment takes into account ESG best practice whilst acknowledging sector and individual company differences due to local laws and regulations, cultural differences and stage of national integration of ESG when making investment decisions.

The ESG factors considered vary by the country, industry and company under review although in all cases we consider  the following factors where they are relevant and can have material impact on stock performance:

  • Environmental: Pollution, site management/consideration, greenhouse gas emissions, climate change, habitat protection, recycling, water
  • Social: Human/employee rights, working conditions, health and safety, firm-employee relations, child/forced labour, conflict zones
  • Governance: Board composition, independence, transparency, compensation and accountability, shareholder rights and relations, cyber security, protection of personal data, corruption.

A key component to our ESG process is engagement with companies, which is explained in greater detail in the next section. Engagement serves three main purposes for us as it relates to ESG integration:

  1. Due Diligence – we engage with companies, conduct due diligence and understand potential risks and opportunities relating to the investment.
  2. Education – though our engagement with companies, we are able to share best practices and provide insights into ESG practices of peers (e.g. disclosures, targets, and benchmarking).
  3. Action – we engage with companies to encourage disclosures and target setting.

We are currently looking into ways we can develop our ESG research process further by assessing the benefits of using a third-party ESG data provider  as well as the use of recognised frameworks such as TCFD’s Climate-Related Risks and Opportunities. We have engaged an independent ESG Consultant to assist us with developing our policies and processes in line with industry standards.  

3.3  Stewardship

Stewardship is typically implemented through tools including engagement and proxy voting.

The partnership is responsible for oversight of stewardship activities and acts as a point of escalation if necessary.

CCAM’s commitments to the Japan Stewardship Code and UK Stewardship Code are set out on our website:

3.3.1  Engagement

CCAM’s investment philosophy emphasises fundamental, proprietary research, to identify potential companies, supported, where possible, by direct company meetings conducted by the dedicated and experienced Asian and Japanese teams at CCAM. As well as review and assessment of third party research and engagement with country and industry experts, members of the investment team engage in one-on-one meetings and telephone calls with senior management or Investor Relations representatives of companies.

The purpose of such engagement includes:

  • understanding key drivers of growth;
  • understanding competitive positioning;
  • assessing the alignment of management goals and strategy with those of shareholders;
  • assessing corporate governance; and
  • assessing the environmental, social, governance and sustainability risk profile

CCAM’s dialogue with companies has developed over a number of years and it seeks open and constructive dialogue with management and board members, in order to broaden its knowledge of the company’s strategy, operations and risk identification and management, and to ensure any concerns CCAM might have are addressed.

The Portfolio Manager is responsible for engagement on ESG matters and monitoring is carried out via investment reviews. We do not use proxy advisors or other external service providers such as ESG rating services. Where CCAM might have specific concerns with management’s strategy, company performance (financial and non-financial), and risk profile, or where it deems it necessary to protect its clients’ interests, it will consider escalating this to senior management or seriously consider disposing of its position. In addition, once an investment is made, CCAM will engage with other institutional investors over material matters impacting all shareholders, when required.

Our propriety research incorporates company-specific data and analysis as well as information from third party research providers. We also have a propriety system which allows us to record and track engagements and assists us in reporting this activity to our clients.

Public Engagement

Aside from engagement with portfolio companies, CCAM contributes, when appropriate, to relevant and important industry consultations and we discuss wider market issues in industry media. For example, we published a piece in July 2021 in Wealth DFM magazine discussing Japan’s corporate governance reforms.

Collaborative Engagement

We generally engage with companies on an individual basis but subject to any regulatory considerations/constraints, once an investment is made, CCAM may participate in collective engagement with other institutional investors over material matters which could have a material impact on shareholder value, when required. Strong corporate governance is one of our main investment criteria, both in the initial decision-making process and an ongoing consideration, and with that in mind we typically wouldn’t expect to participate in collaborative engagement on a regular basis due in part to our investment strategy and investment into high conviction stocks and intimate knowledge of investee companies and management.

