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Responses and Representations

A key part of our work as a voice championing the sustainable finance industry is responding to policy consultations and inquiries held by the Government, Parliament and regulators to help them develop policies in relevant areas.  We also represent our members by working to lobby the government on key legislative and political developments affecting the industry.

To see our pre-2009 policy responses and representations, please click here.

Recent activities on our current policy priorities:

2018

UKSIF Policy Update: DWP clarifies trustees’ fiduciary duties in law - 13th September

 The Department for Work and Pensions (DWP) announced this week (11th September) new regulations which will clarify trustees’ fiduciary duties including consideration of ESG factors. These new rules for trust-based pension schemes follow a public consultation which took place over the summer and are a response to the Law Commission’s 2017 report on pension funds and social investment.

UKSIF Press Release on DWP Investor Duties Announcement – 11th September

UKSIF’s response to the Government’s announcement that trust-based pensions schemes will be required to develop policies on how they integrate financially material factors including ESG and climate change.

UKSIF response to DWP consultation on fiduciary duties – 16th July

UKSIF’s submission to the DWP consultation on clarifying the investment duties of pension trustees. This is a key policy priority for UKSIF, and our submission argued strongly for statutory rules which require trustees to consider financially material ESG factors and that where appropriate members’ views may also be considered. 

UKSIF Member Policy Update webinar – 27th June

A member-only policy briefing webinar to discuss new Government proposals to clarify the fiduciary duties of pension schemes in law, in particular requiring schemes to consider and state publicly their approach to ESG factors as well as the views of their members on social investment and ethical issues.

UKSIF response to the European Commission proposals to amend MiFID II – 21st June

UKSIF’s submission to draft proposals to and MiFID II to require financial advisers to ask clients about their sustainability and ESG preferences. This was a key recommendation from the HLEG on Sustainable Finance and the European Commission Action Plan on Sustainable Finance. UKSIF fully supports the idea, although had concerns with the way the legislation had been worded.

UKSIF Policy Update: Government commits to clarification of concept of fiduciary duty in law – 18th June

Fantastic news as DWP and the FCA have both committed to legislative changes to require all UK pension schemes to consider financially material ESG factors during the investment process. New rules will also require schemes to have a policy on how they consider members’ views on non-financial issues and on their stewardship activities.

UKSIF Policy Update: The Government’s response to its advisory group report on boosting UK social impact investing – 14th June

UKSIF sent the following policy update to members which outlines the Government’s commitments in response to the “Corley Report” on social impact investing in the UK. Among other things it calls for clarification of fiduciary duty, and notes a Government aspiration for schemes to target a minimum percentage allocation to social investments.

Press Release: New rules to tackle climate change risks proposed for Pension Schemes by Parliamentary committee – 4th June

UKSIF’s press release covering the Environmental Audit Committee’s new report, Greening Finance, in which the committee calls for clarification of fiduciary duty and UKSIF is quoted extensively. 

UKSIF Policy Update: The Green Finance Taskforce – 28th March

UKSIF issued the following policy brief to members which outlined the recommendations of the Green Finance Taskforce.

UKSIF Policy Update: European Commission Action Plan on Sustainable Finance - March

The following update was sent to members and outlines the ten overarching recommendations by the EU Commission as part of its Action Plan on sustainable finance.

UKSIF response to the FRC’s Corporate Governance Code Review – 28th February

UKSIF’s response to the Financial Reporting Council’s Corporate Governance Code Review called for more prominent and explicit reference to ESG and sustainability throughout the Code, as well as reference to the TCFD recommendations and the Sustainable Development Goals. The consultation also contained some questions on stewardship ahead of a fuller Stewardship Code Review later this year.

UKSIF response to the European Commission Consultation on Investor Duties – 22nd January

UKSIF’s response to the European Commission’s investor duties consultation. We strongly supported a duty on European investors which incorporates consideration of environmental, social and governance factors. 

UKSIF Policy Update: European Commission Consultation on Investor Duties – 15th January

UKSIF issued the following brief to members highlighting the investor duties consultation and providing some suggested answers. This work stemmed directly from the High Level Expert Group on Sustainable Finance interim report.

UKSIF submission to the Environmental Audit Committee Inquiry on Green Finance – 3rd January

As well as giving oral evidence, UKSIF sent the following written submission to the Committee.

2017

UKSIF response to DWP consultation on investment disclosure – 7th Dec

UKSIF’s submission to the consultation focussed on investment disclosures and a more expansive Statement of Investment Principles for pension schemes.

UKSIF Policy Update: Investment Management Strategy II – 6th December

UKSIF has produced the following brief for members on the IMS II which covers green finance, social investment and Islamic finance.

UKSIF Policy Update: 2017 Budget Statement Member Briefing – 22nd November

UKSIF has produced the following brief for members on relevant aspects of the 2017 budget statement.

