(e) Funds that use targets for specific ESG-related metrics
If a fund’s use of one or more ESG strategies includes the use of targets for specific ESG-related metrics, such as carbon emissions, staff encourage such funds to disclose those targets as part of their investment strategies and identify if those targets may evolve or change over time in response to changing circumstances.
(f) Funds that invest in underlying funds
ESG Objective Funds and ESG Strategy Funds that invest in underlying funds that have an ESG-related focus and/or that employ ESG strategies must describe the process or criteria used to select the underlying funds27 and should disclose any parameters around the types of ESG focus(es) that the underlying funds will have.
In addition, staff’s view is that, if the underlying funds are named in the prospectus, the investment strategies disclosure should describe the ESG strategies that are used by the underlying funds. If the underlying funds are not named in the prospectus, the investment strategies disclosure should describe the ESG strategies that are used by the underlying funds, to the extent that such strategies are known.
(g) Funds that use multiple ESG strategies
ESG Objective Funds and ESG Strategy Funds that use multiple ESG strategies should provide disclosure explaining how the different ESG strategies are applied during the investment selection process. In staff’s view, this disclosure should include the order in which the strategies are applied if the specific order would have an impact on the securities being selected for the portfolio.
27 Item 5(1)(c)(iv) of Part B of Form 81-101F1.