3.3.2  Proxy Voting

The primary voting policy of CCAM is to protect or enhance the economic value of its investments on behalf of its clients. CCAM will vote against any agenda that threatens this position, in particular concerns over inappropriate incentives, changes in capital structure and mergers or acquisitions which are seen as detrimental to the creation of business value. CCAM aims to vote all our clients’ shares where it has its clients’ authority to do so, assuming there are no conflicts of interest. However, there are occasions where we do not vote, principally where we have sold the shares prior to the date of the meeting. All voting decisions are made in consultation with, and approval by, the portfolio managers. Once the proxy votes are submitted, they are recorded by CCAM.

CCAM uses a 3rd party proxy voting service which provides us with holdings information, the ability to view company management recommendations and reports detailing the required elections and cast votes. The system also allows us to record historical decisions and voting statistics, many of which we share with our clients.

As we are a fundamental bottom-up investment house where we intimately know the stocks in our portfolios with all research undertaken in house, we do not take voting recommendations.

CCAM aims to vote all shares where it has its clients’ authority to do so, assuming there are no conflicts of interest. All voting decisions are made in consultation with, and approval by, the portfolio managers. Once the proxy votes are submitted, they are recorded by CCAM. Proxy voting records are available at

4. Reporting and Monitoring

Transparency: We provide a high level of transparency to investors and produce a monthly factsheet containing information covering our top positions, an extensive exposure summary, and commentary on what has worked and what has not, as well as future strategy. Full disclosure of the portfolio is available on a monthly basis to investors.

Proxy Voting Reporting: We publish our voting records on our website using the PLSA (Pension and Lifetime Savings Association) Vote Reporting Template.

Stewardship Reporting: As stewardship forms an integral part of the investment process, our approach to corporate governance and broader ESG factors in relation to our investee companies is incorporated into our client reporting as well as discussed with clients at investment review meetings. Reports detailing our engagement and voting activities are published annually. While there is an element of anonymisation on our public website, full transparency is available to all investors on request.

PRI Reporting: We report annually on our activities and progress on implementing the PRI according to the PRI reporting framework.

5. Memberships of Industry Bodies

CCAM believes that participation in industry bodies demonstrates our commitment to responsible investing, helps us to be active owners, promotes appropriate ESG disclosures and helps us to learn and enhance our effectiveness in ESG. To this end, CCAM is affiliated with the following organisations:

5.1  PRI

CCAM became signatories of the UN-supported Principles for Responsible Investment (PRI) on 6 December 2018. The PRI is fast becoming a global standard for investment managers’ ESG alignment.

As a signatory to the Principles, we publicly commit to adopt and implement them, where consistent with our fiduciary responsibilities:

  • Principle 1: We will incorporate ESG issues into investment analysis and decision-making processes.
  • Principle 2: We will be active owners and incorporate ESG issues into our ownership policies and practices.
  • Principle 3: We will seek appropriate disclosure on ESG issues by the entities in which we invest.
  • Principle 4: We will promote acceptance and implementation of the Principles within the investment industry.
  • Principle 5: We will work together to enhance our effectiveness in implementing the Principles.
  • Principle 6: We will each report on our activities and progress towards implementing the Principles.

We also commit to evaluate the effectiveness and improve the content of the Principles over time. We believe this will improve our ability to meet commitments to beneficiaries as well as better align our investment activities with the broader interests of society. CCAM reports annually to the PRI on the firm’s responsible investment initiatives, activities and achievements and seeks to meet the standards expected by the PRI in doing so.

5.2  Association of Investment Companies (AIC)

CCAM is a member of the  AIC. The Association of Investment Companies (AIC) was founded in 1932 to represent the interests of the investment trust industry – the oldest form of collective investment. Today, the AIC represents a broad range of investment companies, incorporating investment trusts, VCTs and other closed-end funds.

