Written policies and procedures: During the ESG CD Reviews, staff observed that while most IFMs that manage ESG-Related Funds have written policies and procedures relating to the fund’s consideration of ESG factors and/or use of ESG strategies, or in the case of IFMs that are not the port folio adviser of their funds, their oversight of the funds’ portfolio adviser(s) in relation to the consideration of ESG factors and/or use of ESG strategies, some did not. Staff remind IFMs that an IFM that offers ESG-Related Funds should: (a) establish, maintain and apply written policies and procedures that cover its consideration of ESG factors and/or use of ESG strategies, or in the case of an IFM that is not the portfolio adviser of the funds, its oversight of the funds’ portfolio adviser(s) in relation to the consideration of ESG factors and/or use of ESG strategies; and (b) have processes in place to ensure that its written policies and procedures are regularly updated, such as for changes in its business practice, industry practice or securities legislation.19
Unless otherwise noted, the above guidance relating to investment strategies disclosure applies to all ESG-Related Funds. The following guidance applies specifically to certain types of funds and funds in certain circumstances.
19 Sections 11.1 of National Instrument 31-103 Registration Requirements, Exemptions and Ongoing Registrant Obligations and 11.1 of Companion Policy 31-03CP Registration Requirements, Exemptions and Ongoing Registrant Obligations.