Some funds are managed by IFMs that have general proxy voting policies and procedures that address ESG matters among other matters or have a general shareholder or issuer engagement approach that addresses ESG matters among other matters, but the funds do not use ESG-focused proxy voting or shareholder or issuer engagement as a principal investment strategy. As discussed above under “Are ESG factors considered as part of the fund’s investment process?” , depending on the particular circumstances of each IFM’ s investment process, such a fund may be a Non-ESG Fund or ESG Limited Consideration Fund.
Where such a fund is an ESG Limited Consideration Fund, the investment strategies section of the prospectus may include disclosure about the consideration of ESG issues as part of the fund’s proxy voting or engagement approach but should not suggest that E SG-focused proxy voting or engagement is a principal investment strategy of the fund. The investment strategies section should also be clear about the role that the consideration of ESG factors plays in the proxy voting or engagement approach.
Where such a fund is a Non-ESG Fund, staff’s view is that the investment strategies section of the prospectus should not include any disclosure about the consideration of ESG issues as part of its proxy voting or engagement approach.
Disclosure relating to a fund’s proxy voting policies and procedures is discussed below under “Proxy voting and engagement policies and procedures”.