5.3  Alternative Investment Management Association (AIMA)

CCAM is a member of AIMA, the global representative of the alternative investment industry. AIMA promotes best practices in the industry, providing education through white papers, conferences, seminars and webinars.

6. CCAM Firm ESG Procedures

In addition to the ESG approach deployed within the investment process, CCAM believes it is important to operate its own business in line with good ESG practices. As such, CCAM has implemented the following business initiatives across the three pillars of Environmental, Social and Governance. The Partnership is responsible for ESG initiatives at the management company level and is constantly seeking to improve and enhance CCAM’s own ESG culture.

6.1  Environmental Initiatives

6.1.1  Commitment to Carbon Neutrality

  • CCAM is currently assessing third-party companies to calculate and assess our own global carbon footprint. These companies make recommendations of ways we can reduce carbon emissions over time, and in the shorter term, identify carbon offset projects that we can support to neutralise our carbon footprint. We are proud to be working towards becoming a carbon neutral organisation.

6.1.2  Waste Management

  • CCAM has taken steps to reduce paper usage to a bare minimum through the following initiatives:
    • Electronic signing tools are used (where permitted) to avoid the need to print and sign in hard copies.
    • In-person meeting attendees are offered soft copies of presentations rather than printing presentation decks on paper.
  • No plastic cups, crockery or cutlery are available in the office. Staff use reusable crockery, cutlery, and glasses, removing the use of single-use plastics from the office.
  • Recycling bins are provided throughout the office to encourage recycling. Shredded waste paper is recycled by a third party provider.
  • Filtered tap water is provided to reduce plastic water bottle waste.

6.1.3  Energy Efficiency

  • Energy efficient heating has been installed into the office and secondary glazing is on most windows to reduce heat loss.
  • Office lighting has been replaced with more energy efficient LED lighting. Lights in certain rooms turn off automatically when there is no activity. All other lights are switched off at the end of each day.
  • Staff computers are set to enter standby state when unattended or locked.

6.1.4  Travel Practices

  • Whilst some business travel is required to perform certain functions, it is kept to a minimum, with trips requiring a business reason prior to booking. Trips are organised efficiently, grouping together meetings in nearby locations where possible.
  • Trains are used where practical as an alternative to flying (e.g. UK travel or use of the Eurostar).
  • CCAM is looking into installing video conferencing facilities into its offices to support more virtual meetings where possible.
  • Staff are encouraged to walk or cycle to work where possible. Shower facilities are provided onsite to support cycling/running/walking to work. CCAM supports hybrid working where staff are encouraged to work from home part of the week, reducing the carbon footprint from commuting.

6.2  Social Initiatives

6.2.1  Equal Opportunities and Diversity Policy

  • CCAM has an Equal Opportunities and Diversity policy in place which all employees are expected to familiarise themselves with and attest to.
  • We are committed to promoting diversity and equality of opportunity for all staff and job applicants. We aim to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.
  • Staff are given appropriate training covering the value and benefits of diversity; and the legislation covering equal opportunities, discrimination and harassment. The Chief Compliance Officer has overall responsibility for equal opportunities training.

6.2.2  Employee Wellbeing

  • CCAM places significant value on the wellbeing of its staff. Several company benefits and initiatives have been implemented, designed to improve employee health, family and wellbeing and create an inclusive working culture. These initiatives include:
    • Private health insurance including mental health helpline
    • Subsidised gym benefits (provided through private health care)
    • Life coaching provided to members of staff using external coaches
    • Pensions as required by local jurisdiction law
    • Work life balance and flexibility

6.2.3  Internal Engagement

  • We actively encourage constant dialogue and interactions across business areas and seniorities. During the annual performance review, staff are also encouraged to share feedback on their experience of working at CCAM.
  • Staff training needs are identified through regular staff appraisals. All staff are given appropriate access to training to enable them to perform at their best.

6.2.4  External Engagement

  • CCAM has implemented a Corporate Social Responsibility programme where £4,000 per month is donated to charity. Two charities are selected each month, and everyone in the firm is encouraged to nominate a charity.
  • In addition, certain individuals participate on charity boards and provide their time to charities.

