Environmental Audit CommitteeWritten evidence submitted by the Environment Agency
ENVIRONMENT AGENCY PENSION FUND
1. Introduction
1.1 The Environment Agency was set up under the Environment Act 1995 and is the leading public body for protecting and improving the environment in England. We employ around 11,400 people and have an annual budget of about £1 billion.
1.2 The Environment Agency Pension Active Fund (the Fund) is a defined benefit Local Government Pension Scheme with over 23,000 members and assets of £2.1 billion. There is a 93% participation rate of eligible members. The current funding level is around 90%.
2. Fiduciary Duties
2.1 The fund’s fiduciary responsibility is to act in the best interest of its members. The Fund management recognises that financially material environmental issues, eg climate change, can adversely impact on the Fund’s financial risks and investment returns and thus should be taken into account in the investment strategy. Accordingly, the Fund has integrated the consideration of environmental, social and governance (ESG) issues throughout the funding and investment decision making process.
3. Enabling Financially Robust Responsible Investment
3.1 Early on we identified a need to be clear about our approach and what would enable us to both have quality financial returns and be confident the Fund takes proper account of ESG issues. We became the first Local Government Pension Scheme signatory of the United Nations Principles of Responsible Investment (UNPRI). The principles reflect the view that ESG issues can affect the performance of investment portfolios and therefore must be given appropriate consideration by investors if they are to fulfil their fiduciary duty.
3.2 Therefore we must:
be an open, well-funded pension fund with a long term investment time horizon;
have a strong mandate from our employers to align the interest of the organisation with those of the fund, without compromising our financial position;
have commitment and conviction from our employees in the management of the fund and the benefit to them;
integrate management of ESG issues throughout the funding strategy (mandate design, risk management, fund manager appointment and monitoring, collaborative engagement and transparent reporting); and
research and engage with the market to both help it develop and innovate so that we continually improve our investment returns within an ESG context.
Strategic asset allocation
3.3 We undertake a triennial valuation of our liabilities and review the investment strategy in response to that review. In 2010 we partnered with other asset owners globally, as part of the Mercer-led research, considering the implications of climate change scenarios on strategic asset allocation. We integrated the findings into our own review of our strategic asset allocation to inform the development of a robust portfolio, where the investment strategy is positioned to reduce risk and maximise investment opportunities presented by climate change.
3.4 In April 2013 we allocated £250 million investment for real assets covering real estate, infrastructure, forestry and agricultural land to Townsend group. The mandate places a high priority on long term responsible investments that meet our financial targets.
3.5 We are currently engaging with the market on sustainable equities with a view to go out to tender toward the end of the year.
Investment strategy design
3.6 Our Pension Committee has adopted a more flexible approach to the Active Fund future investment strategy and asset allocation so that we can respond responsibly and robustly to both the changing global economic environment and impacts of climate change.
3.7 We have set a target that by 2015 some 25% of the fund will be invested in sustainable and green economy activities. As at 31 March 2013, 13% of the fund was invested in companies which are principally engaged in the field of alternative energy, with an additional 10% in broader, but strongly sustainably themed investments, giving a total of 23%.
Fund manager selection
3.8 In 2012, we recognised that our increased allocation to emerging markets to maximise the returns to the fund, would increase the ESG risk profile of the fund. In designing the investment mandate, it was critical to find a manager with strong ESG credentials to manage these risks effectively. The quality of ESG integration formed 25% of the selection criteria for the manager selection.
3.9 The ability of managers to comply with our policies on Responsible Investment and our Environmental Overlay Strategy is assessed as part of the appointment process. The environmental assessment criteria include the relative quality, integration and impact of environmental research and information in external managers’ investment management and performance reporting processes.
Fund manager monitoring and reporting
3.10 Our fund managers are also expected to assess the impact of any financially material ESG issues in relation to future prospects of investee companies or debt, and to take this into account in their decision-making processes. When appropriate, such issues should also be addressed in our managers’ regular contact and engagement with the senior executives of companies in which the Fund’s assets are invested.
3.11 Each fund manager is required to submit a quarterly compliance report to outline any ESG considerations or analysis that have arisen, and to explain any controversial investments, as well as any engagement and voting on ESG issues that it has conducted with investee companies. Each active equity and bond manager is also required to assist the Environment Agency in assessing the annual environmental footprint of the Fund.
4. Risk Management and Moinitoring
4.1 Environmental and carbon footprinting of the active equities and bonds looks at companies’ environmental impacts. For example, how efficient they are in the amount of raw materials, water and energy used, the waste produced and carbon emitted. The footprint for each equity manager, in relation to the Fund, is compiled by allocating a proportion of the environmental impact of each company, relative to the amount of stock that is held.
4.2 Similarly, we have evaluated the environmental impact of our combined actively managed equity holdings compared to the MSCI All Country World Index (ACWI) for 2013. This is the stock market index maintained by MSCI Inc. (formerly Morgan Stanley Capital International) that incorporates both developed and emerging countries. Historically the benchmark was MSCI World Developed Countries Index but as a result of the changes to our investment strategy, most notably a significant increase in our exposure to emerging markets, we have changed the benchmark for 2013.
4.3 The Fund’s environmental footprint for combined actively managed equities was 4.7% more efficient than the benchmark and the Fund’s carbon footprint was 26% more efficient than the benchmark on 31 March 2013. Our overall footprint for actively managed equities been reduced by 39% since 2008.
4.4 For active UK bonds the portfolio was 42% (environment) and 51% (carbon) more efficient than the IBOXX benchmark, the bond market indices comprising liquid investment grade bond issues.
5. Working with Others
5.1 We will normally act through partnerships and alliances with other institutional pension funds, shareholder bodies, and asset owner organisations, but we reserve the right to act independently. This will include the UNPRI, the Institutional Investors Group on Climate Change (IIGCC) and the UK Sustainable Investment and Finance Association (UKSIF). To further support the integration of environmental governance, we are signatories to the Investor Statement on Climate Change, the Carbon Disclosure Project (CDP) and its sister projects, the Water Disclosure Project (WDP) and the Forestry Footprint Disclosure Project (FFDP).
6. Reporting and Disclosure
6.1 We publish regular updates on voting and engagement, research reports and articles on our website www.EAPF.org.uk. Each year we publish a summary of our progress in implementing our responsible investment strategy in our annual report and accounts. In 2012 we published our second Responsible Investment review, providing a comprehensive detailed of how we have implemented Responsible Investment across all the asset classes.
7. Next Steps
7.1 The Fund officers continue to research and analyse responsible investment approaches to ensure our approach to ESG issues remains in the best financial interest of Fund members. Currently, officers are undertaking a full analysis of the fund in terms of climate risk and this will be a key area for communication with members and other stakeholders. We expect to publish this work in early 2014. This, alongside the recommendations in the Green Light Report: resilient portfolios in an uncertain world (produced by ShareAction and referred to by Catherine Howarth, Chief Executive of ShareAction during the Environmental Audit Committee session 12 November 2103), will help inform the refresh of our responsible investment policies and processes.
November 2013