Funds Management

Responsible Investment Policy

The Funds Management division of Gresham Partners Limited (Gresham) is committed to maintaining an investment and funds management approach that incorporates applicable environmental, social and corporate governance (ESG) considerations.  It is our belief that ESG issues and opportunities can affect valuation, access to capital and financial performance.  The consideration of these factors can deliver better informed investment decisions and investment opportunities for our clients.

Our commitment to ESG

Gresham integrates applicable ESG considerations into our decision-making process.  We understand that ESG issues do not always clearly tie into value and returns, and the impact of ESG practices may differ across companies, sectors and regions.  However, we believe the consideration, understanding and management of ESG issues in conjunction with financial analysis can generate better long-term performance for our clients.  Further, where Gresham is in a position to actively engage with investee company management on these issues, we can actively encourage a greater awareness of ESG factors in company performance and assist those companies to create sustainable businesses that drive improved financial returns. 

We recognise the growing importance that environmental issues are playing in the global economy.  As community standards and expectations around ESG factors continue to evolve, Gresham will need to monitor and assess the potential impact of these changes on its investments.

The investment process

In analysing a potential investment, our funds management professionals are responsible for incorporating into the investment process all factors believed to have a material financial impact, which can include but are not limited to those of an ESG nature.  As Gresham manages a diverse range of funds across various sectors, ESG considerations will differ for each fund, with each investment team being responsible for ensuring an appropriate integration of ESG analysis into their individual investment processes. 

ESG considerations can cover a broad range of matters, and not all of those matters will be relevant to a particular investment.  A number of the following ESG issues may be considered by our investment teams in order to gain a better understanding of the company. 




  • Climate change
  • Occupational health and safety
  • Board structure
  • Biodiversity
  • Labour standards and human rights issues in the supply chain
  • Auditor structure and independence
  • Land contamination
  • Employee equality and diversity
  • Business ethics and conduct, including anti-bribery and corruption, anti-money laundering
  • Resource depletion
  • Community health, safety and security
  • Grievance procedures
  • Waste management
  • Local economic development
  • Executive remuneration
  • Hazardous materials / pollution
  • Indigenous peoples
  • Accounting and disclosure practices
  • Water useage
  • Cultural heritage
  • Transparency and accountability
  • Renewable energy



  • Environmental regulation including potential changes


An investment recommendation from our investment teams to their relevant investment committees will cover a wide range of factors, including views on the drivers of company returns, and the potential impact of any applicable ESG issues.  

Sector or fund-specific ESG policies may be introduced by Gresham or the relevant funds, with any such policies to take precedence over this Responsible Investment Policy. 


Whilst Gresham does not automatically preclude our funds from investing in certain sectors as a result of ESG concerns, individual funds are permitted to adopt specific exclusions if appropriate for their investment strategy.  As a general matter, Gresham will not seek to invest in companies whose core behaviours are in conflict with Gresham’s own commitment to ethical and socially responsible behaviour.    

We are committed to continually improving our approach to ESG integration, particularly as ESG standards and consideration evolve over time.  This Policy will be reviewed at least annually with any proposed changes submitted to the Gresham Board for approval.


Gresham Partners Limited


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