6.3  Governance Initiatives

6.3.1  Governance Structures and Policies

  • CCAM has implemented a suite of compliance and governing groups, policies and procedures that staff are required to adhere to.
  • All policies and procedures are reviewed and updated at least annually, including policies on Stewardship, Responsible Investing - Environmental, Social and Governance (ESG) and Engagement and Shareholder Rights. They are initially reviewed by our internal legal and compliance team, with relevant input and sign-off obtained from other internal (cross functional) teams, and are also reviewed at least annually by our external compliance consultants. This review includes consideration of any legal and/or regulatory developments and any issues arising out of the Compliance Monitoring programme (see below). They are then reviewed and approved by the governing body of CCAM. All staff are required to read and attest to policies and procedures annually and/or as and when there are material updates.
  • In addition, we share many of our policies with clients/prospective clients as part of the due diligence process and we seek feedback and welcome discussion on these policies.
  • A Compliance Monitoring Programme is undertaken on a quarterly basis which monitors the effectiveness of the policies and procedures in place and ensures any issues can be picked up and dealt with on a timely basis.
  • The monthly partnership meeting is also a forum where stewardship and ESG issues are standing agenda items. This ensures a senior level recognition of importance of these issues as well as maintaining an open dialogue on how policies and processes can be improved or updated where necessary.

6.3.2  Remuneration

  • Remuneration of staff is performance-related but in addition to the performance of the individual, CCAM will also take into account the performance of the business unit concerned and the overall results of the firm. Performance assessment will not relate solely to financial criteria but will also include compliance with regulatory obligations and adherence to effective risk management. Part of the formal year end evaluation process considers adherence to policies and procedures, including our Responsible Investing - ESG policy.
  • CCAM’s Remuneration Code promotes sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profiles, fund rules or instruments of incorporation of the client it manages. The remuneration policy is in line with the business and strategy, objective, values and interests of CCAM and the clients it manages and includes measures to avoid conflicts of interest.

6.3.3  Conflicts of Interest

  • CCAM has a Conflicts of Interest policy in place to identify and manage actual and potential conflicts of interest arising from its engagement with companies. It also maintains a conflicts register. All identified conflicts of interests are reported at least annually to senior management. The compliance department carries out a periodic review of any identified conflicts to ensure that appropriate steps have been taken to address and manage them.
  • A copy of CCAM’s Conflicts of Interest Policy can be found here:
  • The Conflicts of Interest Policy highlights that clients may have conflicting interests which impedes CCAM’s ability to fairly perform its duties. e.g. clients may not support the voting and engagement activities of CCAM where we are voting against management or engaging on issues where investee companies do not adhere to best practice. There may also be conflicts between clients, for example in the prioritisation of team resources or identifying and engaging on material aspects and topics of engagement.
  • We mitigate this risk by considering any potential conflicts between clients at the outset of any potential client relationship and during the course of the relationship. Any potential conflicts identified will be discussed at the partnership meetings and an appropriate course of action agreed to ensure that CCAM acts in the clients’ best interests at all times. This may involve declining business or terminating an existing relationship.

7. ESG Training

The ESG landscape is constantly evolving, and CCAM is keen to ensure that all staff are educated and aware of ESG developments across the investment universe. To that end, employees receive regular training and regularly collaboratively engage on a wide range of issues, including ESG, sustainability, climate change and the importance of stewardship and their integration into the investment decision-making process.

Additionally, at each quarterly meeting, the Partnership assesses whether the investment team has the required responsible investment capabilities to conduct necessary ESG research and determines whether additional training and/or resources are required.

8.    Policy Maintenance

8.1  Policy Breaches

In the event of any breaches of the ESG policy, a summary of these breaches would be included in the breaches register and escalated to the partnership, where material.

8.2  Policy Review

The ESG Policy is reviewed at least annually.

The last review of the ESG Policy was completed in December 2021.