At Stewart Investors, we believe in putting people first. Our investment world-view is of a series of partnerships – with each other, with our clients, with the companies we invest in, the people who buy their goods and services, and with the wider society in which we all live and work.

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Reports and policies

Reports and policies

At First Sentier Investors, responsible investment principles underpin our investment approach. Our reports and policies detail our beliefs and how we translate these into action.


Responsible Investment Report

As long-term investors, we know that the decisions we make today impact communities today, tomorrow and years from now. Responsible Investment is at the core of how we operate as a business and allocate capital, and we are committed to transparency and accountability regarding our performance in this area.

Stewardship Report 2022

In our latest Stewardship Report, learn how we act as stewards of our clients' capital, with a focus on investment excellence that seeks to deliver strong investment performance in conjunction with positive, real-world outcomes.

Global policy and principles

Our Global Responsible Investment and Stewardship Policy and Principles articulate our approach to responsible investment, what it means to us and how we implement it.

Our Policy document sets out the responsible investment and stewardship standards that all investment professionals are expected to adhere to in practice, including specific expectations in relation to environmental, social and governance (ESG) integration, corporate engagement, proxy voting and investment screens. This should be read in conjunction with the Principles document, which communicates the beliefs that underpin our approach to responsible investment. This includes our position in relation to our four focus areas: climate change, nature and biodiversity, human rights and modern slavery, and diversity; and our internal governance structure with respect to responsible investment, investment stewardship and ESG.

The Principles document was approved in September 2023, and the Policy document was approved in February 2024. Both documents were approved by the Global Responsible Investment Executive Committee following extensive consultation with investment team members and other stakeholders in the business.

Global Responsible Investment and Stewardship Policy

Please read in conjunction with the Principles

Global Responsible Investment and Stewardship Principles

Please read in conjunction with the Policy

Climate change

In developing our Climate Change Statement, we sought to align our disclosure with the Task Force for Climate Related Financial Disclosure's recommendations and the Investor Group on Climate Change's Guide for Investor Disclosure, Strategy, Governance, Risk Management and Metrics.

Climate Change Statement 2H2023

Learn how we will reach our goals in our latest Climate Change Statement (covering 1 Jul - 31 Dec 2023)

Climate Change Statement 2023

Read our previous statement

Climate Change Statement 2022

Read our 2022 statement

Climate Change Action Plan 2023

Our action plan sets out the steps and pathways we are taking to meet our net zero ambitions

Climate Change Action Plan 2022

Read our 2022 Climate Change Action Plan

Human rights

We have focused our attention on the development of tools to monitor our investment strategies and supply chains.

Modern Slavery Statement

Learn of the progress made in bringing this issue into sharper focus for the companies we engage with, and within our own business and supply chains.


In a diverse global organisation, good governance is extremely important. Governance of responsible investment and stewardship engages over 50 people across our organisation, allowing staff to participate in, and be kept up to date on our responsible investment work.


Our approach to exclusions is outlined in section 2.10 of our Global Responsible Investment and Stewardship Policy. Our current exclusions are as follows:

Controversial weapons

  • Anhui GreatWall Military Industry Co, Ltd
  • BAE Systems Plc
  • Bharat Dynamics Ltd
  • Daikin Industries
  • General Dynamics Corp
  • ICL Group Ltd
  • L3Harris Technologies
  • Larsen & Toubro Ltd
  • LIG Nex1 Co, Ltd
  • Northrop Grumman Corp
  • Poongsan Corp
  • Pretis dd
  • Rheinmetall AG
  • Walchandnagar Industries Ltd