UKSIF submission to the Work and Pensions Select Committee Inquiry on Freedom and Choice in Pensions – 1st November

UKSIF submitted selected Good Money Week polling to the Work and Pensions Select Committee to outline saver demand.

UKSIF submission to the UK budget 2017 – 22nd  September

UKSIF’s submission to the Treasury ahead of the UK 2017 budget statement which focussed on mandating the FCA to consider climate risk.

UKSIF response to the High Level Expert Group on Sustainable Finance interim report - 18th Spetember

UKSIF’s response to the High Level Expert Group on Sustainable Finance interim report. This submission was based on significant member feedback including an all member webinar, a roundtable discussion and several meetings and calls

UKSIF Policy Update: Government Announces Corporate Governance Reform Package - 29th August

UKSIF has produced the following policy update for its members following the Government’s “world leading” package of corporate governance reforms. These focus on executive pay, employees’ voices and corporate governance in privately held businesses.

UKSIF Policy Consultation – EU High-Level Expert Group on Sustainable Finance briefing webinar slides – 17th August

Slides used during the UKSIF-member webinar to brief members on the HLEG on Sustainable Finance.

UKSIF response to the PQM consultation to improve standards for DC accreditation schemes – 21st July

UKSIF’s respond to the PQM consultation which proposes requiring accredited schemes to outline their approach to ESG and stewardship.

Press release on a new consultation by the Pension Quality Mark to improve standard for DC accreditation schemes, July 18th

Summary – Law Commission: Pension Funds and Social Investment, June 26th

A policy brief on the Law Commission’s recent report on pension funds and social investment. Recommendations include amending the investment rules to clarify trustees’ fiduciary duties, requiring contract-based schemes to outline their approach to ESG and stewardship and to require the FCA to publish guidance on financially material and non-financial factors.

New UK Government, 21 June

Cabinet and ministerial changes following the election and the potential impact for the responsible investment sector.

UKSIF 2017 General Election Manifesto Highlights

UKSIF produced the following guide to political party manifestos for members for the 2017 General Election.

UKSIF response to FCA consultation on FAMR implementation part 1, 26 May

Following the Financial Advice Market Review the FCA is consulting on implementation of the FAMR recommendations. This is UKSIF’s response to the consultation which focuses on making it easier for retail investors to invest in-line with their values.

UKSIF letter to Prime Minister ahead of G7 meeting in Sicily, 24 May

UKSIF has written to the Prime Minister and other Government ministers ahead of the G7 meeting in Sicily on the importance of world leaders reaffirming their commitment to the Paris Agreement.

UKSIF response to the Industrial Strategy Green Paper, 11 April

Following engagement with members, UKSIF responded to the Government’s Industrial Strategy Green Paper. Our response highlights ways to support private investment into infrastructure and how to encourage longer-term investment decisions in the investment chain.

Policy update: New Investment Guidance for Defined Benefit Pension Schemes, 30 March

An UKSIF policy brief following the publication by TPR of new investment guidance for trustees of defined-benefit pension schemes.

UKSIF submission to FCA Asset Management Market Study (AMMS), 20 Feb

UKSIF responded to the AMMS and highlighted that the increase in demand for SRI investing is already and will continue to transform the asset management industry, this this focus on responsible investment will likely result in increased costs and that the FCA should be cautious in its approach to avoid stifling innovation and allowing the sector to evolve.

UKSIF response to the Government’s corporate governance review, 17 Feb

UKSIF’s response to the BEIS corporate governance green paper highlighted the strength of the current corporate governance regime in the UK and focused on the need for any reforms to stop short-termism and encourage well performing companies over the long-term.

UKSIF summarised response to the consultation on TCFD Recommendations, 10 Feb

UKSIF responded to the consultation on the TCFD recommendations. We welcomed the TCFD’s work, but highlighted more should be done for the banking sector.

UKSIF submission to FCA Our Future Mission consultation, 29 Jan

UKSIF responded to the FCA’s consultation on its future mission, highlighting that without proper consideration of the impact of climate change and other ESG factors, it risks failing in its statutory and operational objectives.

2016

UKSIF response to LC consultation on DC pension funds and social investments, 21 Dec

The Law Commission was asked by the Government to review the legal and regulatory barriers to social investment by pension funds. UKSIF’s response highlighted high costs, rules around daily dealing and a lack of financial awareness as key barriers which need to be addressed before social investment by pension funds can reach its full potential.

UKSIF Response to BEIS Select Committee inquiry into corporate governance. Nov

UKSIF responded to the BEIS Select Committee inquiry into the UK corporate governance regime, ahead of the Government consultation scheduled for later this year.

