Specialist in Asia Pacific, Japan, China, India and South East Asia and Global Emerging Market equities.

Discover more

Our philosophy is very simple. We are constantly searching for high quality businesses and when we acquire them, we will work relentlessly with them to create long-term sustainable value through innovation, ESG-led and proactive asset management.

Discover more

Stewart Investors manage investment portfolios on behalf of our clients over the long term and have held shares in some companies for over 20 years. They launched their first investment strategy in 1988.

Discover more

Responsible Investment Regulation

Regulatory disclosures

Portfolio carbon footprint disclosure


As to meet the requirements of the Hong Kong Securities and Futures Commission (“SFC”) Circular on Management and Disclosure of Climate-related Risks by Fund Managers (the “Circular”) issued on 20 August 2021. For the in-scope funds with a financial year-end date after the effective date of the enhanced standards on 20 November 2022, large Fund Managers are required to disclose to fund investors the portfolio carbon footprints calculated based on the positions as of the financial year-end.

While this document focuses on the disclosure of portfolio carbon footprint calculation, the rest of the required information has been disclosed either in our Climate Change Statement or on each investment team’s webpage.


Portfolio Carbon Footprint Calculation Methodology

Portfolio carbon footprint is a representation of carbon emissions normalised by the portfolio’s market value and expressed in tons of carbon dioxide equivalent emissions (CO2e) per million Hong Kong dollars invested. Below is the formula we used for the calculation of portfolio carbon footprint:

Below is the calculation methodology that ISS ESG uses, which is the same as the above methodology recommended by SFC (the PCAF methodology).

  • Emission Exposure is calculated using the following formula for “Scope 1&2”.
  • Emission Exposure = Σ𝑃𝑜𝑠𝑖𝑡𝑖𝑜𝑛 𝑂𝑤𝑛𝑒𝑟𝑠ℎ𝑖𝑝 𝑅𝑎𝑡𝑖𝑜×𝑃𝑜𝑠𝑖𝑡𝑖𝑜𝑛 𝑆𝑐𝑜𝑝𝑒 1&2 𝐸𝑚𝑖𝑠𝑠𝑖𝑜𝑛𝑠
    • where position ownership ratio = Investment Value / Enterprise Value including Cash (EVIC)
  • Carbon Footprint = Emission Exposure | Total Analysis Value (in millions of HKD)


Carbon footprints and the proportion of coverage

  • First Sentier Investors MPF Umbrella Fund (financial year end 31 December 2022)
Subjected APIFs (sub-funds): Carbon Footprint
(tCO2e / HKD m invested)
(# securities)
(% AUM)
FSSA MPF Asia Region Equity Fund 1.70 45/47 90%
FSSA MPF Hong Kong Equity Fund 6.73 43/45 96%
First Sentier MPF Asia Region Bond Fund 49.27 131/174 67%
First Sentier MPF Global Bond Fund 3.78 10/107 6%
First Sentier MPF Hong Kong Bond Fund 20.46 78/105 72%

Source of data: ISS ESG | First Sentier Investors holdings data as at 31 December 2022

  • First Sentier Investors Umbrella Funds – First Sentier Asian Bridge Fund (financial year end 30 June 2023) 
  • FSSA China All Cap Fund (financial year end 30 June 2023)
Subjected funds / sub-funds: Carbon Footprint
(tCO2e / HKD m invested)
(# securities)
(% AUM)
First Sentier Asian Bridge Fund 10.6 92/161 67%
FSSA China All Cap Fund 3.7 50/52 97%

Note: For the First Sentier Asian Bridge Fund, carbon footprint is calculated by weighted average of the equity and fixed income portfolio by their AUM as at 30 June 2023. The standalone figures for the equity portfolio and fixed income portfolio are 2.1 and 22.6 (tCO2e / HKD m invested), respectively.

Source of data: ISS ESG | First Sentier Investors holdings data as at 30 June 2023


Underlying assumptions and limitations

  • Only the carbon emissions emitted by corporates have been captured in the carbon footprint calculation (carbon emissions associated with cash, cash equivalents, derivatives and sovereign debt are not within the scope).
  • Limitations to the data provided from third parties will stem from their coverage and methodologies and from limited disclosures by issuer companies. Where data is not available, third party providers may use estimation models or proxy indicators. Methodologies used by data providers may include an element of subjectivity.
  • Whilst data is collected on an ongoing basis, in this rapidly evolving environment, data can become outdated within a short time period.
  • Low coverage of in-scope (corporate) AUM for certain funds is due to 1) lack of enterprise value data; 2) lack of carbon emissions data from companies; 3) company is out of scope for the ISS ESG database; or 4) high proportion of sovereign bonds which the aforementioned calculation methodology cannot be applied.
  • There is a potentially undesired side effect related to attributing the issuer’s absolute emissions to its total equity and debt position (using EVIC). While lower emissions would typically be achieved by encouraging issuers to reduce their absolute emissions (numerator), the recommended calculation methods imply that a similar effect could be achieved by increasing the denominator (either the issuer’s equity or debt position).