  • 22nd Century Group, Inc
  • Al-Eqbal Co. for Investment Plc
  • Altria Group, Inc
  • B.A.T. Capital Corp
  • B.A.T. International Finance Plc
  • B.A.T. Netherlands Finance BV
  • BAT Brasil
  • British American Tobacco Bangladesh Co
  • British American Tobacco Holdings (The Netherlands) BV
  • British American Tobacco Kenya Plc
  • British American Tobacco Malaysia Bhd
  • British American Tobacco plc
  • British American Tobacco Uganda Ltd
  • British American Tobacco Zambia Plc
  • British American Tobacco Zimbabwe Ltd
  • Bulgartabac Holding AD
  • Ceylon Tobacco Co Plc
  • China Tobacco International (HK) Co Ltd
  • Coka Duvanska Industrija AD
  • Duvanska Industrija AD Bujanovac
  • Eastern Co (Egypt)
  • Godfrey Phillips India Ltd
  • Golden Tobacco Ltd
  • Hoang Long Group
  • Imperial Brands Finance Netherlands BV
  • Imperial Brands Finance Plc
  • Imperial Brands Plc
  • ITC Ltd
  • Japan Tobacco, Inc
  • Jerusalem Cigarette Co Ltd
  • JT International Financial Services BV
  • Karelia Tobacco Co, Inc
  • Khyber Tobacco Co Ltd
  • KT&G Corp
  • Lorillard LLC
  • LT Group, Inc
  • Ngan Son JSC
  • Nikotiana BT Holding AD
  • NTC Industries Ltd
  • Old Holdco, Inc
  • Pakistan Tobacco Co Ltd
  • Philip Morris (Pakistan) Ltd
  • Philip Morris CR as
  • Philip Morris International, Inc
  • Philip Morris Operations AD
  • PT Bentoel International Investama Tbk
  • PT Gudang Garam Tbk
  • PT Hanjaya Mandala Sampoerna Tbk
  • PT Indonesian Tobacco Tbk
  • PT Wismilak Inti Makmur Tbk
  • Pyxus International, Inc
  • Reynolds American, Inc
  • Scandinavian Tobacco Group A/S
  • Shanghai Industrial Holdings Ltd
  • Sila Holding AD
  • Sinnar Bidi Udyog Ltd
  • Slantse Stara Zagora Tabac AD
  • Standard Diversified, Inc
  • STG Global Finance BV
  • Swedish Match AB
  • Tanzania Cigarette Co Ltd
  • Turning Point Brands, Inc
  • Tutunski Kombinat AD Prilep
  • Union Investment Corp
  • Union Tobacco & Cigarette Industries Co
  • Universal Corp
  • Vector Group Ltd
  • VST Industries Ltd
  • West Indian Tobacco Co Ltd

Industry collaboration

We support a number of industry and trade groups that are focused on developing and improving responsible investment. While these groups do not speak for us unless we specifically sign a statement they draft, we are aligned with their broader missions.

Each year, we review the various initiatives that we have been involved with. We do this to ensure their purpose aligns with our clients’ interests and that we have the capacity to make a meaningful contribution. The initiatives that we actively support and engage with are listed here:


PRI (2007)

  • Signatory
  • Pilot sovereign engagement, member (2023)
  • Spring (PRI stewardship initiative on nature) endorser (2023)

Finance for Biodiversity pledge (2021)

  • Signatory

Task Force on Climate-Related Financial Disclosures (2021)

  • Supporter

Tobacco Free Portfolios Pledge (2021)

  • Signatory

Cambridge University Investment Leaders Group (2013)

  • Founder member
  • Nature Working Group member (November 2023)

Climate Action 100+ (2017)

  • Supporting Investor

Task Force on Nature-related Financial Disclosure (TNFD) Forum (2022)

  • Forum member

Big Tech and Human Rights Investor Collaboration (2023)

  • Collaborating Investor

Nature Action 100 (2023)

  • Investor Participant, member of engagement team with two companies



UK Sustainable Investment Forum (2013)

  • Member

EUROSIF* (2013)

  • Public Policy Working Group

* Only national SIFs are members of EUROSIF. FSI participate in EUROSIF monthly Public Policy Group as a guest/non-member.