UKSIF response to the PMI and APPT consultation on a Diploma in Professional Trusteeship, 29 Sept

LGPS Guidance on Preparing and Maintaining an Investment Strategy Statement Statement, Policy Update 21 Sept

UKSIF Response to 21st Century Trusteeship and Governance, 9 Sept

UKSIF Response to House of Lords Select Committee on Charities Call for Evidence, 5 Sept

UKSIF Response to Mission-led Business Review, 3 August

One Month after Brexit Policy Update, 27 July 

SRI Post-Brexit, 5 July

UKSIF letter to the Charity Commission on social investments, 1 June

UKSIF letter to the FSB on the Task Force on Climate-related Financial Disclosures and Response to the TCFD Consultation May

UKSIF Response to the Pensions Regulator Code of Practice Guidance for DC Scheme Consultations, 11 May

UKSIF letter to Secretary of State for Energy and Climate Change on 5th Carbon Budget, 9 May

UKSIF Response to Department for Business, Innovation and Skills consultation to transpose the Non-Financial Reporting Directive into UK Law, 15 April

UKSIF letter to the Charity Commission on CIIs and the McCall opinion, 30 March 2016

UKSIF Policy Update: Budget 2016 Highlights, 16 March

UKSIF Response to FCA Regulatory Barriers to Social Investment, 14 March

UKSIF Press Release: New Government rules could hinder councils’ long-term investment and damage savings, 24 Feb

UKSIF Response to Department for Communities and Local Government’s consultation on Revoking and Replacing the Local Government Pension Scheme (Management and Investment of Funds) Regulations 2009, 19 Feb

UKSIF Response to Environmental Audit Committee’s inquiry on sustainability and HM Treasury, 18 Feb

UKSIF response to The Pensions Regulator (TPR) DC Code of Practice update, Jan

UKSIF response to All Party Parliamentary Group on Financial Education for Young People’s call for input, 22 Jan

 2015

UKSIF response to HM Treasury and FCA call for input on the Financial Advice Market Review (FAMR), 22 Dec

 UKSIF Submission to the Asset Management Market Study, 18 Dec

 UKSIF response to the Government consultation Better Workplace Pensions: Reducing regulatory burdens and response to consultation on the investment regulations, Dec 2015

UKSIF response to Government announcement on fiduciary duty, 13 Nov

UKSIF letter response to ECC inquiry on investor confidence in UK energy system, 23 Oct

CDP, IIGCC and UKSIF consultation response to ‘Reforming the business energy efficiency landscape’, Oct

UKSIF response to HM Treasury’s consultation on pensions tax relief, 30 Sept

UKSIF Press Release: Investor letter to Chancellor on support for renewables, 10 Sept

UKSIF co-ordinated letter: Investor letter to Chancellor on support for renewables, 10 Sept

UKSIF response to EAC inquiry on the Government’s approach to sustainable development, Aug

UKSIF letter response to ECC inquiry on future work programme, 20 July

 

1) Long-termism and ESG Investing

  • 2015

Jun: UKSIF Press Release: Response to G7 commitment to decarbonise the economy

May: Article by Fergus Moffatt for Responsible Investor on the importance of clarifying fiduciary duties

May: UKSIF General Election Manifesto Highlights

Apr: UKSIF response to the Department for Work and Pensions’ Consultation on changes to the Occupational Pension Scheme Regulations

Apr: UKSIF Press Release: Fiduciary Duty: Financially material factors should be taken into account by trustees

  • 2014

Nov: UKSIF submission to Environmental Audit Committee Inquiry on Sustainable Development Goals (SDGs)

Oct: UKSIF response to FCA Consultation Paper CP14/16: Proposed Rules for Independent Governance Committees

Sep: UKSIF response to FCA Consultation Paper CP14/11: Retirement Reforms and the Guidance Guarantee

Sep: Letter from Minister of State for Pensions responding to UKSIF-coordinated letter regarding the Law Commission’s recommendations on Fiduciary Duties of Investment Intermediaries 

Sep: Letter from The Rt. Hon Vince Cable MP responding to UKSIF-coordinated letter regarding the Law Commission’s recommendations on Fiduciary Duties of Investment Intermediaries 

Jul: UKSIF response to Department for Communities and Local Government on the Local Government Pension Scheme consultation

Jul: UKSIF-coordinated letter to the Secretary of State for Business, Innovation and Skills, The Rt. Hon Vince Cable MP, and Minister of State for Pensions, Mr Steve Webb MP, regarding the Law Commission’s recommendations on Fiduciary Duties of Investment Intermediaries 

Jul: UKSIF Press Release: Investors representing £550bn ask Government for Statutory Clarification of Fiduciary Duty

Jun: UKSIF response to HM Treasury on the Freedom and Choice in Pensions consultation

 

2) Green Finance

  • 2014

 

3) Impact Investment

  • 2014

4) Activities in other policy areas