FAIRR (2023)

  • Investment member

World Benchmarking Alliance (2023)

  • Ally


Asia Pacific

Financial Services Council (2020)

  • Member of the Fund Management Board Committee
  • Member of the Investment Expert Group
  • Member of the ESG Working Group
  • Director of the FSC Board

Investor Group on Climate Change (2013)

  • Member

Australian Sustainable Finance Initiative (2022)

  • Member of Coordinating Working Group
  • Member of Technical Working Group

Responsible Investment Association Australasia (2013)

  • Board Member
  • Member of the Human Rights Working Group
  • Member of the Nature Working Group

30% Club Australia (2018)

  • Investor Working Group member

40:40 Vision (2020)

  • Steering Group member
  • Investor Working Group member

Women in Sustainable Finance (2019)

  • Committee member

Investors Against Slavery & Trafficking APAC (2019)

  • Chair

Japan Sustainable Investment Forum (JSIF) (2021)

  • Signatory

Japan Stewardship Initiative (JSI) (2021)

  • Signatory

Hong Kong Green Finance Association (2023)

  • Member


Policy advocacy

We have actively participated in a number of consultations and initiatives that we believe support the transition to a more sustainable financial system.


Future Regulatory Regime for ESG ratings providers

In June 2023 First Sentier Investors provided a submission to His Majesty's Treasury consultation paper 'Future regulatory regime for Environmental, Social, and Governance (ESG) ratings providers', detailing our view on the topic. 

Sustainability Disclosure Requirements (SDR) and investment labels

The Financial Conduct Authority requested feedback on their consultation paper 'Sustainability Disclosure Requirements (SDR) and investment labels' in October 2022. This consultation paper proposed new rules to help consumers navigate an increasingly complex investment product landscape, protect them from greenwashing and rebuild trust. First Sentier Investors provided a consultation response to this paper.

Eurosif, PRI, IIGCC, EFAMA, UNEP FI - Joint statement on ESRS

First Sentier Investors was signatory on a letter which called on the European Commission to uphold the integrity and ambition of the first set of the European Sustainability Reporting Standards (ESRS), as envisaged within EFRAG’s final technical advice to the Commission published in November 2022.

ESA's Call for Evidence on better understanding greenwashing

The European Supervisory Authorities (ESA) made a Call for Evidence in November 2022, seeking input from stakeholders on how to understand the key features, drivers and risks associated with greenwashing and to collect examples of potential greenwashing practices. First Sentier Investors responded to this Call for Evidence in January 2023.

FCA’s Guidance on the Anti-Greenwashing Rule

In January 2024, First Sentier Investors provided a response to FCA’s consultation on ‘Guidance on the Anti-Greenwashing Rule’ GC23/3.

Asia Pacific

Enhancement of Climate-related Disclosures under the Environmental, Social and Governance Framework

First Sentier Investors submitted a consultation response to the Hong Kong Stock Exchange’s consultation paper 'Enhancement to Climate-related disclosures under the Environmental, Social and Governance Framework'. This paper made the proposal to the Hong Kong Exchange to mandate all issuers to make climate-related disclosures in their ESG reports.

GHG Reduction Safeguard Mechanism Reform

In February 2023, First Sentier Investors provided feedback on the Department of Climate Change, Energy, Environment and Water’s consultation on the proposed reforms of the Safeguard Mechanisms. First Sentier Investors’ submission detailed its support for the proposed changes to the Safeguard Mechanism.

Climate-related financial disclosure Consultation paper

In December 2022, the Australian Government Treasury asked for initial views on key considerations for the design and implementation of standardised, internationally-aligned requirements for disclosure of climate-related financial risks and opportunities in Australia, for their consultation paper on Climate-related financial disclosure. First Sentier Investors made a submission in February 2023.

Australian Sustainable Finance Strategy Consultation

In December 2023, the Australian Government released its consultation paper on Australia's Sustainable Finance Strategy. First Sentier Investors provided a response to this paper, explaining our views on the topic.